Object

Affordable Housing SPD

Representation ID: 71627

Received: 13/02/2020

Respondent: Barton Willmore (now Stantec)

Representation Summary:

RE: SITE SIZE
The draft SPD states “where the site is a subdivision of a larger site or adjacent to another potential
housing site, the site size for threshold purposes will be taken to be the larger development site.”
A series of considerations are then set out for determining whether two or more sites should be considered as one. The draft SPD should be clear that any barriers to separate sites being reasonably considered as one whole development site, for example landownership and landowner intentions, will be fully accounted for. The draft SPD states that the density of the development will be considered in the application of the threshold of 10 dwellings. We consider that this section of the draft SPD should be reworded to make it clear that the Council is not seeking to control the density of developments beyond where density is being used to purely circumvent the provision of affordable housing i.e. the guidance should not lead to increases in density across all developments. The guidance should further clarify that in considering whether the density is ‘inappropriate’ this will have regard to all principles of good design, not just density which on its own can be a crude measure of whether not a development is suitable.