Policy HC3: Affordable Housing

Comment

Representation ID: 4082

Received: 13/12/2022

Respondent: Staffordshire Police

Affordable homes should be dispersed evenly through the development, not grouped together in large numbers. Groups of terraced housing can lead to neighbour tensions over parking. Apartment blocks should have CCTV at communal entrances.

Object

Representation ID: 4248

Received: 23/12/2022

Respondent: McCarthy Stone

Agent: Miss Natasha Styles

Legally compliant? No

Sound? No

Duty to co-operate? Yes

As older peoples’ housing has been found to not be viable with a 30% affordable housing threshold the affordable housing requirement should be amended for such schemes to ensure the Plan is in accordance with national policy and its own evidence.

The Plan should clarify that older people's housing schemes should be exempt from providing first homes and starter homes.

The stage 1 viability study should be updated to ensure up to date values for older person's housing schemes are used to reflect the current market conditions. Thresholds should be reduced or a nil affordable housing requirement introduced where necessary.

Object

Representation ID: 4357

Received: 19/12/2022

Respondent: CPRE Staffordshire

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? No

CPRE analysis shows that Green Belt sites build at lower densities and the majority of homes provided on such sites are unaffordable by the NPPF's definition. Other CPRE reports indicate that greenfield is being increasingly used over brownfield, despite brownfield land increasing and being found in high supply in all regions of England. Despite this there is a substantial decrease in the proportion of housing units with planning permission, down to 44%, the lowest since registers began.

Comment

Representation ID: 4472

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Bloor Homes notes that for all major developments 30% of all homes are to be delivered as affordable housing. This appears to be broadly supported by the2021 Stage 1 Viability Study which determined the current affordable housing requirement of 40% affordable provision is very unlikely to prove supportable on larger schemes with significant infrastructure costs. The Stage 1 Viability Study confirmed that affordable housing within the range of 20-30% is potentially relevant to strategic housing sites overall, assuming a maximum of £9,200/dwelling S106 costs and no additional CIL contribution. For Land East of Bilbrook the appraisal appears to assume approximately £14,000/dwelling S106 costs and no additional CIL contribution, although this is not clear within the site appraisals. Bloor Homes recognises that S106 costs will be subject to change at the planning application stage.
Viability is dynamic and the Council’s evidence relates to a snapshot in time. Therefore, Bloor Homes supports the mechanism within Policy HC3 to submit a viability assessment at the application stage if it can be demonstrated that circumstances have changed. Such circumstances should include increasing infrastructure costs or changes to house prices or build costs.

Comment

Representation ID: 4506

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes notes that for all major developments 30% of all homes are to be delivered as affordable housing. This appears to be broadly supported by the 2021 Stage 1 Viability Study which determined the current affordable housing requirement of 40% affordable provision is very unlikely to prove supportable on larger schemes with significant infrastructure costs.
Viability is dynamic and the Council’s evidence relates to a snapshot in time.
Therefore, Cameron Homes supports the mechanism within Policy HC3 to submit a viability assessment at the application stage if it can be demonstrated that circumstances have changed. Such circumstances should include increasing infrastructure costs or changes to house prices or build costs.

Comment

Representation ID: 4536

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes notes that for all major developments 30% of all homes are to be delivered as affordable housing. This appears to be broadly supported by the 2021 Stage 1 Viability Study which determined the current affordable housing requirement of 40% affordable provision is very unlikely to prove supportable on larger schemes with significant infrastructure costs.
Viability is dynamic and the Council’s evidence relates to a snapshot in time.
Therefore, Cameron Homes supports the mechanism within Policy HC3 to submit a viability assessment at the application stage if it can be demonstrated that circumstances have changed. Such circumstances should include increasing infrastructure costs or changes to house prices or build costs.

Comment

Representation ID: 4562

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes notes that for all major developments 30% of all homes are to be delivered as affordable housing. This appears to be broadly supported by the 2021 Stage 1 Viability Study which determined the current affordable housing requirement of 40% affordable provision is very unlikely to prove supportable on larger schemes with significant infrastructure costs.
Viability is dynamic and the Council’s evidence relates to a snapshot in time. Therefore, Cameron Homes supports the mechanism within Policy HC3 to submit a viability assessment at the application stage if it can be demonstrated that circumstances have changed. Such circumstances should include increasing infrastructure costs or changes to house prices or build costs.

Comment

Representation ID: 4586

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Evolve Planning & Design

The Stage 1 Viability Study confirmed that affordable housing within the range of 20-30% is potentially relevant to strategic housing sites overall, assuming a maximum of £9,200/dwelling S106 costs and no additional CIL contribution.
is recognised that a Stage 2 Viability Assessment builds upon the Stage 1 findings and includes updated assumptions on development costs and values, including a review of the four strategic sites. For Cross Green the appraisal appears to assume approximately £11,000/dwelling S106 costs and no additional CIL contribution, although this is not clear within the site appraisals. Taylor Wimpey recognises that S106 costs will be subject to change at the planning application stage.
Viability is dynamic and the Council’s evidence relates to a snapshot in time. Therefore, Taylor Wimpey supports the mechanism within Policy HC3 to submit a viability assessment at the application stage if it can be demonstrated that circumstances have changed. Such circumstances should include increasing infrastructure costs or changes to house prices or build costs.
The policy refers to further guidance being provided by the Affordable Housing SPD is noted. The SPD is not the appropriate approach for setting new policy and or burdens on delivery, and the Local Plan should provide clarity at the point of adoption as to what is required to be delivered.

Comment

Representation ID: 4619

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

Four Ashes Road Ltd notes that for all major developments 30% of all homes are to be delivered as affordable housing. This appears to be broadly supported by the 2021 Stage 1 Viability Study which determined the current affordable housing requirement of 40% affordable provision is very unlikely to prove supportable on larger schemes with significant infrastructure costs.
Viability is dynamic and the Council’s evidence relates to a snapshot in time.
Therefore, the mechanism within Policy HC3 is supported, which allows for the submission of a viability assessment at the application stage if it can be
demonstrated that circumstances have changed. Such circumstances should include increasing infrastructure costs or changes to house prices or build costs.

Object

Representation ID: 4634

Received: 22/12/2022

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Clowes objects to policy HC3 as written because it is not justified.Paragraph 8.10 of the SHMA 2022 sets out that 50% of the affordable housing requirement should be both affordable rent / social rent. Greater clarity is required regarding the justification for the requirement for 50% social rent only in policy HC3, and why it makes no reference to affordable rent.

Furthermore we consider that Policy HC3 should be amended to state ‘where viable’ in order to provide sufficient flexibility and allow tenures to be agreed between SSDC and the applicant on a site by site basis and determined on local need at the time of the application.

Comment

Representation ID: 4675

Received: 22/12/2022

Respondent: Keon Homes

Agent: Evolve Planning & Design

Keon Homes notes that for all major developments 30% of all homes are to be delivered as affordable housing. This appears to be broadly supported by the 2021 Stage 1 Viability Study which determined the current affordable housing requirement of 40% affordable provision is very unlikely to prove supportable on larger schemes with significant infrastructure costs.
Viability is dynamic and the Council’s evidence relates to a snapshot in time. Therefore, Keon Homes supports the mechanism within Policy HC3 to submit a viability assessment at the application stage if it can be demonstrated that circumstances have changed. Such circumstances should include increasing infrastructure costs or changes to house prices or build costs.

Support

Representation ID: 4688

Received: 12/12/2022

Respondent: Mr Mark Stephens

Agent: Advance Land & Planning Limited

Support the proposed affordable housing requirement of 30%.

Comment

Representation ID: 4715

Received: 22/12/2022

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Lovell Homes notes that for all major developments 30% of all homes are to be delivered as affordable housing. This appears to be broadly supported by the 2021 Stage 1 Viability Study which determined the current affordable housing requirement of 40% affordable provision is very unlikely to prove supportable on larger schemes with significant infrastructure costs.
Viability is dynamic and the Council’s evidence relates to a snapshot in time.
Therefore, Lovell Homes supports the mechanism within Policy HC3 to submit a viability assessment at the application stage if it can be demonstrated that
circumstances have changed. Such circumstances should include increasing infrastructure costs or changes to house prices or build costs.

Object

Representation ID: 4736

Received: 22/12/2022

Respondent: Hallam Land Management

Agent: Acres Land & Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Whilst the 30% requirement for affordable housing is accepted, this need not be a fixed figure. Sites will need to be considered against wider viability criteria and judged on its own merits/circumstances.

The Viability Study 2022 identifies that some sites may struggle to meet the affordable housing requirement. This may become more pronounced during a recession.

The guidance concerning the share and spread of affordable products is welcomed; but should not be a requirement as some sites may not be able to accommodate 50% Social Rented housing. Shared Ownership may become less attractive as interest rates rise, so developers should be given the opportunity to vary the offer to respond to local demand, viability factors, and grant funding circumstances at the time. The council should not hamstring itself by binding requirements to the SHMA.

Object

Representation ID: 4751

Received: 22/12/2022

Respondent: Tetlow King Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

There is concern that the tenure mix proposed completely cuts out the affordable rented tenure. The proposed tenure split does not account for all affordable needs as those who qualify for affordable rent may not qualify for social rent. Further policy text should be added which allows for tenure split to be discussed on a site by site basis.

In larger sites it is recommended that affordable housing is clustered rather than pepper potted, with the policy expecting a maximum group size of 10-15 dwellings. This can be achieved while delivering visually indistinguishable housing products that are well dispersed. It also allows effective management and maintenance over the life time of development.

Securing affordable housing in perpetuity for all major housing development is not supported and will likely affect viability. Affordable housing kept in perpetuity should only relate to rural exception sites.

Staircasing restrictions impact consumer appetites for products and as a financial impact on housing associations. Policy H3 should recognise there will be occasions where special circumstances apply to warrant removal of the staircasing restriction on a case by case basis.

It is good practice to include the affordable housing requirements within the plan itself.

Object

Representation ID: 4762

Received: 19/12/2022

Respondent: Mrs Joanne Harding

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Housing Market Assessment Update (2022) identifies a net affordable housing need of between 67 dpa and 156 dpa. The NPPF is, however, clear that the derivation of affordable housing policies must not only take account of need but also viability and deliverability. The Council should be considering a differentiated policy approach to the provision of affordable housing in line with the evidence provided in their Viability Study. It may be beneficial for the Council to refer to other affordable home ownership products not just Shared Ownership in line with definition of affordable housing in the NPPF.

Object

Representation ID: 4813

Received: 22/12/2022

Respondent: Crest Nicholson

Agent: Avison Young

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

A blanket requirement for 30% affordable housing requirement on all sites is not justified having regard to paragraphs 3.2.2 and 3.2.3 of the Viability Study (2022), not consistent with the NPPF requirement that the levels and types of affordable housing should not undermine plan deliverability.

Object

Representation ID: 4819

Received: 24/02/2023

Respondent: Trine Developments Limited

Agent: Cerda Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

In terms of cross reference between these policies and Policy SA4 – Strategic development location: Land North of Penkridge. The policy requirements are clear that at least 40 units providing for specialist elderly housing are required on each of the housing allocations. It is not clear whether the housing mix, density and affordable housing provision for each of the strategic allocations is to be met within individual planning applications (which could be numerous) or within the allocation as a whole. For clarity and in order to avoid confusion this matter should be identified either within these policies or Policies MA1 or SA4.

Object

Representation ID: 4842

Received: 22/12/2022

Respondent: David Wilson Homes

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The proposed policy should be less prescriptive in terms of tenure mix, to allow sites to best respond to current housing needs with a location and site-specific approach. Impact on scheme viability is referenced in the existing policy H2, and there should also be an allowance for a consideration of site viability, including whether there is a need for new infrastructure etc. which could impact on delivery of the allocated sites. The proposed tenure split for affordable housing is broadly in line with the need evidenced in the Housing Market Assessment Update 2022. However, this may change over time and location-specific flexibility should be provided.

Comment

Representation ID: 4887

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

The latest Housing Market Assessment Update (2022) identifies a net affordable housing need of between 67 dpa and 156 dpa, dependent on the proportion of
household income used spent on housing costs. The Viability Study (2022) clearly highlights the challenges in delivering the 30% affordable housing requirement, and highlights that without higher sales values the sites would not necessarily be viable. As such, affordable housing policy should take full account of all evidence in terms of both affordable housing need and viability, and ensure that sufficient flexibility remains.
PPG states that a minimum of 25% of all affordable housing units secured through developer contributions should be First Homes. The NPPF states that planning policies should expect at least 10% of the total number of homes to be available for affordable home ownership. The proposed policy is consistent with these requirements.
However, in relation to affordable housing tenure, existing Core Strategy policy H2 states that the precise proportion of affordable housing tenure split will be agreed with
the Council “having regard to local housing needs within the locality of the development, exceptional circumstances and the effects on the viability of a scheme.”
The proposed policy should be less prescriptive in terms of tenure mix, to allow sites to best respond to current housing needs with a location and site-specific approach.
Impact on scheme viability is referenced in the existing policy H2, and there should also be an allowance for a consideration of site viability, including whether there is a need for new infrastructure etc. which could impact on delivery of the allocated sites. The proposed tenure split for affordable housing is broadly in line with the need evidenced in the Housing Market Assessment Update 2022. However, this may change over time and location-specific flexibility should be provided.

Comment

Representation ID: 4926

Received: 21/12/2022

Respondent: Bellway Homes Ltd

Agent: Turley

The latest Housing Market Assessment Update (2022) identifies a net affordable housing need of between 67 dpa and 156 dpa, dependent on the proportion of
household income used spent on housing costs. The Viability Study (2022) clearly highlights the challenges in delivering the 30% affordable housing requirement, and
highlights that without higher sales values the sites would not necessarily be viable. As such, affordable housing policy should take full account of all evidence in terms of both affordable housing need and viability, and ensure that sufficient flexibility remains.

PPG states that a minimum of 25% of all affordable housing units secured through developer contributions should be First Homes. The NPPF states that planning policies should expect at least 10% of the total number of homes to be available for affordable home ownership. The proposed policy is consistent with these requirements.

However, in relation to affordable housing tenure, existing Core Strategy policy H2 states that the precise proportion of affordable housing tenure split will be agreed with
the Council “having regard to local housing needs within the locality of the development, exceptional circumstances and the effects on the viability of a scheme.”

The proposed policy should be less prescriptive in terms of tenure mix, to allow sites to best respond to current housing needs with a location and site-specific approach.
Impact on scheme viability is referenced in the existing policy H2, and there should also be an allowance for a consideration of site viability, including whether there is a need for new infrastructure etc. which could impact on delivery of the allocated sites. The proposed tenure split for affordable housing is broadly in line with the need evidenced in the Housing Market Assessment Update 2022. However, this may change over time and location-specific flexibility should be provided.

Comment

Representation ID: 4949

Received: 23/12/2022

Respondent: Churchill Retirement Living

Agent: Planning Issues

Churchill Retirement Living have provided commentary and supplemental evidence and their own viability appraisal in a separate document entitled 'Review of Local Plan Viability Assessment for Sheltered Housing'. All scenarios tested result in a substantial negative residual land value. The Local Plan Viability Study itself was issued in October 2022, informed by evidence from earlier in 2022 when the property market was more bouyant. It does not reflect the uncertainty currently in the property market at present, which market commentators are forecasting to continue into 2023. The Council should ensure there is sufficient headroom in the viability of developments and that its policy requirements are robustly tested.

Object

Representation ID: 4964

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The policy proposes specific percentages for each affordable tenure. Barratt objects to this requirement. Paragraph 8.10 of the SHMA 2022 sets out that 50% of the affordable housing requirement of the affordable housing provision to be both affordable rent/ social rent. A distinction needs to be made between affordable and social rent, and this should be reflected in the policy.

Object

Representation ID: 4986

Received: 20/12/2022

Respondent: Barratt West Midlands

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The policy proposes specific percentages for each affordable tenure. Barratt objects to this requirement. Paragraph 8.10 of the SHMA 2022 sets out that 50% of the affordable housing requirement of the affordable housing provision to be both affordable rent/ social rent. A distinction needs to be made between affordable and social rent, and this should be reflected in the policy.

Object

Representation ID: 5066

Received: 20/03/2023

Respondent: Boningale Homes ltd.

Agent: Enzygo

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Concern that 30% requirement is over optimistic given the reliance on strategic sites. A more balanced portfolio of sites is required including proportionate scale sites associated with the small settlements.

Object

Representation ID: 5085

Received: 19/12/2022

Respondent: Barberry

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We consider that in relation to the proposed 25% shared ownership and 25% first homes tenures, there should be some flexibility given here as it allows affordable rent to be substituted against shared ownership. To not include or indicate this within the policy would, in our view make the policy inconsistent with NPPF para 82.

Object

Representation ID: 5117

Received: 22/12/2022

Respondent: Redrow Homes

Agent: Harris Lamb Property Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy HC3 requires 30% affordable housing provision. This approach is flawed. We comment on this matter in detail in our response to Table 7. In short, the 30%
affordable housing provision target does not reflect the affordable housing needs of the district. It is based upon the Birmingham and Black Country element of the
housing requirement delivering affordable housing support of the growth of South Staffordshire. Clearly any affordable housing delivered as part of the Birmingham and Black Country element of the housing target should be to support affordable housing needs to Birmingham and the Black Country.
As detailed in our response to Table 7, in order to meet the annual affordable housing requirement it would necessitate 50% affordable housing provision on the South Staffordshire element of the housing requirement. This is likely to make development unviable and has not been tested as part of the plan making process.
Furthermore, policy HC3 should set an affordable housing requirement for the South Staffordshire element of the Plan’s housing requirement and separately for the
conurbation’s affordable housing need. These are two separate requirements and should be treated as such.

Comment

Representation ID: 5126

Received: 13/12/2022

Respondent: Seven Homes

Agent: RCA Regeneration

We consider that in relation to the proposed 25% shared ownership and 25% first homes tenures, there should be some flexibility given here as it allows affordable rent to be substituted against shared ownership. To not include or indicate this within the policy would, in our view make the policy inconsistent with NPPF para 82.

Object

Representation ID: 5139

Received: 19/12/2022

Respondent: St Philips

Agent: RCA Regeneration

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We consider that in relation to the proposed 25% shared ownership and 25% first homes tenures, there should be some flexibility given here as it allows affordable rent to be substituted against shared ownership. To not include or indicate this within the policy would, in our view make the policy inconsistent with NPPF para 82.

Support

Representation ID: 5151

Received: 21/12/2022

Respondent: Taylor Reed Homes

Agent: RCA Regeneration Ltd

Our client has made us aware that they are willing to support a proposal that is above 30%.

We consider that in relation to the proposed 25% shared ownership and 25% first homes tenures, there should be some flexibility given here as it allows affordable rent to be substituted against shared ownership. To not include or indicate this within the policy would, in our view make the policy inconsistent with NPPF para 82.