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Affordable Housing Supplementary Planning Document

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Affordable Housing Supplementary Planning Document Affordable Housing Supplementary Planning Document Consultation Statement 1 1. Introduction 1.1 The Town and Country Planning (Local Planning) (England) Regulations 2012 require a local planning authority to consult the public and stakeholders before adopting a Supplementary Planning Document (SPD). 1.2 This statement sets out details of the consultation which has informed the preparation of the SPD. 1.3 The purpose of the Affordable Housing SPD is to aid the effective implementation of the Housing policies in the District Plan (Chapter 14) in particular HOU3 which relates to Affordable Housing. Once adopted the SPD will be a material consideration in planning decisions. 2. Town and Country Planning Regulations 2.1 The SPD is produced in accordance with the Town and Country Planning (Local Planning) (England) Regulations 2012. The relevant regulations relating to the consultation process are explained below. Regulation 12: Regulation 12(a) requires the Council to produce a consultation statement before adoption of the SPD, this must set out who was consulted, a summary of the issues raised, and how these issues were incorporated in to the SPD. Regulation 12(b) requires the Council to publish the documents for a minimum 4 week consultation, specify the date when responses should be received and identify the address to which responses should be sent. Regulation 35: Regulation 12 states that when seeking representations on an SPD, documents must be available in accordance with Regulation 35. This requires the Council to make documents available by taking the following steps; 2 o Make the document available at the principal office and other places within the area that the Council considers appropriate; o Publish the document on the Council’s website. 3. Statement of Community Involvement (SCI) 3.1 The Council’s SCI was adopted in 2019 and explains how the council will involve the community in plan-making and in the consideration of planning applications. The SCI sets out that SPD’s should be subject to a four-week public consultation. 4. Consultation undertaken 4.1 The SPD was approved for public consultation at Executive on 8th October 2019. Formal public consultation was undertaken on the draft SPD for a period of four weeks from 30 January to 27 February 2020. 4.2 Consultation was undertaken in accordance with the Town and Country Planning (Local Planning) (England) Regulations 2012 and the Statement of Community Involvement. Consultees were consulted by email; or post where no email address was provided. A list of consultees is provided in Appendix A. The SPD consultation was also advertised via the Council’s website and social media. 4.2 The SPD and Strategic Environmental Assessment (SEA) Screening Statement were made available on the Council’s website: https://www.eastherts.gov.uk/affordablehousingspd. This included Information about how to submit representations. Paper copies were available for public inspection during normal office hours at the East Herts Council Offices in Hertford and Bishop’s Stortford, town council offices and in libraries across the district. 3 4.3 Representations could be made via the Council's consultation portal http://consult.eastherts.gov.uk/portal; emailed to [email protected] or sent to; Planning Policy, East Herts Council, Wallfields, Pegs Lane, Hertford, SG13 8EQ. 5. Issues raised during the consultation 5.1 During the consultation, over 60 representations were received, made by 29 respondents. Of the representations, the majority either objected to elements within the SPD or were seeking amendments. There were some comments of support of the document in general, and a number of supportive comments for specific elements within the document. 5.2 The main issues raised through the consultation include: Requests for further flexibility in guidance to assist developers Requests for additional information to be provided within certain sections. Stronger policies and commitments from the Council on Affordable Housing 5.3 A summary of the consultation responses is set out in the schedule below. This table outlines the comments by topic, the Council’s response to these issues and any consequential changes to the SPD. If text is to be deleted from the draft SPD it is shown struck through. If new text is to be inserted it is shown in red. 4 Rep No. Topic/Section/para. Support Issue Officer Response Proposed modification Number or Object General Comments East Herts - Aware that some planning 1 – D. Royle Noted. This SPD provides No amendment in response to this applications negotiate the policy Affordable Housing guidance on how to issue. requirement of affordable housing implement affordable SPD downwards. The SPD should detail the housing rather than the enforcement and monitoring of the enforcement of it. Section 4 level of affordable housing agreed of this SPD deals with how upon and guaranteeing good quality. affordable housing is secured through the S106 process. East Herts Object Essential that the Council holds 4 – East Herts Noted. Council’s approach to No amendment in response to this developers to commitments and Affordable Housing viability is set out in section 5 issue. Green Party doesn’t allow viability assessments to of this SPD. SPD be used by developers to escape obligations. Paragraphs 3.4.2 and 3.5.1 Hope that the use of commuted sums demonstrate that these or alternative site provision will be alternatives are only available minimal. in exceptional circumstances. The charge for affordable housing for key workers should be based on The NPPF defines affordable individual incomes not the needs of housing and in order to the housing market – BBC evidence comply rents are based on shows that towns aren’t affordable for local market rents. key workers. Also important is the dwellings are energy efficient to avoid fuel poverty for those on low incomes. 5 East Herts Object This document means that there will 5 – D. Desmulie The tenure mix has changed No amendment in response to this be fewer houses at affordable rent in Affordable Housing due to the updated National issue. East Herts despite need being the Planning Policy Framework, SPD greatest. The Council has chosen to this is explained in section 2 opt out of house building and of the SPD. Affordable rent management despite money available still remains the Council’s to build at social rents. House prices priority and this is set out in and rents are not affordable in this section 3.2. District to a section of the population particularly those who can’t work or are in low paid jobs. New developments are advertised as gated another symbol of a divided society. East Herts Object Essential we build more affordable 16 – G. Gaunt The aim of the SPD is to No amendment in response to this housing and secondary schools but Affordable Housing provide further information issue. when builders run out of money and and guidance on the policies SPD they ask to change their plans and are in the District Plan that relate excused. to affordable housing in Objects to the Gresley Park particular – it does not relate development in the District Plan due to specific sites. to traffic and green belt matters. East Herts Support No comment – SPD does not relate to 17 – Natural Noted No amendment in response to this the impact on the natural Affordable Housing issue. England environment. SPD East Herts Support Consultation very clear and easy to 18 – C. Jones Noted No amendment in response to this understand. No further comments to Affordable Housing issue. make. SPD East Herts Support Draft SPD is thorough, evidence-based 19 – G. Edkins Support noted and No amendment in response to this and professional. Hightown supports Affordable Housing welcomed. issue. (Hightown the proposed predominance of rent in SPD the planning obligation mix, choice of Housing shared ownership as preferred form 6 Association) of home ownership, and also firm stance on commuted sums and on stipulations that restrict abuse of Vacant Building Credit. Social rent forms part of the We regret that EHDC does not require definition of affordable an element of Social Rent as part of housing in the SPD and the the affordable mix like other Council would encourage it authorities (Welwyn Hatfield, Watford, where possible. Three Rivers) East Herts - Most long-term funds for housing 22 – G. Edkins Issue noted – this section No amendment in response to this associations come from commercial Affordable Housing does not set out the specific issue. (Hightown) lenders, who need the assurance that wording of clauses but only SPD in the (almost unprecedented) event what clauses are likely to be that we go broke, their last resort - included in the S106 having first offered the homes to the agreement. LA or other HA’s – would be to sell the loan security, in this case the Specific wording can be affordable homes. Could the wording agreed through the S106 at 4.0.2 be amended to give suitable process. assurance in the S106 exemption clause. Suggest adding the words; “subject to appropriate safeguards for funders after continued use of affordable dwellings in perpetuity.” East Herts - The Property Planning Team on behalf 27 – Noted No amendment in response to this of Hertfordshire County Council as a Affordable Housing issue. Hertfordshire landowner has no comments to make SPD on this consultation. County Council Property Planning Team East Herts - No specific comments to make at this 28 – Historic Noted No amendment in response to this stage. issue. 7 England Affordable Housing SPD East Herts Object 1. The imposition of a requirement for 35 – Noted No amendment in response to this perpetual affordability will inevitably Affordable Housing issue. Hertingfordbury impact on development SPD viability. Mention is made of viability Parish Council assessment in some circumstances and there is also reference to commuted sums under certain conditions.
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