Policy LHN2: Affordable Housing

Showing comments and forms 1 to 11 of 11

Object

Proposed Submission Core Strategy

Representation ID: 20611

Received: 21/09/2011

Respondent: Sedlescombe Parish Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

LHN2(iv)(a) The "Affordable Housing" background paper mentions that affordable housing should be provided in rural areas where there is a "demonstrable need" and not in accordance with a blanket percentage figure of houses to be provided. Villages which already have a greater percentage of affordable housing than the average of the District should not be required to add further to that stock. With the latest Housing Needs Survey in this parish being ten years ago, it is not likely that up-to-date information regarding need will be available when housing development is proposed.

Full text:

LHN2(iv)(a) The "Affordable Housing" background paper mentions that affordable housing should be provided in rural areas where there is a "demonstrable need" and not in accordance with a blanket percentage figure of houses to be provided. Villages which already have a greater percentage of affordable housing than the average of the District should not be required to add further to that stock. With the latest Housing Needs Survey in this parish being ten years ago, it is not likely that up-to-date information regarding need will be available when housing development is proposed.

Object

Proposed Submission Core Strategy

Representation ID: 20613

Received: 21/09/2011

Respondent: Sedlescombe Parish Council

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Robust justification for seeking developer contributions in lieu of onsite provision of affordable housing on the scale proposed as stated in PPS3 has not been provided.

Full text:

Robust justification for seeking developer contributions in lieu of onsite provision of affordable housing on the scale proposed as stated in PPS3 has not been provided.

Object

Proposed Submission Core Strategy

Representation ID: 20778

Received: 27/09/2011

Respondent: Trinity College

Agent: Bidwells

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Trinity College supports the flexible approach to affordable housing provision provided in Policy LHN2. Whilst the 30% affordable housing seems high in these financially challenging times, and based on the findings of the GVA Housing Viability Study, the ability for this requirement to be reduced to reflect changing needs is welcomed.

To further clarify Policy in relation to housing being provided to help support business development, it would be useful to include specific reference to NE Bexhill, which requires housing development to contribute to the provision of infrastructure to support business development on new sites in North East Bexhill.

Full text:

Trinity College supports the flexible approach to affordable housing provision provided in Policy LHN2. Whilst the 30% affordable housing seems high in these financially challenging times, and based on the findings of the GVA Housing Viability Study, the ability for this requirement to be reduced to reflect changing housing needs, development viability and the desire to deliver other local objectives such as job creation and business development is welcomed.

To further clarify the Policy in relation to housing being provided to help support business development, it would be useful to include specific reference to North East Bexhill, which requires housing development to contribute to the provision of infrastructure to support business development on new sites in North East Bexhill.

Support

Proposed Submission Core Strategy

Representation ID: 20889

Received: 09/11/2011

Respondent: Crowhurst Parish Council

Representation Summary:

We support this policy.

Full text:

We support this policy.

Object

Proposed Submission Core Strategy

Representation ID: 20894

Received: 09/11/2011

Respondent: Laurence Keeley

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

If we develop as propsoed in the Core Strategy we will continue to build awful estates which I believe contribute to a host of negatives including family breakdown, depression, mental health issues and vandalism. poor design and quality is exacerbated by the lack of open space. If, for example, you were to go and visit Hailsham and Hellingly area you could see the awful estates being developed. The houses are too compacted; there are no open spaces, cheaply built and expensive to buy.
See comments to policy EC1 plus visit www.campaign-for-change.co.uk for more details.

Full text:

If we develop as propsoed in the Core Strategy we will continue to build awful estates which I believe contribute to a host of negatives including family breakdown, depression, mental health issues and vandalism. poor design and quality is exacerbated by the lack of open space. If, for example, you were to go and visit Hailsham and Hellingly area you could see the awful estates being developed. The houses are too compacted; there are no open spaces, cheaply built and expensive to buy.

Open market housing makes most people have mortgages beyong their means, again I may refer you to my previous comment made on policy EC1 referring to the community land trust, adn we shoudl not allow developers to build what they want but should instruct them to build what is needed. We cannot have open market housing with more and more people dependent in part-time jobs. In my comment on policy EC1 I state that there is a need for a large number of affordable dwellings annually. It then goes on to say that Rother District will deliver them over a number of years, some of these may be called affordable when in reality they are not and the vast majority will remain on the waiting list. The 70% open market can bring more people to the area, putting more pressure on social services and school placements. We should stop building open market housing. See comments to policy EC1 plus visit www.campaign-for-change.co.uk for more details.

Support

Proposed Submission Core Strategy

Representation ID: 20916

Received: 08/11/2011

Respondent: Glyndebourne 1991 L & P Trust

Agent: Strutt & Parker

Representation Summary:

It is noted that affordable housing contributions will typically be needed for all developments of one dwelling or over in rural areas.
It is noted that the level of affordable housing required in the rural area will remain at current levels identified within the Local Plan -40%.
The policy also states that there will exception to the level of affordable housing sought where the main purpose of housing is to support business development, where job creation is a priority. This exception is strongly supported as it reinforces the importance of sustainable mixed use development which is consistent with National Policy.

Full text:

It is noted that an affordable housing contribution will typically be needed for all developments of one dwelling or over in rural areas.
It is noted that the level of affordable housing required in the rural area will remain at the current level identified within the Rother Local Plan 40%.
The policy also states that there will exception to the level of affordable housing sought where the main purpose of housing is to support business development, where job creation is a priority. This exception is strongly supported as it reinforces the importance of sustainable mixed use development which is also detailed in National Planning Policy.

Support

Proposed Submission Core Strategy

Representation ID: 21010

Received: 29/09/2011

Respondent: Messrs. R. & J.C. Stapylton-Smith

Agent: DHA Planning

Representation Summary:

The continuation of the 40% requirement as set out in the 2006 Rother Affordable Housing SPD is welcomed and considered to be the most suitable delivery mechanism of affordable housing within the district.

The recognition of market conditions and the impact of affordable housing provision on financial viability for housing development is particularly welcomed and the introduction of an appropriate exception clause is considered vital to ensuring the continue delivery of housing development over the plan period. This policy is therefore considered to be both justified and efficient.

Full text:

Policy LNH2 sets the level of affordable housing to be provided in housing developments according to localised areas within the district. In the Rural Areas the policy requires 40% of the development to comprise affordable housing on schemes of 5 dwellings or more; or financial contributions on a sliding scale up to the equivalent of providing 40% affordable housing in lieu of on-site provision on all residential schemes of less than 5 dwellings.

The policy states that where it can be demonstrated that these requirements would either render otherwise suitable development unviable, or where the local need for affordable housing would no longer justify the above levels, the proportion of affordable housing will be expected to be the most that does not undermine viability, or is needed locally.

The continuation of the 40% requirement as set out in the 2006 Rother Affordable Housing SPD is welcomed and considered to be the most suitable delivery mechanism of affordable housing within the district.

The recognition of market conditions and the impact of affordable housing provision on financial viability for housing development is particularly welcomed and the introduction of an appropriate exception clause is considered vital to ensuring the continue delivery of housing development over the plan period. This policy is therefore considered to be both justified and efficient.

Support

Proposed Submission Core Strategy

Representation ID: 21041

Received: 11/11/2011

Respondent: Rother and Hastings CPRE

Representation Summary:

CPRE Sussex welcomes and supports criterion (iv) of Policy LHN2 on Affordable Housing:

(iv) In the Rural Areas:
a) 40% on-site affordable housing on schemes of 5 dwellings or more; or
b) A financial contribution, on a sliding scale up to the equivalent of providing 40% affordable housing, in lieu of on-site provision on all residential schemes of less than 5 dwellings.

Full text:

CPRE Sussex welcomes and supports criterion (iv) of Policy LHN2 on Affordable Housing:

(iv) In the Rural Areas:
a) 40% on-site affordable housing on schemes of 5 dwellings or more; or
b) A financial contribution, on a sliding scale up to the equivalent of providing 40% affordable housing, in lieu of on-site provision on all residential schemes of less than 5 dwellings.

Object

Proposed Submission Core Strategy

Representation ID: 21092

Received: 09/11/2011

Respondent: Rye Town Council

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The evidence base indicates that there is more locally derived need unmet in Rye than elsewhere in Rother. The Strategic Housing Market Assessment recommends 40% affordable housing in Rye and whilst being less profitable is still viable.

It is therefore disappointing that the provision of affordable housing within developments has been reduced from 40% to 30%.
The reduction in the allocation of affordable housing provision, combined with the reduction in housing allocation from 450 to 350, and the fact that there is a strong second home market in Rye ) means that local demand for homes will not be met.

Full text:

It is clear from the evidence base that there is more locally derived need unmet in Rye than elsewhere in Rother (S.2.37 Rye and Rye Harbour Study 2011). The Affordable Housing Background Paper 2011refers to the Strategic Housing Market Assessment (SHMA) 2010 that recommends 40% affordable housing in Rye. The Affordable Housing Viability Study (AVHS) was drafted in parallel to the SHMA in order to ensure that the conclusions could be used to inform both studies. This indicates that 40% while being less profitable is still viable.

It is therefore disappointing that the provision of new affordable housing within new developments in Rye has been reduced from the current 40% to 30%. The main reason given within paragraph 15.28 is to kick start regeneration. This appears to be a reaction to the current economic conditions whereas the Core Strategy covers a period of 17 years to 2028 which will see the economy over a number of economic cycles.

The reduction in the allocation of affordable housing provision, combined with the reduction in the housing allocation from 450 to 350, and the fact that there is a strong second home market in Rye (including new properties) means that local demand for homes will not be met.

Please also note typing error in the last paragraph on page 119 which refers to proposals for less than 15 houses in Bexhill and Rye and 10 in Battle. It should read 15 in Bexhill and 10 in Rye and Battle

Object

Proposed Submission Core Strategy

Representation ID: 21119

Received: 09/11/2011

Respondent: Town and Country Planning Solutions

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Part (v)

While it is acknowledged that there is a high level of need within the rural parts, the 40% requirement could render open market housing development as unviable. This is of significance, as housing development in rural settlements makes a significant contribution to overall housing.

While the policy enables an applicant to demonstrate viability, no clarification is provided as to the level or nature of such justification.

It is also unclear how the Council would manage financial contributions or be directed towards the provision of affordable housing.

Full text:

Part (v)

While it is acknowledged that there is a high level of need for affordable housing within the rural parts of the district, the 40% requirement of schemes of 5 dwellings or more (or the financial equivalent of 40% affordable housing on sites of 5 dwellings or less) could render open market housing development as being unviable. This is of significance, as the district has a rural character with only 3 principal towns (Bexhill, Battle and Rye) and therefore housing development in rural settlements makes a significant contribution to overall housing supply in the District.

While part of the policy enables an applicant to demonstrate viability in relation to the provision of affordable housing, no clarification is provided as to the level or nature of such justification to satisfy the Council in this respect.

It is also unclear how the Council would manage the financial contribution (part (iv)(b) of the Policy) or how this would be directed towards the provision of affordable housing on other sites that might be specifically allocated for affordable housing, as there is no cross-reference or link to draft Policy LHN4 (Sites for wholly or substantially affordable housing).

Object

Proposed Submission Core Strategy

Representation ID: 21298

Received: 11/11/2011

Respondent: Marchfield Strategic Land Ltd

Agent: JB Planning Associates Ltd.

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Delivering affordable housing is listed as the second "main issue" for the Core Strategy (paragraph 4.2).

We do not doubt the significance or severity of the issue. Our representations are concerned with whether the CS provides the most appropriate response to affordable housing delivery:

The significant need for affordable housing is not properly reflected in the wider housing strategy, with both the reduction in planned growth and the manner in which that growth is proposed to be accommodated; and

(2) The proposed Affordable Housing Policy is not sufficiently robust in terms of either thresholds or the overall target.

Full text:

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.