Affordable Housing Requirement

Object

Representation ID: 71593

Received: 17/02/2020

Respondent: AC Lloyd Homes c/o Delta Planning

Agent: Delta Planning

Alternative Developer Contributions
This section refers to Policy H2, which allows off-site contributions to be made in lieu of on-site affordable housing provision in certain circumstances. It should be made clear in the SPD that although on-site provision is a priority, alternative options can be considered where appropriate as permitted by policy H2.

Object

Representation ID: 71594

Received: 17/02/2020

Respondent: AC Lloyd Homes c/o Delta Planning

Agent: Delta Planning

Fractions should be rounded up and down to ensure development is delivered at the most appropriate levels for each site.

Object

Representation ID: 71595

Received: 17/02/2020

Respondent: AC Lloyd Homes c/o Delta Planning

Agent: Delta Planning

Alternative Developer Contributions

The 2nd paragraph notes that on-site affordable provision may not be practical within smaller conversion schemes, where affordable and market accommodation cannot be separated out and would present difficulties in terms of management and service charges. Some definition of what may be considered to be a ‘smaller’ scheme, should be provided. Notwithstanding this, the same issues could also be applicable to larger conversion schemes as well and some allowance for individual assessment should be included within the policy so that off-site contributions can be utilised where they could be more appropriate.

Object

Representation ID: 71596

Received: 17/02/2020

Respondent: AC Lloyd Homes c/o Delta Planning

Agent: Delta Planning

The preferred tenure split is unclear as conflicting information is provided within the SPD. Definitions of tenures could assist in making the requirement clear.

Object

Representation ID: 71602

Received: 17/02/2020

Respondent: Deeley Group Ltd c/o Delta Planning

Agent: Delta Planning

Alternative Developer Contributions

This section refers to Policy H2, which allows off-site contributions to be made in lieu of on-site affordable housing provision in certain circumstances. It should be made clear in the SPD that although on-site provision is a priority, alternative options can be considered where appropriate as permitted by policy H2.

Object

Representation ID: 71603

Received: 17/02/2020

Respondent: Deeley Group Ltd c/o Delta Planning

Agent: Delta Planning

Fractions should be rounded up and down to ensure development is delivered at the most appropriate levels for each site.

Object

Representation ID: 71604

Received: 17/02/2020

Respondent: Deeley Group Ltd c/o Delta Planning

Agent: Delta Planning

Alternative Developer Contributions

The 2nd paragraph notes that on-site affordable provision may not be practical within smaller conversion schemes, where affordable and market accommodation cannot be separated out and would present difficulties in terms of management and service charges. Some definition of what may be considered to be a ‘smaller’ scheme, should be provided. Notwithstanding this, the same issues could also be applicable to larger conversion schemes as well and some allowance for individual assessment should be included within the policy so that off-site contributions can be utilised where they could be more appropriate.

Object

Representation ID: 71605

Received: 17/02/2020

Respondent: Deeley Group Ltd c/o Delta Planning

Agent: Delta Planning

The preferred tenure split is unclear as conflicting information is provided within the SPD. Definitions of tenures could assist in making the requirement clear.

Object

Representation ID: 71627

Received: 13/02/2020

Respondent: Barton Willmore (now Stantec)

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.

Object

Representation ID: 71628

Received: 13/02/2020

Respondent: Barton Willmore (now Stantec)

RE: SITE VIABILITY
The draft SPD provides for instances where developers may not be able to meet the affordable housing and other planning obligations in full. The ability for viability to be considered and negotiations to take place on the viable amount of provision is supported. The draft SPD should refer to the Council having regard to PPG on viability (including the standard approach to viability assessments) to ensure consistency with national policy and guidance.

Object

Representation ID: 71629

Received: 13/02/2020

Respondent: Barton Willmore (now Stantec)

RE: ALTERNATIVE DEVELOPER CONTRIBUTIONS
The draft SPD provides a calculation for off-site affordable housing financial contributions. It is noted that this seeks to reflect the increased number of market houses on a site (where an off-site financial contribution is being made) and results in a higher percentage of affordable housing being provided for via an off-site financial contribution. It should be demonstrated that this is not going over and above existing local plan polices which have been subject to viability assessment. Policy H2 states the Council will “in exceptional circumstances, accept contributions of equivalent value in lieu of on-site delivery. This should include financial contributions, land or off-site provision of affordable homes.” Paragraph 4.27 of the Warwick District Local Plan then states that a developer may be required to provide either, or both, an alternative site and financial contribution. It is therefore not clear if the ’uplifted’ off-site financial contribution contained within the draft SPD assumes a developer will not be providing land as well, or if the ‘uplift’ for the financial contribution assumes no land is provided. This should be clarified in the draft SPD. The text of the SPD should also confirm that the off-site financial contributions will be ‘rounded down’ as per the examples provided in the accompanying table.

Support

Representation ID: 71630

Received: 13/02/2020

Respondent: Barton Willmore (now Stantec)

RE: AFFORDABILTY & TENURE
The draft SPD provides an expected tenure split based upon the most recent Strategic Housing Market
Assessment (SHMA) findings but notes that these may vary site to site. In relation to the housing types and sizes, the draft SPD seeks to deviate from the SHMA and provide fewer one bed properties. This is in recognition of the limitations placed on household growth and individual lifestyle choices by one-bedroom properties. The draft SPD seeks to provide more two-bed properties and fewer one bed properties, but still within the sum of the total range for these i.e. 55-65%. The draft SPD also encourages two-bed bungalows to be provided; however, the draft SPD should recognise the potential implications for site density and design of providing such properties.

The flexible approach for site specific tenure mixes, housing types and sizes is supported. The
flexibility could be strengthened by references to the site-specific circumstances such as location, local market demand and viability being considered as part of determining the mix on site.

Object

Representation ID: 71635

Received: 17/02/2020

Respondent: William Davis Ltd

In discussing tenure, the draft document only makes mention of social rented, affordable rented and shared ownership tenures, and ignores other intermediate tenures that are included in the definition of affordable housing in Annex2 of the NPPF (February 2019). This includes, discounted market sales, and ‘other affordable routes to home ownership’ (equity loans, other low-cost homes for sale and rent to buy), and Starter Homes. This is strictly contrary to the approach set out in Policy H2 of the Local Plan, to which the SPD relates, which states at point e): “The affordable housing will meet the definition of affordable housing set out in Annex 2 of the National Planning Policy Framework (NPPF) in terms of tenure, eligibility and provider. If the NPPF is replaced by later national guidance while this policy H2 remains in force then, at the time of consideration of a planning application, the definition of affordable housing shall be taken to be as defined in such later national guidance” (my underlining). Therefore, even though these other tenures were not quoted at the time the Local Plan was adopted the new NPPF definitions are recognised as being relevant to all current planning applications, by virtue of this policy wording. The SPD should therefore provide updated guidance on these tenures to assist negotiations on current and future planning applications.

Object

Representation ID: 71647

Received: 20/02/2020

Respondent: Leonie Stoate

As SPD’s do not form part of the development plan, they are unable to introduce new policies. The SPD states “…this SPD seeks an affordable housing mix that differs from that modelled in the SMHA.” We recommend that the Council removes all text regarding housing types and sizes where it does not correspond with the findings of the JSHMA in order to be found sound.

The SPD encourages the retention of all affordable housing in perpetuity. We ask that the SPD removes all requirements to retain affordable housing in perpetuity unless explicitly relating to rural exception sites.

Support

Representation ID: 71684

Received: 21/02/2020

Respondent: Gladman Developments

Support the recognition that tenure split may need revising with more up-to-date evidence in the future. However, emphasis should be made that although this is the preferred split, in some circumstances negotiations can take place to vary this.

Support

Representation ID: 71685

Received: 21/02/2020

Respondent: Gladman Developments

Note that the typology mix differs from the SHMA. Urge that the SPD makes clear that mix is a guide rather than a fixed requirement, with the specific mix discussed on a site by site basis.

Support

Representation ID: 71686

Received: 21/02/2020

Respondent: Gladman Developments

Note that the Government will soon soon launch a "First Homes" White Paper consultation and that the SPD may need updating in the future to remain consistent with Government objectives

Object

Representation ID: 71689

Received: 21/02/2020

Respondent: Barton Willmore

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. Reword to make it clear that the Council is not seeking to control density.

Object

Representation ID: 71690

Received: 21/02/2020

Respondent: Barton Willmore

Affordable Housing Requirements- Site Viability
The draft SPD provides for scenarios where developers may not be able to meet the affordable housing and other planning obligations in full. The ability for viability to be considered and negotiations to take place on the viable amount of provision is supported. The draft SPD should include reference to the Viability PPG (including the standard approach to viability assessments) to ensure consistency with national policy and guidance.

Object

Representation ID: 71691

Received: 21/02/2020

Respondent: Barton Willmore

ALTERNATIVE DEVELOPER CONTRIBUTIONS
The draft SPD provides a calculation for off-site affordable housing financial contributions. It is noted that this seeks to reflect the increased number of market houses on a site (where an off-site financial contribution is being made) and results in a higher percentage of affordable housing being provided for via an off-site financial contribution. It should be made clear that this contribution is not going over and above existing local plan polices which have been subject to viability assessment. Policy H2 states the Council will; in exceptional circumstances, accept contributions of equivalent value in lieu of on-site delivery. This should include financial contributions, land or off-site provision of affordable homes.
Paragraph 4.27 of the Warwick District Local Plan then states that a developer may be required to provide either, or both, an alternative site and financial contribution. It is therefore not clear if the ’uplifted’ off-site financial contribution contained within the draft SPD assumes a developer will not be providing land as well, or if the ‘uplift’ for the financial contribution assumes no land is provided. This should be clarified in the draft SPD.
The text of the SPD should also confirm that the off-site financial contributions will be ‘rounded down’ as per the examples provided in the accompanying table.

Support

Representation ID: 71692

Received: 21/02/2020

Respondent: Barton Willmore

AFFORDABILITY & TENURE
The draft SPD provides an expected tenure split based upon the most recent Strategic Housing Market Assessment (SHMA) findings but notes that these may vary site to site.
In relation to the housing types and sizes, the draft SPD seeks to deviate from the SHMA and provide fewer one-bed properties. This is in recognition of the limitations placed on household growth and individual lifestyle choices by one-bedroom properties. The draft SPD seeks to provide more two-bed properties and fewer one-bed properties, but still within the sum of the total range for these i.e. 55-65%. The draft SPD also encourages two-bed bungalows to be provided; however, the draft SPD should recognise the potential implications for site density and design of providing such properties.
This flexible approach for site specific tenure mixes, housing types and sizes is supported.
This flexibility however, could be further strengthened by references to the site-specific circumstances such as location, local market demand and viability being considered as part of determining the mix on site.

Object

Representation ID: 71699

Received: 21/02/2020

Respondent: Taylor Wimpey UK Limited

Agent: Mr Andrew Lowe

The SPD must aim to provide the greatest possible flexibility, avoiding unnecessary financial burdens and allowing schemes to reflect their local context.
Acknowledging the dated nature of the JSHMA will ensure that there remains sufficient scope and flexibility to depart from the specified mix of affordable housing types and tenures where justified by more up-to-date evidence.
Taylor Wimpey objects to the proposed rounding of fractions, as any calculations must accord with standard mathematical principles.
The methodology for calculating off-site financial contributions should be revised.
Our attached representations expand upon these concerns.

Object

Representation ID: 71707

Received: 21/02/2020

Respondent: Lioncourt Strategic Land Limited

Agent: Savills

We have made comments on the following:
- the percentage of Social Rent should be reduced further to enable the mix to achieve the requirements of NPPF paragraph 64.
- he proposed housing mix table should be removed from page 19 and the ‘Housing Types and Sizes’ section of the SPD should be amended to ‘encourage’ the development of more two and three bed affordable dwellings.
- the requirement for 5% of affordable rented properties to be bungalows should be removed.
- clarity is sought on the requirement for the proposed Starter Home restrictions.

Object

Representation ID: 71708

Received: 21/02/2020

Respondent: St Joseph Homes

We request that additional wording is added to describe the conditions whereby variance from the tenure split would be acceptable.
We request that the Council do not commpletely discount 1-bedroom shared ownership units completely.
We request the Council consider the social value contribution made by developments when calculating the affordable housing contribution.

Object

Representation ID: 71717

Received: 21/02/2020

Respondent: Pegasus Group

Site Size
The draft text suggests that a ‘threshold of 10 units’ will be applied when considering affordable housing provision in new schemes. This does not accord with Local Plan Policy H2 which sets a threshold of 11 or more dwellings, or a total floorspace of over 1,000m2. The wording set out in the draft SPD should be amended to accord with Local Plan Policy H2.

Object

Representation ID: 71718

Received: 21/02/2020

Respondent: Pegasus Group

Site Viability
Northern Trust support the recognition that some development proposals may be unable to meet all of the relevant affordable housing requirements whilst remaining viable and deliverable. Northern Trust support the requirement to submit a viability assessment where this is the case

Object

Representation ID: 71719

Received: 21/02/2020

Respondent: Pegasus Group

Affordability and Tenure
Northern Trust welcome the Council’s recognition that the tenure split may be revised by subsequent SHMA’s or successor document to represent the most recent and robust evidence which Northern Trust welcome and fully support. In this regard, and noting that the SHMA Update is based upon data which is some 5 years old, it would important that the SPD confirms that this evidence base will be updated in a timely manner noting the NPPF’s requirement to deliver a wide range and variety of homes.

Object

Representation ID: 71720

Received: 21/02/2020

Respondent: Pegasus Group

Housing Types and Size
Mix doesn’t take into account the risks of single occupants in two-bedroom properties paying the “bedroom tax”.

Insufficient flexibility overly prescriptive rules from Councils can delay developments, and Northern Trust encourages the Council to be more flexible.

There is no sufficient evidence regarding bungalow need.

Object

Representation ID: 71721

Received: 21/02/2020

Respondent: Pegasus Group

Affordability in Perpertuity
The commentary provided under this subheading relating to Starter Homes and Discount[ed] Market Sales is confusing and no context is provided as to the purpose of this text. However, in respect of the starter homes, it is assumed that this text relates to the proposed restriction period for the resale of starter homes. It is important that any such restriction period is properly considered and evidenced noting the impact that having a restricted period which is too long can make it difficult for first-time buyers to move on to a larger (or smaller) new home and can put off first-time buyers from taking up such products.

It is unclear what the text relating to Discount[ed] Market Sales relates to or its purpose and we would reserve the right to comment on this further once this has been made clear. Nevertheless, we would note that references to ‘determined by local incomes’ in considering what is market value does not accord with the definition of such affordable housing within the NPPF.