H2 Affordable Housing
Support
Publication Draft
Representation ID: 65176
Received: 24/06/2014
Respondent: Sundial Group Ltd
Agent: Mr Marcus Bates
The Affordable Housing mix needs to respond to the evolving requirements of Registered Providers and allow for flexibility to assist with delivery.
In general terms we support draft Policy H2 which seeks to secure affordable housing as part of new development. In particular, we support the recognition that the location and means of delivery will be the subject of negotiation and will account of site specific factors such as viability, in accordance with paragraphs 173 and 174 of the NPPF. We would also support a policy which provides flexibility in terms of the sizes, types and tenures of affordable homes provided and which does not seek to set out a prescribed mix. The affordable housing mix needs to respond to the evolving requirements of Registered Providers and allow for flexibility to assist with delivery to meet housing need and align with their funding constraints.
Object
Publication Draft
Representation ID: 65244
Received: 27/06/2014
Respondent: Deeley Group Ltd
Agent: Delta Planning
Legally compliant? Yes
Sound? No
Duty to co-operate? No
Deeley Group object to part (b) of policy H2 regarding Affordable Housing. It is considered that the threshold of sites of 5 or more dwellings or 0.17 hectares is too low and disregards the costs of developing small sites over larger one's. This policy will have an adverse effect on the ability of developers to bring forward small sites which can provide a valuable contribution to housing provision across the district. If a higher threshold is introduced this will encourage more sites to come forward and more affordable housing provision to be provided in the District.
Deeley Group object to part (b) of policy H2 regarding Affordable Housing. It is considered that the threshold of sites of 5 or more dwellings or 0.17 hectares is too low and disregards the costs of developing small sites over larger one's. This policy will have an adverse effect on the ability of developers to bring forward small sites which can provide a valuable contribution to housing provision across the district. If a higher threshold is introduced this will encourage more sites to come forward and more affordable housing provision to be provided in the District.
Object
Publication Draft
Representation ID: 65291
Received: 25/06/2014
Respondent: A C Lloyd Homes Ltd
Agent: Delta Planning
Legally compliant? Yes
Sound? No
Duty to co-operate? No
A C Lloyd Homes object to part (b) of policy H2 regarding Affordable Housing. It is considered that the threshold of sites of 5 or more dwellings or 0.17 hectares is too low and disregards the costs of developing small sites over larger one's. This policy will have an adverse effect on the ability of developers to bring forward small sites which can provide a valuable contribution to housing provision across the district. If a higher threshold is introduced this will encourage more sites to come forward.
A C Lloyd Homes object to part (b) of policy H2 regarding Affordable Housing. It is considered that the threshold of sites of 5 or more dwellings or 0.17 hectares is too low and disregards the costs of developing small sites over larger one's. This policy will have an adverse effect on the ability of developers to bring forward small sites which can provide a valuable contribution to housing provision across the district. If a higher threshold is introduced this will encourage more sites to come forward.
Object
Publication Draft
Representation ID: 65477
Received: 27/06/2014
Respondent: King Henry VIII Endowed Trust (Warwick)
Agent: AMEC
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
We broadly support the 40% affordable housing target to meet local needs. However the policy wording may not allow sufficient flexibility to take into account viability or site specific factors. Not in all cases will 40% affordable housing be viable.
Viability is referred to in the second paragraph of the policy; however this appears to relate solely to the form of provision, its location on site and the means of delivery.
Whilst we acknowledge that the SHMA is an important source of housing needs information, applying this policy rigidly may not necessarily assist in meeting local housing needs. The SHMA is only a 'snapshot' in time and will not always reflect the dynamic nature of the housing market. We would emphasise the need for flexibility to ensure that a wider range of factors can also be taken into account in determining the overall housing mix. These may include site specific factors relating to the existing local area or site specific viability factors.
There is a very real danger that pockets of relative social exclusion may result and indeed that the mix prescribed for the urban extension may prejudice its compatibility and full social integration into the main core community to which it relates. Such dangers are obviously exacerbated in circumstances in which relatively high percentages of affordable housing and, within this, relatively high proportions of social rented tenures are being inflexibly required, with no scope for reasonable negotiation.
see attachment
Object
Publication Draft
Representation ID: 65526
Received: 27/06/2014
Respondent: Sharba Homes Group
Agent: PJPlanning
Legally compliant? No
Sound? No
Duty to co-operate? No
We seek clarification on this policy over whether Growth Villages, as defined in policy H1 fall under point A or point B, as the policies map does not identify rural areas explicitly.
We seek clarification on this policy over whether Growth Villages, as defined in policy H1 fall under point A or point B, as the policies map does not identify rural areas explicitly.
Support
Publication Draft
Representation ID: 65527
Received: 27/06/2014
Respondent: Keith Wellsted
Needed
Needed
Object
Publication Draft
Representation ID: 65884
Received: 27/06/2014
Respondent: Centaur Homes
Agent: McLoughlin Planning
Legally compliant? No
Sound? No
Duty to co-operate? No
The Policy could be interpreted to seek higher levels of affordable
housing and, therefore, lacks any precision or certainty for applicants. In accordance with the SHMA, the amount of affordable housing required in the
District is broadly proportionate to 40% of the total housing need, excluding any
requirement that arises assisting adjacent authorities with their housing need. The
insertion of "up to 40%" merely reflects the need for flexibility with proposals
involving an odd number of houses.
See attachment
Support
Publication Draft
Representation ID: 65996
Received: 27/06/2014
Respondent: West Midlands HARP Planning Consortium
Agent: Tetlow King Planning Ltd.
We are supportive of the 40% affordable housing target. However the policy wording currently states that residential development "will not be permitted unless provision is made for a minimum of 40% affordable housing" We are of the opinion that such a blanket policy does not allow the flexibility a developer may require to bring forward sites that may not be viable at such a high rate of delivery. In the interests of delivering more affordable housing it would be of benefit to the Council to make clear that lower contributions may be acceptable providing the developer can offer clear evidence to justify
a lower target.
See attachment
Object
Publication Draft
Representation ID: 66048
Received: 27/06/2014
Respondent: Home Builders Federation Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
This policy proposes that a minimum of 40% affordable housing to meet local needs is provided on residential developments of 10 or more dwellings within the urban area and 5 or more dwellings within the rural areas. The form of affordable housing, its location on the site and its means of delivery will be subject to negotiation at the time of a planning application.
Policy H2 together with other policy requirements such as Policy CT5 Infrastructure Contributions to Meeting Places, Cultural Facilities and Public Art, Policy CC3 Building Standards Requirements, and DM1 Infrastructure Contributions are not justified by the viability assessments, which demonstrate that at the Baseline Market Position no development was viable at 40% affordable housing provision.
See attachment
Object
Publication Draft
Representation ID: 66092
Received: 27/06/2014
Respondent: Gleeson Developments
Agent: Savills (L&P) Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy H2 refers to a need for a minimum of 40% affordable housing to meet the local needs. However, the evidence base does not justify this level of affordable housing. Indeed, the Base Line Market Position in the Viability Assessment Final Report (Nov 2011 DTZ) which pre-dates the NPPF and NPPG confirms that no development was viable at 40% (paragraph 10.6). Paragraph 10.8 of the Affordable housing Viability Assessment states: "....DTZ would suggest Warwick District Council consider producing a zoned affordable housing policy which has different affordable housing percentages by area."
This stance should be considered in policy H2. Policy H2 should therefore be re-written to ensure that the level of affordable housing renders development viable.
See attachment.
Object
Publication Draft
Representation ID: 66112
Received: 27/06/2014
Respondent: CALA Homes (mids) Ltd
Agent: Cerda Planning Ltd
Legally compliant? No
Sound? No
Duty to co-operate? No
However, Policy H2 together with other policy requirements such as Policy CT5 (Infrastructure Contributions to Meeting Places, Cultural Facilities and Public Art), Policy CC3 (Building Standards Requirements), and Policy DM1 (Infrastructure Contributions) result in a level of financial contribution that render development unviable.
The consultants, DTZ, who prepared the Council's Affordable Housing Viability Assessment suggest Warwick District Council consider producing a zoned affordable housing policy which has different affordable housing percentages by area. This recommendation should be considered by the Council.
See attachment
Object
Publication Draft
Representation ID: 66122
Received: 27/06/2014
Respondent: Mr and Mrs Martin
Agent: Cerda Planning Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy H2 together with other policy requirements such as Policy CT5 (Infrastructure Contributions to Meeting Places, Cultural Facilities and Public Art), Policy CC3 (Building Standards Requirements), and Policy DM1 (Infrastructure Contributions) result in a level of financial contribution that render development unviable. Indeed, it is not justified by the LPA's own viability assessments, which demonstrate that no development was viable when providing 40% affordable housing.
The consultants, DTZ, who prepared the Council's Affordable Housing Viability Assessment suggest Warwick District Council consider producing a zoned affordable housing policy which has different affordable housing percentages by area. This recommendation should be considered by the Council.
See attachment
Object
Publication Draft
Representation ID: 66192
Received: 27/06/2014
Respondent: Hallam Land Management and William Davis
Agent: Marrons Planning
Legally compliant? No
Sound? No
Duty to co-operate? No
In its present form there are a number of concerns about this policy, it is considered inconsistent with the advice in para. 50 of the NPPF and on that basis is unsound.
If market conditions for the development of land for new homes were to fall back from those currently experienced, securing the provision of at leat 40% of the new homes as affordable on any one site, may render a development proposal unviable.The policy as presently drafted is insufficeintly flexible to allow for such future circumstances.
It is considered that by including in Policy H2 the expression that on all qualifying sites, a minimum of 40% of the new housing must be affordable, then there will be flexibility in the application of the policy over time.
see attached
Object
Publication Draft
Representation ID: 66246
Received: 24/06/2014
Respondent: Crest Strategic Projects
Agent: d2planning
Legally compliant? No
Sound? No
Duty to co-operate? No
Objections are lodged to the proposed 40% affordable housing provision. This is contrary to the evidence which concludes that 35% affordable housing is a viable level. The purpose of the Plan led system is to provide certainty to developers, landowners etc. If the Council ignore their own evidence and adopt a higher threshold for affordable housing, there will be no guarantee that they would adopt a flexible approach once the 40% threshold was adopted.
This approach is totally contrary to the guidance in the NPPF which requires that viability of affordable housing and other policy requirements of the plan are deliverable and to ensure that these do not render development unsuitable and thus that plans undeliverable. The onus should not be placed on the developer to provide viability but for the Council to ensure that viability has been assessed when arriving at the initial figure for affordable housing within policy. This is in line with the NPPF but also the decision in Blyth Valley DC v Persimmon Homes (North East) limited (2008).
Concerns are also expressed at the content of the viability assessment which underpins the affordable housing policy. It considered that either a number of costs have not been taken into account e.g. biodiversity offsetting, flood mitigation etc or that the figures included within the viability assessment are too low e.g. planning contributions.
see attached
Object
Publication Draft
Representation ID: 66293
Received: 26/06/2014
Respondent: Mr H E Johnson
Agent: Bond Dickinson
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
We support the Council's intention to provide affordable homes.
However, we object to a blanket requirement of 40%: this is too prescriptive. It is not justified or effective and the policy is therefore unsound. The policy should make it clear that the amount of affordable housing will be determined on a site by site basis with an overall aim of achieving 40% where possible and viable, in order to be sound.
see attached
Object
Publication Draft
Representation ID: 66348
Received: 27/06/2014
Respondent: David Wilson Homes
Agent: Turley
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
We support this policy, however we recommend that the Council applies a flexible approach to viability and deliverability as emphasised in the Framework which states that 'the sites and the scale of development identified in the plan shoul not be subject to such a scale of obligation and policy burden that their avility to e developed viably is threatened'.
This applies equally to the setting of and appliocation of affordable housing policies.
see attached
Object
Publication Draft
Representation ID: 66469
Received: 27/06/2014
Respondent: Gladman Developments
Agent: Stansgate Planning
Legally compliant? No
Sound? No
Duty to co-operate? No
Sets out that development will not be permitted unless provision is made for 40% affordable housing of sites of 10 or more dwellings, or 0.3 ha or more within the urban areas, and on sites of 5 or more dwellings or 0.17 ha within rural areas.
Policy Analysis
Council should ensure that its affordable housing requirements are based on robust evidence, taking account of development viability. In this regard we note that the authority's most recent Affordable Housing Viability Study was published in 2011, with a further addendum prepared in 2012. Concerned as to whether this evidence is out-of-date inadequate to support the LP's proposals.
Conclusions on Soundness
In light of the time that has passed since publication of affordable housing viability evidence, query whether this is still up to date and sufficient to support the approach set out in Policy H2.
See attached
Object
Publication Draft
Representation ID: 66549
Received: 27/06/2014
Respondent: Taylor Wimpey
Agent: Barton Willmore
Legally compliant? No
Sound? No
Duty to co-operate? No
Policy H2 should be re-worded in order to clarify that the overall requirement of 40% affordable housing can be reduced based on viability. In its current form the policy appears to allow for the: form of provision of affordable housing; location on the site of affordable housing; and the means of delivery of affordable housing to be subject to negotiation at the time of a planning application, and it states that the viability of the development will be a consideration in such negotiations.
However, this does not clearly state that the actual proportion of affordable housing can be negotiated based on the viability of a site, which when considered against paragraph 173 of the NPPF is something which a developer should clearly be capable of doing.
See attached
Support
Publication Draft
Representation ID: 66589
Received: 27/06/2014
Respondent: Catesby Property Group
In general terms we support draft Policy H2 which seeks to secure affordable housing as part of new development. In particular, we support the recognition that the location and means of delivery will be the subject of negotiation and will account of site specific factors such as viability, in accordance with paragraphs 173 and 174 of the NPPF. We would also support a policy which provides flexibility in terms of the sizes, types and tenures of affordable homes provided and which does not seek to set out a prescribed mix. The affordable housing mix needs to respond to the evolving requirements of Registered Providers and allow for flexibility to assist with delivery to meet housing need and align with their funding constraints.
These representations are submitted on behalf of Cates by Estates Ltd and Kenilworth Wardens Cricket Club, in respect of their land interests at Kenilworth Wardens Sports Club, Glasshouse Lane, Kenilworth. Catesby Estates Limited was formed in 1996 (part of the Catesby Property group PLC) and specialises in the promotion of land through the planning system for sustainable residential and commercial development.
The land available extends to approximately 5 hectares and currently comprises a pavilion building with associated parking and access from Glasshouse Lane, together with part of Glasshouse Wood and the sports pitches. The land is broadly bounded by residential development to the north and the A46 and Kenilworth Rugby Club to the south. The land is currently identified as being within the Greenbelt, however it has been allocated for residential development, as part of a larger allocation at Thickthorn (H06), in the Publication Draft Local Plan.
We have reviewed the Publication Draft Local Plan and would offer the following comments. We confirm that we would wish to attend the Examination in Public to discuss the content of these representations and any other relevant topics.
Duty to Cooperate and Strategic Planning
We note that the Publication Draft Plan confirms that the Council has worked cooperatively with a range of organisations in the region and sub-region in respect of cross boundary, strategic issues. This extends to the Evidence Base and the Coventry and Warwickshire SHMA (CWSHMA) is of particular importance to the overall strategy of the Plan and the quantum of housing to be delivered within each district in the sub-region.
The draft Plan goes on to confirm that each of the authorities within the sub-region are at a different stage in preparing plans and, as a result, the capacity of the other districts to deliver their full objectively assessed housing requirement in full is not known. Whilst we recognise the difficulties involved with multiple authorities seeking to work together on strategic issues, we are particularly concerned in respect of Coventry City Council's ability to meet its full objectively assessed needs within its own administrative boundaries and the likely knock on effect for Warwick District, resulting in the need to identify additional sites for development. There is a risk therefore that the Plan is not positively prepared in that it does not make an allowance (without a further review of the Plan) for accommodating unmet needs from neighbouring authorities.
DS6 Level of Housing Growth
We note that the Council will provide for 12,860 new homes between 2011 and 2029. Paragraph 2.20 of the draft Plan makes reference to the CWSHMA and that Warwick District aims to meet its objectively assessed need. We support the Council in seeking to meet its objectively assessed need for new market and affordable housing, however the CWSHMA indicates that the overall assessed need for Warwick District amounts to 720 dwellings per annum over the period 2011 - 2031, equivalent to 12,960 for the period 2011- 2029. In light of this, we would query why the draft Plan proposes a lower requirement of 714 dwellings per annum.
The Plan is unlikely to progress to adoption until mid-201S, at best, and given this we would suggest that the Council extends the Plan period to 2031 so that it aligns with the CWSHMA, as the relevant evidence base, and more importantly, ensures that the Plan will have a 1S-year life span in accordance with paragraph 1S7 of the NPPF.
In view of the above, and in order to ensure that the Plan is consistent with national policy, we would recommend that the plan period is extended to cover the period 2011 - 2031, and consequently in order to ensure that the Plan is positively prepared and justified the draft Policy DS6 should be amended to increase the housing requirement to at least 14,400 (720 dwellings per annum).
Paragraph 4.12 of the draft Plan makes it clear that there is a serious affordability problem in Warwick District and paragraph 4.13 goes on to confirm that delivering 268 affordable homes per annum is challenging and that a large proportion will need to be provided on private development sites. Given that the primary route for the delivery of affordable housing is via private development sites, consideration should also be given to further increasing the overall housing requirement as a leaver to secure the delivery of more affordable housing.
DS7 Meeting the Housing Requirement
Draft Policy DS7 sets out the various categories from which the overall housing requirement will be delivered. We note that the breakdown includes sites with planning permission at 1st April 2013 and sites with planning permission granted between 1st April 2013 and 31st December 2013. It is not clear from the supporting text, and we would therefore query, whether any discount has been applied to this figure or whether there is an assumption that all of the sites with planning permission will be delivered in full within the plan period . It would be normal practice to apply a 10% reduction to committed sites for non-implementation and to ensure robustness.
We note that there is a substantial allowance for deliveries from windfalls, small urban sites assessed in the SHLAA and a consolidation of existing employment areas. We would query whether there is any 'double-counting' of sites and how robust including a windfall allowance is if allowances are being included for small SHLAA sites and the consolidation of existing employment sites, given that these categories are likely to make up a large proportion of what would normally be regarded as windfall sites.
In this respect, we are concerned that the Plan may not be effective in that it does not ensure the delivery of the full housing requirement within the Plan period .
DS11 Allocated Housing Sites
We support the identification of land at the Kenilworth Sports Club, Glasshouse Lane as part of the draft allocation for residential development at Thickthorn (H06). We confirm that the land is available for development and that there are no substantial constraints which would prevent the land coming forward in the short term.
We can confirm that Kenilworth Wardens Cricket Club Ltd is in advanced discussions in respect of relocating the sports facilities to Castle Farm and at the same time acquiring further land from the adjoining landowner to extend and improve the range of sports facilities available. This would remove the principle constraint to development, by ensuring the transfer of the sports facilities to the Castle Farm site. The transfer would also secure an extension and improvement of the sports facilities thus providing additional benefits to the wider community.
We are mindful that the land has been assessed by the Council in the 2014 and it is considered potentially suitable. Having considered the potential constraints to development, we are conscious that the extent of land available would allow significant landscape buffers to be introduced to both the A46 to the south, in order to protect occupiers from potential noise disturbance, and to Glasshouse Wood to the north, in order to protect the integrity of the Scheduled Ancient Monument
and the Ancient Woodland.
Initial feasibility work suggests that approximately 3 hectares of net developable land could be available on land controlled by Catesby Estates and Kenilworth Wardens, which could accommodate between 90 - 100 dwellings together with associated open space, landscaping, access arrangements and sustainable drainage features. Whilst we recognise that the site forms part of a larger allocation for residential development, and therefore there is an expectation that there will be a comprehensive masterplanning exercise to include the balance of the Thickthorn site, we confirm that the site could come forward for development individually if required.
Access to the site can be provided from Glasshouse Lane and the extent of frontage to Glasshouse Lane provides flexibility in the location of the access point to ensure that the necessary visibility splays can be achieved. Whilst this would result in the removal of hedgerow and trees, this would be kept to a minimum and would make use of existing breaks and gaps where appropriate. Any new development could incorporate walking and cycling links to the existing residential development to the north, improving the sustainability of the site and providing alternative modes of travel.
The site is currently identified as being within the Green Belt, however we do not consider that the site makes a positive contribution to the purposes of the Green Belt. We are aware of the conclusions drawn in the 2009 Green Belt Review, and it is our view that the A46 acts as a defensible barrier to the south east and prevents the unrestricted sprawl of Kenilworth. In addition, the A46 also acts as a barrier to the wider countryside and prevents development from encroaching in to the countryside. In light of this, and very limited availability of non-Green Belt land within the District, we consider that it is entirely appropriate to remove the land at Tickthorn from the Green Belt for and to allocate it for residential development.
H2 Affordable Housing
In general terms we support draft Policy H2 which seeks to secure affordable housing as part of new development. In particular, we support the recognition that the location and means of delivery will be the subject of negotiation and will account of site specific factors such as viability, in accordance with paragraphs 173 and 174 of the NPPF. We would also support a policy which provides flexibility in terms of the sizes, types and tenures of affordable homes provided and which does not seek to set out a prescribed mix. The affordable housing mix needs to respond to the evolving requirements of Registered Providers and allow for flexibility to assist with delivery to meet housing need and align with their funding constraints.
H4 Securing a Mix of Housing
We welcome the flexibility in the wording of this policy and would recommend that it is not amended to include the specific percentage splits. The NPPF seeks to ensure that a wide choice of high quality homes are provided and requires local planning authorities to "plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community" (paragraph 50, bullet 1). It therefore recognises the importance of allowing flexibility to adapt to market trends through development. As drafted, the policy would provide the flexibility to ensure the Plan remains consistent with paragraph 50 of the NPPF over the course of the plan period.
CC3 Building Standards Requirement
We object to the inclusion of a policy which requires all new dwellings to be constructed to meet the requirements of the Code for Sustainable Homes. The Code for Sustainable Homes (CfSH) was introduced in 2007 and, whilst at the present time remains the national standard for the sustainable design and construction of new homes in England and Wales, there are some imminent changes which are likely to render such a policy out of date.
Following the publication of the Harman Review into local housing standards in 2012 a Technical Housing Standards Review Group was established to look into existing sustainability standards applied to new housing, including the Code for Sustainable Homes. In August 2013 the Government published the Housing Standards Review Consultation in relation to the rationalisation of the framework of building regulations and local housing standards. The overall aim of this policy is to prevent local and national housing standards being unnecessarily complex and overlapping or contradicting each other, or parts of the Building Regulations. With regard to the Code for Sustainable Homes, the Government proposed to wind down the role of the Code.
In March 2014 the Government announced the results of the consultation and issued a Ministerial Letter outlining proposals for simplification of residential sustainabi lity standards. This involves consolidating requirements into the Building Regulations with amendments to the Planning and energy Act 2008 to remove local authority's ability to set energy standards above Building Regulations. The announcement confirmed the Government's intention to wind down the Code.
In light of the above, any policy which seeks to control the sustainable design and construction of homes by reference to the Code for Sustainable Homes, will both be quickly out of date and a repetition of the requirements of Building Regulations. Policy CC3 should therefore be deleted from the Local Plan.
We trust that these representations will be considered by the Council and look forward to being kept informed of the progression of the Local Plan. We would be pleased to meet with Officers to discuss the content of our representations and the delivery of residential development on land at Glasshouse Lane and would propose to contact you shortly in this regard . In the meantime, please do not hesitate to contact me if you have any queries.
Object
Publication Draft
Representation ID: 66751
Received: 27/06/2014
Respondent: Mr Edward Walpole-Brown
Agent: Brown and Co
Legally compliant? No
Sound? No
Duty to co-operate? No
We feel the Policy is unsound and needs to be challenged on the basis that it
indicates there should be a minimum of 40% affordable. We should suggest that it
should be up to 40% subject to viability and establishing local needs. Whilst it is
accepted there may be an affordable housing problem, much of this has been due
to the lack of supply of housing land as a result of ineffective Plans from the past
and the inability to delivery adequate land for housing growth.
See attached
Object
Publication Draft
Representation ID: 66770
Received: 26/06/2014
Respondent: Burman Brothers
Agent: Nigel Gough Associates Ltd
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Understand Council's desire to see to provide a requirement on all principle sites of up to 40% affordable housing, this has got to be properly tested for each allocation in terms of tenure/mix
see attached
Object
Publication Draft
Representation ID: 66834
Received: 27/06/2014
Respondent: Europa Way Consortium
Agent: AMEC
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
We are concerned that the wording requiring a minimum of 40% affordable housing may not allow sufficient flexibility to take into account viability or site specific factors. Consideration of viability is required to be consistent with para 173 of the NPPF.
With regard to sub point ii) sizes, types, and tenures of homes; flexibility is needed to allow for changing housing needs and market conditions over the time required to build an urban extension. Flexibility is needed to facilitate a wide range of factors being taken into account in determining overall housing mix.
We would recommend changing the words 'determined on' in the first line to 'guided by'.
There is a very real danger of creating pockets of relative social exclusion if the proportions of social rented tenures are inflexibly required.
see attached