15.24

Affordable Housing - Para 15.24 and Policy LHN2 (pages 118-119)

Summary
1. Delivering affordable housing is listed as the second "main issue" for the Core Strategy at paragraph 4.2 of the Draft CS (page 16). The Draft CS notes:

"The relative affordability of housing in Rother has been a significant issue for some time and is getting worse. Research in 2004 by the Joseph Rowntree Foundation showed Rother ranked in the top 30 'least affordable' districts in Britain".

2. We do not doubt either the significance or the severity of the issue. Our representations are concerned with whether or not the Core Strategy provides the
most appropriate response to the issue of affordable housing delivery, having regard to that context. Our submissions are essentially twofold:

(1) The significant need for affordable housing delivery is not properly reflected in the wider strategy for the provision of new housing, with both the reduction in the overall level of planned growth and the manner in which that growth is proposed to be accommodated acting against the interests of affordable housing delivery; and

(2) That the proposed Affordable Housing Policy itself is not sufficiently robust
in terms of either the thresholds for affordable housing or the overall target.

Representations
3. The Core Strategy notes at paragraph 15.24 that, based on the 2005 Housing
Needs Survey, the requirement for new affordable housing (being the overall
need for affordable housing minus the available stock via re-lets) equates to 256
dwellings per annum. The paragraph goes on to state that providing sufficient new
development to deliver this would be "unsustainable" (no specific explanation is
given), and that therefore the Council has adopted a target of 50 dwellings per
annum i.e. a level of provision that equates for about 20% of the actual need.

4. New market housing remains the most likely means by which affordable housing will be delivered in the future, particularly given the constraints on RSL budgets.

5. According to the 2011 Affordable Housing Background Paper (Table 1, page 6),
of the 178 affordable housing units delivered between 2005 and 2009, 50% came
from s106 agreements on private housing schemes, and 50% came from RSL
schemes, but that percentage will be affected firstly by the downturn in private
housebuilding over that period, and secondly by future constraints on RSL grant,
which will increasingly reduce RSL-only schemes.

6. So the decision to reduce the overall scale of new housing provision in the District below the level proposed in the South East Plan, and then potentially to reduce provision still further in the event that the Bexhill-Hastings Link Road does not arise, is a conscious decision to deliver less affordable housing than would
otherwise be possible.

7. We understand the 'balanced scorecard' approach adopted in the AH Background Paper which explains how the various affordable housing percentages are derived (i.e. for Bexhill, the level of affordable housing provision takes in to account the viability of delivering both the affordable housing and other community benefits).

8. However, it is not clear from the Background Paper why the decision was taken to set the threshold for affordable housing at 15 units at Bexhill, when at paragraph 4.8, the Background Paper notes that there is no evidence that applying affordable housing quotas to sites smaller than 10 units would be any less viable than those at more than 10 units.

9. Similarly, there is no clear explanation as to where the target of 50 units per
annum referred to at paragraph 15.24 comes from (compared to, say, the current
Housing Strategy target of 70 units per annum).

10. We appreciate that raising the percentage of affordable housing required in new developments will be counter-productive if that simply makes the development unviable, and therefore we do not suggest altering the thresholds, since these have been properly assessed.

11. However, three relatively straightforward ways of increasing affordable housing delivery would be to:

(a) Lower the site size threshold in Bexhill (as the main urban area, Bexhill is
the primary source of supply of new housing, and many sites will be of a
smaller scale and hence there is a missed opportunity for supply);

(b) Maintain the level of new housing at the rate set by the South East Plan,
rather than trying to lower housing provision overall; and

(c) Facilitate the early delivery of the strategic growth locations identified in
the Core Strategy at Bexhill, since these will be the main sources of affordable housing supply.

12. Following on from the above, we consider that paragraph 15.24 and Policy LHN2 of the Core Strategy are unsound because:

(1) The affordable housing target has not been Justified;

(2) The site size threshold for Bexhill has not been Justified, and nor is the policy the most appropriate having regard to affordable housing delivery.

Proposed Amendments

13. In order to remedy the Core Strategy, the following amendments are required:

(1) Overall affordable housing target to be adjusted having regard to the
amended overall level of housing supply (set out in our representations to
OSS1) and having regard to revised and justified site thresholds;

(2) Policy LHN2 amended in respect of revised and justified site thresholds.