Box 20 - Preferred Strategy for Housing
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19089
Received: 11/11/2008
Respondent: Courtley Consultants Ltd
Agent: Courtley Consultants Ltd
PPS3 requires a robust up to date assessment of housing need and assessment refecting the likely economic viability of land for housing within their area.
We believe no such assesment on viability has been undertaken.Thus making this section of the core strategy unsound.
PPS3 requires a robust up to date assessment of housing need and assessment refecting the likely economic viability of land for housing within their area.
We believe no such assesment on viability has been undertaken.Thus making this section of the core strategy unsound.
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19130
Received: 26/01/2009
Respondent: Councillor David Vereker
Communities. I do not think lowering the threshold for affordable housing will achieve the expected result and the forecast gain is so negligible that it is not worth the risk of upsetting the landowners/developers.
Comment
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19194
Received: 28/01/2009
Respondent: Northiam Parish Council
RDC's housing strategy is to increase provision of affordable housing to meet identified needs. The Parish Council is concerned that those needs are not being based on up to date accurate information and that 'local needs' may mean district-wide to RDC rather than within the village.
RDC's housing strategy is to increase provision of affordable housing to meet identified needs. The Parish Council is concerned that those needs are not being based on up to date accurate information and that 'local needs' may mean district-wide to RDC rather than within the village. The strategy of lowering the development qualification from 5 to 3 in the rural villages will help increase the number of affordable homes but the design of dwelling and the rent/purchase options are also key issues.
The stated initiative to reduce the number of empty homes is strongly supported.
Support
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19211
Received: 28/01/2009
Respondent: Salehurst & Robertsbridge Parish Council
We feel that this is especially important in the rural villages.
We feel that this is especially important in the rural villages.
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19212
Received: 28/01/2009
Respondent: OCEAN PARCS LIMITED
Agent: Brett Drury Land & Planning
Inadequate evidence base
Out of date evidence base
Lack of financial viabibility asessment
Contrary to PPS and Case law
Unsound policy-making etc.
• It is noted that the proposed CS addresses the imbalance of resident population which has a higher than average proportion of residents over the age of 45. However, whilst we support the aim to use development proposals as a means to fund the provision of affordable housing, we do not believe it appropriate to apply this across all sectors.
• Developments aimed at different housing sectors such as sheltered Housing, retirement housing, holiday chalets, time-share, etc. will produce quite different financial viabilities. Specialist services and care facilities necessary to support homes designed for the elderly impose an increased financial burden on the development and may restrict its ability to contribute an affordable housing component.
• It is government policy that housing provision should provide for all sectors including for the elderly. However, housing designed specifically to meet the needs of specialist housing groups (for example as with student accommodation) doesn't necessarily lend itself to a haphazard mix of occupants forced upon it by affordable housing policy. The suggested blanket approach to affordable housing comprised in the SPD and these policy documents represents a crude and inappropriate tool when applied in these circumstances.
• As a result, we believe that the affordable housing policy presents a serious risk to both the financial and the functional viability of many types of housing scheme resulting in the abandonment of many potentially valuable schemes. As a result, attainment of the higher order aims and objectives of the Government and of Rother Council will not be realised. Accordingly we do not agree that the Council's adopted SPD on Affordable Housing is likely to achieve its aims of providing more affordable housing within the District.
• The recent Court of Appeal case - Blyth Valley Borough Council v Persimmon Homes (North East) Ltd and others - demonstrated that local planning authorities must recognise the 'crucial requirement of the PPS that an economic viability assessment of any percentage figure was a central feature of the policy on affordable housing'. The evidence base listed on the Council's web-site as background papers upon which the policy directions are based includes a Housing Needs study dated 2005, a housing strategy document dated from 2004 and a Hastings and Rother Housing Market Assessment 2007.
• The work leading up to the publication of these documents was of course undertaken some time before these dates all of which not only pre-date the current economic recession, but also were formulated during the height of a long period of inflationary pressure on land transactions and within the housing market in general. The Court of appeal held that Blyth Valley 'failed to reflect the requirement of the PPS as to the need for an informed economic viability study as part of the process leading to a policy requiring a particular percentage of affordable housing.' We do not believe that the Council's data is adequately up to date to fulfil this requirement.
• The background papers show no evidence of any financial viability work having been undertaken to inform the process of selecting a particular percentage affordable housing requirement. Even had it done so, such evidence would not have taken account of the dramatic changes in housing market viabilities resulting from the world-wide economic down-turn and housing recession in the UK resulting in falling land and property prices. We believe that this would leave an Inspector with no alternative than to find a core strategy legally flawed and unsound.
• Moreover, the fragility of the housing market in terms of viability is unlikely to meet the overall objective of providing additional housing to meet the needs set out in the draft RSS for the SE. To universally and without up to date financial viability tests, apply punitive costs to housing schemes further increases the likelihood of allocations and housing permissions being unimplemented. Delivery of (appropriate) development is the principle aim of the Development plan process and this will fail without proper regard to viability.
• We suggest that it would be appropriate to aim for an overall increase in affordable housing provision within Rother District, in line with the emerging regional policy. However, we suggest that it should generally only apply to open market schemes and not at all to those specifically designed for specialist sectors such as for retirement and for student accommodation. In any event, all applications of such a policy should be subject to up to date financial viability tests for any given site.
• In this regard we suggest that it will be necessary for the Council to indicate in the framework documents a system of ranking 'planning gain' requirements in order for infrastructure; service & utility; social; community; carbon reduction and all other development costs to be prioritised in order to inform the development process in a transparent way.
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19261
Received: 30/01/2009
Respondent: Aroncorp Ltd
Agent: Broadlands
The number of affordable dwellings that the Strategy seeks to secure through the twenty year period should be set out, together with the number that is to be secured through the S106 mechanism. These figures should seek the provision of more than 92 dwellings per annum overall and 53 new homes through Section 106 (referred to in paragraph 101.0, as that figure is much less than the annual requirement of 256 dwellings set out in the Housing Needs Survey 2005).
The number of affordable dwellings that the Strategy seeks to secure through the twenty year period should be set out, together with the number that is to be secured through the S106 mechanism. These figures should seek the provision of more than 92 dwellings per annum overall and 53 new homes through Section 106 (referred to in paragraph 101.0, as that figure is much less than the annual requirement of 256 dwellings set out in the Housing Needs Survey 2005).
Support
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19305
Received: 30/01/2009
Respondent: AmicusHorizon Ltd (Rother Homes)
We support the intention to maximise the number of affordable homes coming through the Planning system. That said there needs to be a degree of flexibility in both the percentage of affordable homes on specific sites as well as the tenures of said homes. We support the use of the term 'Intermediate' tenure and this does indeed allow other home ownership products to be utilised as and when required.
We support the intention to maximise the number of affordable homes coming through the Planning system. That said there needs to be a degree of flexibility in both the percentage of affordable homes on specific sites as well as the tenures of said homes. We support the use of the term 'Intermediate' tenure and this does indeed allow other home ownership products to be utilised as and when required.
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19553
Received: 25/02/2009
Respondent: Trustees of the Glyndebourne 1991 L & P Trust
Agent: Mr. Dale Mayhew
Core Strategy obliged to be in broad conformity with the emerging SE Plan, as it represents a higher tier part of Development Plan. This sets out a requirement at Policy H4, that LDFs should set targets for the provision of affordable housing, having regard to the overall regional target that 25% of all new housing should be social rented accommodation and 10% other forms of AH. The existing LP exceeds this target, and relies on justification of the disparity of average income to average house price.
Nonetheless, a further increase within the rural parishes to 50% would represent a significant departure from draft Policy H4, placing the policy in conflict with a higher tier Development Plan policy.
Any increase above existing LP level is likely to jeopardise the viability of delivering local market housing, due to the increased burden of providing high numbers of affordable housing units. A lack of viability could stem the
flow of new housing, resulting in the failure of the District to meet its annualised housing target figures. This would likely worsen the affordability gap that increase in the percentage seeks to address. Would therefore be counterproductive.
This concern particularly acute on mixed use sites as residential element may be required as the mechanism to enable the viability of mixed use schemes. Given this, there should be no increase in the rural area percentage beyond current Local Plan policy.
Furthermore, the Council acknowledges that it has a Rural Exception Sites Project, which is specifically designed to tackle the problem of the lack of affordable rural housing. This concept is specifically provided for in PPS3 as the
mechanism for delivering requisite affordable housing in rural communities. Should the district consider that it needs a greater delivery of affordable housing in rural areas, it should utilities a Rural Exceptions Policy to increase delivery.
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19614
Received: 30/01/2009
Respondent: Rother and Hastings CPRE
Page 93 Box 20 Provision needs to be made to prevent housing size creep. Affordable houses become unaffordable because of a lax attitude by planners to extension applications. There are examples of this in the district where groups of small houses have all become four bed roomed. See Knowle Hill at Bodiam as a good or rather bad example of this.
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 19926
Received: 27/01/2009
Respondent: Croudace Strategic Ltd
Agent: Charles Planning Associates Limited
The options of lowering the site threshold and percentage of affordable housing sought should be informed by a robust assessment of the viability of such options. This assessment must be carried out before the next stage of the Core Strategy. The percentage of affordable housing above the recently adopted policy would call into question the viability of a number of sites, The Council must accept that an increase in the affordable housing provision sought on each site will need to be balanced against other requirements. In this regard, the percentage of affordable housing sought on each site should be based on site specific circumstances. The Core Strategy may set a target, informed by a viability assessment, the Council should not seek to stringently apply this as an absolute minimum but rather as a guideline for negotiation.
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 20040
Received: 29/01/2009
Respondent: Laurence Keeley
Paragraphs 10.6 to 10.32
All development land would be passed over to a community trust and a rental would be paid to the owners. Income from agricultural land at this time would be about £500 an acre. If one doubled this to £1000 an acre it would not be unreasonable. The trust would oversee development. Developers would be instructed to build houses for around £80,000. These would be sold at cost, plus ground rent, to the people with a priority need in the district, with a restriction that one may only sell back to the trust.
Object
Core Strategy Consultation on Strategy Directions 2008
Representation ID: 20117
Received: 29/01/2009
Respondent: Mr. & Mrs. John Howlett
Paragraphs 10.6 to 10.32
Social and economic conditions are currently exacerbated by a lack of choice of affordable housing and the seasonal and low-income nature of jobs associated with the tourism industry.
There is a chronic lack of affordable rented accommodation and thus we would ask a large proportion of new housing be designated for low cost rent. We believe the current stipulation is at 40%; we would ask the RDC in the Core Strategy to raise the required percentage for low cost rent to 60% in what they themselves define as a town with social and economic deprivation.