Solihull Local Plan (Draft Submission) 2020

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Solihull Local Plan (Draft Submission) 2020

Policy P4A Meeting Housing Needs – Affordable Housing

Representation ID: 10945

Received: 14/12/2020

Respondent: West Midlands Urban Community Homes

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The omission of specific reference to Community Led Housing (CLH) reduces the soundness of the Local Plan. CLH groups and organisations are extremely well placed to deliver on the aspirations outlined in the introduction to the ‘Providing Homes for All’ policy chapter and to meet Challenge B identified in the Plan. Namely to provide a broad range of housing of different types, sizes, values and tenures that are responsive to needs, particularly that for affordable housing, creating and maintaining mixed and balanced communities. Examples of reasonable alternative policies are included.

Change suggested by respondent:

wMUCH asks SMBC to consider making explicit reference to Community Led Housing, as a mechanism for Providing Homes for All, within the Local Plan and/or in supplementary policy such as the Meeting Housing Needs Supplementary Planning Document (SPD). This could be either as a dedicated policy, or embedded across other policy topics.

Noting support for community based initiatives within Local Plan policy gives considerable weight to the acceptability of this form of development. In turn this gives confidence to community groups to pursue CLH. Linking community led solutions to delivering sustainable development and creating more resilient communities encourages CLH groups to look at what additional benefits can be delivered through their scheme.

It is good practice to have a coherent suite of planning documents for CLH. This would include policy in the Local Plan, a bespoke SPD or including a CLH section in a housing SPD, and tailored S106 Agreement templates. Together these support transparent and consistent decision making. They also provide clarity to communities of what is expected of them and the parameters within which they need to design a scheme.

wMUCH is in contact with the colleagues in the SMBC Economy & Infrastructure and Places Directorates about ways in which SMBC can enable CLH. We would welcome the opportunity to discuss further supplementary policy and strategy development with SMBC across housing and planning. For instance, we have recently supported another local authority to develop a dedicated community led housing policy, to sit alongside existing housing and planning policy.

About us
West Midlands Urban Community Homes (wMUCH) is a new enabler hub to provide knowledge and expertise to inspire and support a new wave of CLH in the West Midlands. We are the lead dedicated CLH support organisation in the region, funded by the Ministry of Housing, Communities and Local Government and Power to Change as part of a national network of hubs. We provide advice and support to CLH groups and organisations to help them plan and deliver their projects, as well as collaborating with strategic partners such as SMBC to enable CLH.

Full text:

West Midlands Urban Community Homes (wMUCH) believes that omission of specific reference to Community Led Housing (CLH) reduces the soundness of the Local Plan.

What is community led housing?
The definition of Community Led Housing agreed by Government, Homes England and national infrastructure bodies is:

1. Open and meaningful community participation and consent takes place throughout the development process. Communities do not have to initiate the scheme or build the homes themselves, but many do.
2. The community group or organisation owns, manages or stewards the homes in whichever way they decide to. There is a presumption that they will take a long-term formal role.
3. The housing development is of true benefit for the local community, a specific group of people (an intentional community), or both. These benefits are clearly defined and legally protected in perpetuity.

CLH includes a variety of models such as cohousing, community land trusts (CLTs), community self-build, development trusts, housing co-operatives, self-help housing, tenant management, mutual home ownership and potentially other new innovative models. It includes new build, renovation of existing buildings and regeneration and it can operate across any tenure – home ownership, shared ownership and market, affordable and social rented homes.

The benefits of community led housing and alignment with SMBC’s policy objectives outlined in the Local Plan

CLH schemes open up housing opportunities to a wide range of people who are currently unable to find a home they can afford or that meets their needs. That these developments are led and owned by the community means they attract high levels of support. The benefits of CLH are broad and include the following:

Housing – a way of doing more, differently
• Enhancing affordability permanently and meeting local need
• Diversification of housing providers and housing choice
• Increasing supply by building homes where other providers cannot operate
• Bringing in resources not accessible to other housing providers through commercial and social lenders, charitable funds, crowdfunding, community bonds and members’ own labour.
• Supporting regeneration and returning empty homes to use

We believe that the benefits outlined above are very aligned with SMBC’s policy intent set out in the Draft Local Plan, particularly in the introduction to the ‘Providing Homes for All’ policy chapter. Namely to provide a broad range of housing of different types, sizes, values and tenures that are responsive to needs, particularly that for affordable housing, creating and maintaining mixed and balanced communities.

As outlined in the Foreword to the Draft Local Plan, this is not just about the numbers. We need quality and diverse housing that can be assimilated into, and support, our existing communities. wMUCH believes that CLH groups and organisations are extremely well placed to deliver on these aspirations and meet Challenge B identified in the Plan.

Vibrant communities – a strong social fabric
• Strong, mutually supportive and resilient communities, important for COVID 19 recovery
• Tackling loneliness and isolation, with increased sense of belonging and improved wellbeing
• Building cohesive communities and helping to reduce anti-social behaviour
• People are empowered to make decisions and participate in their community
• Independence and security for different groups by meeting their support needs, such as older and vulnerable people
• Improved financial situation, stability of ownership/ occupancy and liveability for individuals
• Stabilising new settlements/ community building in new neighbourhoods
• Creating a sense of place and identity
• Creating shared amenities and facilities for the community

A healthy local economy
• Supporting the local economy through local supply chains
• Community asset ownership and wealth building, long term income for communities
• Tackling structural inequality by empowering groups who have traditionally been excluded from asset ownership
• Enhancing provision of other community based social enterprise
• Providing skills, training and jobs for local people, particularly construction skills
• Enabling people to remain in their local area and ensuring that schools, services and amenities remain viable
• Contributing to the green agenda and the transition to zero carbon through energy efficient and sustainable homes

We believe that these benefits have an important role to play in meeting Challenge F identified in the Draft Local Plan – Reducing inequalities in the Borough.

There is a range of research and evidence about the benefits of CLH, such as CCIN’s report ‘CLH: A Key Role for local authorities’ , in the ‘business case for CLH’ in the associated CLH toolkit , from the New Economics Foundation , in the Commission on Co-operative Housing’s ‘Bringing Democracy Home’ report , and from Capital Economics about CLH’s high value for money.

Alignment with national planning policy

The process by which CLH is developed and the homes it provides helps LPAs achieve some of the requirements placed on them by the National Planning Policy Framework (NPPF) and statute, including:
• Fulfil the purpose of planning to promote sustainable development. Through the development process and what they provide CLH schemes are integrated action that provides social, economic and environmental benefits.
• Assess and reflect in Local Plan policy the size, types and tenures of housing for different groups. CLH responds directly to the specific housing needs within a particular community across the range of housing types, sizes and tenures
• Early engagement to improve the effectiveness of the planning application system with better co-ordination between public and private resources and better outcomes for communities. CLH provides a direct route for planners to engage early and work in collaboration with communities on development proposals.
• Housing Act 2016 requires Local Planning Authorities (LPAs) to make land available to meet the demand on their self-build registers. By adopting policy and practice that supports CLH, LPAs will be taking steps towards meeting this statutory requirement as CLH falls within the statutory definition of Self and Custom Build housing.

Reasonable alternatives

There are examples from elsewhere in the country where planning policy does make explicit reference to community led housing or community led development. Most commonly, CLH has been supported in Local Plans by embedding it in a raft of generic policies, which in combination open up opportunities for CLH delivery, including Self and Custom Build. Alternatively, but to date less frequently, Local Plans may adopt a bespoke Community Led Development policy.

Examples of specific policies for Community Led Development in Local Plans include:
• Test Valley Local Plan - adopted 2016 Policy COM9: Community Led Development
• East Cambridgeshire Local Plan 2015 Policy GROWTH 6: Community-led development

As aforementioned, the most common approach is for CLH to be noted in a number of policies throughout the Local Plan. In so doing policy opens up site opportunities of different sizes, in different locations and at prices that make it viable to deliver CLH. There is potential relevance for CLH across the policies within the ‘Providing Homes for All’ section of the draft submission plan. There is particular relevance for the policies below and there are examples from elsewhere in the country where CLH has been embedded into these policy topics :

• Overarching policy statements on the provision of the right type of housing. An example is the New London Plan - draft with minor modifications, which says: 1.4.5A The homebuilding industry itself also needs greater diversity to reduce our reliance on a small number of large private developers. New and innovative approaches to development, including Build to Rent, community led housing, and self and custom-build, will all need to play a role, and more of our new homes will need to be built using precision-manufacturing.
• Policy P4A Meeting Housing Needs – Affordable Housing. Arun District Council Local Plan -adopted July 2018 Paragraph 12.3.10. states that Community Land Trusts (CLTs) will be promoted by the Council as one mechanism for delivering additional affordable housing in Arun. Leeds City Council has also developed a formal local qualification for alternative providers of affordable housing. The Council’s template for Section 106 Agreements makes provision for alternative providers of affordable housing. It was used to allow for part of a market development to be transferred to a CLH organisation.
• Policy P4B – Meeting Housing Needs – Rural Exceptions. An example is East Devon Local Plan 2013 -3031 Strategy 27: Development at the Small Towns and Larger villages. This policy provides a list of villages where there is a Development Boundary, but no allocated sites. It says that if communities wish to promote development other than that which is supported through the strategy and other strategies in the Plan they will need to produce a Neighbourhood Plan or promote community led development (for example Community Land Trusts) justifying how and why, in a local context, the development will promote the objectives of sustainable development.
• Policy P4D – Meeting Housing Needs - Self and Custom Housebuilding. An example is the City of York Regulation 19 Draft Local Plan Policy H4: Promoting Self and Custom Build House Building. The supporting text defines self and custom build to explicitly include community led projects where the community organises construction work.
• Policy P5 – Provision of Land for Housing. In Bristol, an affordable housing policy was prepared as part of the Local Plan to make land available for community-led development at scale. The City’s Local Plan draft policies make explicit reference to CLH alongside self-build. It allocates specific named sites for this purpose and also defines locations suitable for Community-led housing exception sites. They then developed a CLH Land Disposal Policy which in 2020, led to their first land disposal call offering eleven council-owned sites for housing at discounted rates. To inform decisions, Bristol and Bath Regional Capital CIC and HACT have worked with Bristol City Council to develop a calculator that demonstrates the social value and financial savings impacts generated by CLH.

Other local authorities have developed dedicated CLH policies which sit alongside existing housing and planning policy. For example, Birmingham City Councils recent Community Led Housing Policy.

A Planner’s Guide to Community Led Housing | Community Led Homes and CLH: A key role for local authorities | Co-operative Councils Innovation Network are both useful references about what and how local authorities can enable CLH through planning policy, alongside examples from elsewhere in the country.

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