Publication Plan April 2024

Object

Representation ID: 5994

Received: 31/05/2024

Respondent: West Midlands Housing Association Planning Consortium

Agent: Tetlow King Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The tenure mix proposed by Policy HC3 ‘Affordable Housing’ (25% First Homes, 50% Social Rent, 25% Shared Ownership) completely disregards the affordable rented tenure. The proposed tenure split therefore does not account for all affordable needs as those who qualify for affordable rent may not qualify for social rent.

Comment

Representation ID: 5995

Received: 31/05/2024

Respondent: West Midlands Housing Association Planning Consortium

Agent: Tetlow King Planning

Principal concern is to optimise the provision of affordable housing and to ensure the evolution and preparation of consistent policies that help deliver the wider economic and social outcomes needed throughout the West Midlands region.

As significant developers and investors in local people, the WMHAPC is well placed to contribute to local plan objectives and the Housing Associations to act as long-term partners in the community.

Comment

Representation ID: 5996

Received: 31/05/2024

Respondent: West Midlands Housing Association Planning Consortium

Agent: Tetlow King Planning

Appreciates the intention to require new development to fully integrate and be materially indistinguishable from the market housing as well as suitably pepper pot the affordable housing across the site. However, this approach is not the most suitable for many housing associations and registered providers as it makes management more difficult as the properties are more spread out. The WMHAPC would not encourage affordable housing to be grouped together in one area, instead, recommending that affordable housing is clustered across a site, with policy expressing a maximum group size or range; approximately 10-15 dwellings forming each cluster on larger sites (circa 100+ dwellings) is often favoured.

Object

Representation ID: 5997

Received: 31/05/2024

Respondent: West Midlands Housing Association Planning Consortium

Agent: Tetlow King Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Paragraph 7 of Policy HC3 asserts that all affordable housing will be secured in perpetuity. The sole reference in the NPPF to retaining affordable housing in perpetuity is in Annex 2 where this is sought for affordable housing delivered on Rural Exception Sites.

“Rural exception sites: small sites used for affordable housing in perpetuity where sites would not normally be used for housing. . . A proportion of market homes may be allowed on the site at the local planning authority’s discretion, for example where essential to enable the delivery of affordable units without grant funding.”

This principle is appropriate and supported by our members as this helps to secure land for delivery of affordable housing in rural areas where housing delivery would otherwise not be supported. Securing affordable housing in perpetuity more widely is not supported as it restricts lenders’ appetite to fund development, private companies will not typically invest in developments if there is no prospect of realising the original investment and any returns. We therefore request that all references to securing affordable housing in perpetuity are removed from the draft Local Plan unless they are made specifically in relation to Rural Exception Sites.

Comment

Representation ID: 5998

Received: 31/05/2024

Respondent: West Midlands Housing Association Planning Consortium

Agent: Tetlow King Planning

The draft Local Plan does not set out an affordable housing needs figure or requirement. While the Council’s evidence base includes the 2022 Strategic Housing Market Assessment Update (SHMA), it is nevertheless good practice to include an affordable housing target in the Plan itself to allow for effective monitoring of affordable housing delivery.

Comment

Representation ID: 5999

Received: 31/05/2024

Respondent: West Midlands Housing Association Planning Consortium

Agent: Tetlow King Planning

Paragraph 8 of Policy HC3 states that “shared ownership housing will be subject to staircasing restrictions in Designated Protected Areas in accordance with the relevant legislation, in order to safeguard new provision.” Where shared ownership properties are to be provided as intermediate housing on sites in DPAs - staircasing restrictions impact consumer appetites for the product and has a financial impact on housing associations as they have to be prepared to buy back the property. Shared ownership properties are expected to play a significant role in providing the affordable homes required in South Staffordshire.

As DPAs are found across the South Staffordshire area, we ask as a minimum that Policy HC3 recognises that there will be occasions where special circumstances apply that warrant the removal of the staircasing restriction provided that this request is justified with evidence. It is accepted that this will be done on a case-by-case basis as the evidence often relates to the site’s specific circumstances.

Object

Representation ID: 6000

Received: 31/05/2024

Respondent: West Midlands Housing Association Planning Consortium

Agent: Tetlow King Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy HC4 requires that all major developments wil be required to ensure that 100% of both market and affordable housing delivery meets the higher access standards Part M4(2) Category 2.

The WMHAPC queries the need for this blanket requirement given it is unclear if there is a need for 100% of new homes to be built to this accessibility standard.

The sole reference to the technical standards in the NPPF (2023) is on page 40, footnote 52 which states:
“Planning policies for housing should make use of the Government’s optional technical standards for accessible and adaptable housing, where this would address an identified need for such properties.” (Emphasis added)

Footnote 52 states that the accessibility technical standards are optional and should only be required where there is a demonstrated need. Without the appropriate evidence, a blanket application of accessibility standards may undermine the viability of development schemes across South Staffordshire, resulting in fewer affordable homes being delivered across the authority.

Object

Representation ID: 6001

Received: 31/05/2024

Respondent: West Midlands Housing Association Planning Consortium

Agent: Tetlow King Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy HC6 seeks to limit rural exception sites to areas adjoining key settlements only. This approach could significantly prevent the housing needs of many rural communities being met and is contradictory to both the PPG and NPPF (2023):
“As set out in the National Planning Policy Framework, rural exception sites can come forward in any rural location. In designated rural areas and areas designated as Green Belt, rural exception sites are the only sort of exception sites that can come forward.” (Emphasis added)

We therefore encourage the Council to allow rural exception sites adjoining any settlement where it can be shown that development would be sustainable.

Part b) of Policy HC6 specifies that an affordable housing need must be identified in the parish through a ‘robust housing need survey’. The WMHAPC does not agree with the evidence justification to rely solely on a housing needs survey. It is recommended that the Council rewords the policy to instead allow for the best available evidence to justify the need for Rural Exception Sites such as the use of local housing register data, local demographic data, temporary accommodation figures etc. Housing needs surveys can often be inaccurate and challenging to conduct, leading to potential delays in planning applications and in turn resulting in an overall reduction in the delivery of affordable housing. By using a broader range of evidenced bases, justification for Rural Exception schemes can be reflective of actual housing needs.

Support

Representation ID: 6002

Received: 31/05/2024

Respondent: West Midlands Housing Association Planning Consortium

Agent: Tetlow King Planning

The WMHAPC supports the Council’s decision to include a First Homes Exceptions sites policy. It is noted that the Council will consider a local eligibility criteria to be implemented for the delivery of First Homes and such criteria will be detailed within a forthcoming affordable housing SPD.

Object

Representation ID: 6003

Received: 31/05/2024

Respondent: West Midlands Housing Association Planning Consortium

Agent: Tetlow King Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Policy HC12 seeks to ensure that “all new residential developments must meet or exceed the Government’s Technical Housing Standards – National Described Space Standard (2015) or subsequent editions.”

In line with PPG, the WMHAPC welcomes the Council’s efforts to demonstrate a need, the viability and timing of the introduction of Nationally Described Space Standards (NDSS).

However, it is important to understand that the NDSS is not a building regulation. Whilst it understood that the Council has attempted to demonstrate a need to apply NDSS through an audit of the existing dwellings being delivered, where dwellings are not meeting NDSS, it does not necessarily mean that the dwellings being delivered are of poor quality. The application of NDSS is not essential for all dwellings to achieve these standards in order to provide good quality living. For affordable housing, in particular, there may be instances in which achieving NDSS is impractical and unnecessary.