Publication Plan November 2022

Object

Representation ID: 4750

Received: 22/12/2022

Respondent: Tetlow King Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

At present DS1's stance on rural exception sites would frustrate affordable housing delivery instead of maximising delivery. The Council should allow for a limited number of market homes on rural exception sites within the Green Belt to help ensure the viability of affordable-led schemes and to ensure local rural housing needs are being met.

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: 4752

Received: 22/12/2022

Respondent: Tetlow King Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

In its current form part b) of Policy H6 offers no flexibility in how applicants can demonstrate and justify the need for a rural exception site. The PPG is clear that the use of a housing needs survey is not the sole means of identifying local needs. The Council should take a more flexible approach by allowing applicants to justify local needs using other forms of "appropriate evidence" such as the housing register and government data returns.

The viability of rural exception sites will differ on a site by site basis, as such setting a limit on market homes which can be delivered on such sites without demonstrating 'proportionate evidence' will likely limit the number of affordable homes delivered.

Object

Representation ID: 4753

Received: 22/12/2022

Respondent: Tetlow King Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Setting a limit on the number of market homes that can come forward on First Homes exception sites without demonstrating proportionate evidence will likely limit the number of affordable homes being delivered.

Comment

Representation ID: 4754

Received: 22/12/2022

Respondent: Tetlow King Planning

NDSS are not a building regulation and where dwellings are not meeting NDSS it does not necessarily mean that the dwellings being delivered are of poor quality. For affordable housing in particular there may be instances where achieving NDSS is impractical and unnecessary.