Rother Local Plan 2020-2040 (Regulation 18)

Comment

Representation ID: 27624

Received: 23/07/2024

Respondent: Southern Housing

The supporting text (paragraph 8.22) states that the HEDNA indicates there is a need for 325 affordable homes per annum, and that this figure is greater than the annual average of all homes delivered since 2011. This highlights the severe lack of housing delivery across Rother. As set out in our responses to Q77 and Q76, the Council should aim for the higher level of growth to try and meet as much housing need as possible (both market and affordable). Failure to meet identified need will ensure a large level of unmet need later in the plan period/start of the next local plan period. This will make it difficult to deliver the level of economic and other growth identified in the draft local plan. Subject to the review identified at (paragraph 7.9) of the HELAA, RDC should consider maximising the number of homes and ensuring the percentage of affordable homes is adjusted accordingly.

We welcome the fact the draft policy (footnote 52) acknowledges the approach for First Homes may change. RDC should consider allowing flexibility to deliver other affordable tenures in lieu of First Homes, particularly on 100% affordable schemes.

Please see also our response to Q77 and Q76 relating to the development strategy.

Comment

Representation ID: 27625

Received: 23/07/2024

Respondent: Southern Housing

The supporting text (paragraph 8.22) states that the HEDNA indicates there is a need for 325 affordable homes per annum, and that this figure is greater than the annual average of all homes delivered since 2011. This highlights the severe lack of housing delivery across Rother. As set out in our responses to Q77 and Q76, the Council should aim for the higher level of growth to try and meet as much housing need as possible (both market and affordable). Failure to meet identified need will ensure a large level of unmet need later in the plan period/start of the next local plan period. This will make it difficult to deliver the level of economic and other growth identified in the draft local plan. Subject to the review identified at (paragraph 7.9) of the HELAA, RDC should consider maximising the number of homes and ensuring the percentage of affordable homes is adjusted accordingly.

We welcome the fact the draft policy (footnote 52) acknowledges the approach for First Homes may change. RDC should consider allowing flexibility to deliver other affordable tenures in lieu of First Homes, particularly on 100% affordable schemes.

Please see also our response to Q77 and Q76 relating to the development strategy.

Comment

Representation ID: 27626

Received: 23/07/2024

Respondent: Southern Housing

The supporting text (paragraph 8.22) states that the HEDNA indicates there is a need for 325 affordable homes per annum, and that this figure is greater than the annual average of all homes delivered since 2011. This highlights the severe lack of housing delivery across Rother. As set out in our responses to Q77 and Q76, the Council should aim for the higher level of growth to try and meet as much housing need as possible (both market and affordable). Failure to meet identified need will ensure a large level of unmet need later in the plan period/start of the next local plan period. This will make it difficult to deliver the level of economic and other growth identified in the draft local plan. Subject to the review identified at (paragraph 7.9) of the HELAA, RDC should consider maximising the number of homes and ensuring the percentage of affordable homes is adjusted accordingly.

We welcome the fact the draft policy (footnote 52) acknowledges the approach for First Homes may change. RDC should consider allowing flexibility to deliver other affordable tenures in lieu of First Homes, particularly on 100% affordable schemes.

Please see also our response to Q77 and Q76 relating to the development strategy.

Comment

Representation ID: 27627

Received: 23/07/2024

Respondent: Southern Housing

We welcome the inclusion of draft Policy HOU3. As identified in the draft plan, there is a significant need for affordable housing in Rother and supply is falling short (paragraph 8.22). It is therefore encouraging that the Council is supportive of 100% affordable housing schemes to help address this matter. Point ii) of the policy states the tenure should be discussed on a case-by-basis. While we support this, it’s important to allow flexibility in to order to ensure greater certainty of delivery by Registered Providers (RPs). This will allow RPs greater opportunity to submit applications for viable schemes during difficult times for the sector (such as the issues being experienced at present, such as capped rents, rising build costs, high cost of borrowing, high cost of labour, etc).

Comment

Representation ID: 27628

Received: 23/07/2024

Respondent: Southern Housing

We welcome the inclusion of draft Policy HOU3. As identified in the draft plan, there is a significant need for affordable housing in Rother and supply is falling short (paragraph 8.22). It is therefore encouraging that the Council is supportive of 100% affordable housing schemes to help address this matter. Point ii) of the policy states the tenure should be discussed on a case-by-basis. While we support this, it’s important to allow flexibility in to order to ensure greater certainty of delivery by Registered Providers (RPs). This will allow RPs greater opportunity to submit applications for viable schemes during difficult times for the sector (such as the issues being experienced at present, such as capped rents, rising build costs, high cost of borrowing, high cost of labour, etc).

Comment

Representation ID: 27629

Received: 23/07/2024

Respondent: Southern Housing

As per our response to Q119, we support the principle of this policy given the level of affordable housing need. However, as drafted, the policy only makes provision for allocating 100% affordable housing schemes in Neighbourhood Plans. Consideration should be given to allocating 100% affordable housing sites in the local plan or a future planning document if required. This will ensure greater certainty of delivery.

Comment

Representation ID: 27630

Received: 23/07/2024

Respondent: Southern Housing

As per our response to Q119, we support the principle of this policy given the level of affordable housing need. However, as drafted, the policy only makes provision for allocating 100% affordable housing schemes in Neighbourhood Plans. Consideration should be given to allocating 100% affordable housing sites in the local plan or a future planning document if required. This will ensure greater certainty of delivery.

Comment

Representation ID: 27631

Received: 23/07/2024

Respondent: Southern Housing

We support Policy HOU5 for the same reasons as set out in our response to Q119 and 121. Affordable housing is required at rural settlements to help create mixed and balanced communities. The provision of small-scale schemes will help ensure local residents have the opportunity to remain in these locations.

Comment

Representation ID: 27632

Received: 23/07/2024

Respondent: Southern Housing

We support Policy HOU5 for the same reasons as set out in our response to Q119 and 121. Affordable housing is required at rural settlements to help create mixed and balanced communities. The provision of small-scale schemes will help ensure local residents have the opportunity to remain in these locations.

Comment

Representation ID: 27633

Received: 23/07/2024

Respondent: Southern Housing

The Council needs to ensure a variety of dwelling types are provided across Rother. The subdivision of properties can assist in achieving this provided schemes are of a sufficient quality. We therefore welcome the inclusion of the policy criteria, which appear to be aimed at ensuring quality accommodation for the lifetime of a conversion scheme.