Affordable Housing – Supplementary Planning Document Consultation Draft
Consultation statement
The following details accompany the consultation on the draft Affordable Housing Supplementary Planning Document (SPD), as required by the Town and Country Planning (Local Development) (England) Regulations 2004 (Regulation 17).
Pre production consultation
When consultation 28 September 2006 took place What was Housing Needs Assessment results consulted upon Who was Those marked with an asterix at Appendix 1 consulted How was Seminar which outlined results of Housing Needs consultation Assessment and how the Council was going to undertaken address the affordable housing issue. Summary of the The seminar was an opportunity to share the findings main issues raised of the Housing Needs Assessment prior to undertaking a pre-production consultation
When consultation Between 4 October 2006 and 15 November 2006 took place What was Pre-production consultation document consulted upon Who was See Appendix 1 consulted How was Letters and consultation document sent to those listed consultation at Appendix 1. In addition, the consultation document undertaken was placed on the District Council’s website. Summary of the A number of issues were raised which were main issues raised considered in preparing the draft Supplementary Planning Document. The comments received are summarised report at Appendix 2
APPENDIX 1 LIST OF PEOPLE CONSULTED
Government Office for the East Midlands Leicestershire County Council All Parish Council in North West Leicestershire Home Builders Federation* David Wilson Homes* Miller Homes* William Davis* Redrow Homes* JS Bloor Ltd* Housing Corporation* Westbury Homes Nottingham Ltd* Peveril Homes* Taylor Woodrow* Crest Homes Midlands Ltd* Persimmon Homes (Midlands)* Jelson Ltd* Henry Boot Developments* Cadeby Homes Ltd* Wimpey Homes East Midlands* Haslam Homes Ltd* Bryant developments* Barrett (East Midlands)* Clarke Homes Ltd* Radleigh Homes* Bellway Homes* NorthCountry Homes Group Ltd* Countrywide Homes Ltd* Webbir Homes* Linden Homes* East Midlands Housing Association* Freeth Cartwright LLP* Fairgrove Homes* Derwent Living* Nottingham Community Housing Association* Stamford Homes* Eastern Shires Housing Association Ltd* De Montfort Housing Society Ltd* FcH Housing and Care* Leicester Housing Association* Housing 21* Wallbrook Housing Association* Ball J A New Homes*
APPENDIX 2
AFFORDABLE HOUSING SUPPLEMENTARY PLANNING DOCUMENT – PRE-PRODUCTION CONSULTATION RESPONSES
Question 1 Do you accept the annual need of 305 dwellings identified in the Fordham report? If not why not? Would it be appropriate to identify how much of this need should be met through the planning system?
Long Whatton and Diseworth Parish Council
Whilst accepting the figure for 305 affordable dwellings per annum it would be unrealistic to expect more than about 10% of this through the planning process (new build).
Comment
The figure of 10% is noted, although no justification has been provided to support it.
Mr Wallis Hart
Requirement for 305 dwellings seems very high. The Local Plan correctly gives priority to sustainable locations. The need is to improve the quality of existing AH not to build anymore. More housing must await more local jobs and improved infrastructure and amenities.
Comment
The need to improve the standard of existing housing is beyond the remit of the SPD. The need to ensure that development is sustainable is acknowledged and the provision of affordable housing is a key issue in this respect.
Home Builders Federation
The AH target is based upon a Housing Needs Survey (HNS) whilst the Government is to place more emphasis on Housing Market Assessment (HMA). The HBF is concerned that until this work is complete the present policy is not founded on a robust and credible evidence base. Parish and Local HNS are a valuable tool in gauging housing needs, but their traditional bottom up approach has shortcomings such as the difficulty of accommodating inward migration compared to more recent needs/demand assessment methods. Therefore the HBF object to question 1.
Comment
The need to undertake a HMA is reflected in PPS3. This is an issue that is being addressed across the Leicester and Leicestershire Housing Market Area, but in the meantime the Fordham report is considered to be robust and accords with good practice advice.
William Davis Ltd
Queries the adequacy of the Housing Needs Assessment (HNA) as a robust assessment of housing need.
Comment
The HNA has followed good practice advice and is considered to provide a robust basis for the consideration of the need for affordable housing.
Jelson Ltd
It is acknowledged that the Fordham report appears to have been produced in accordance with guidance in the good practice guide. Jelson has some serious concerns regarding the way in which need has been calculated relating to the assessment of affordability (lending rates etc) and need identified through in- migration. It is considered appropriate to identify the level of affordable housing through the planning system in order to enable expectations to be managed and to encourage the pro-active exploration of alternative sources of AH provision.
Comment
The HNA has followed good practice advice and is considered to provide a robust basis for the consideration of the need for affordable housing.
Freeth Cartwright LLP on behalf of Barratt Homes East Midlands
There is clearly conflict between the identification of affordable housing need and of housing need generally as evidenced in paragraph 2.1.2 of the need identified for AH being 83% of the total Structure Plan annual requirement. Whilst paragraph 2.1.2 recognises it is unrealistic to expect the level of need identified by Fordham to be secured by the planning system, there would appear to be an error in either the Fordham or the Structure Plan methodology. Clearly the need for AH is in identification of need from concealed household which the structure plan figure should pick up. Barratt Homes view it is neither satisfactory, nor credible to suggest the two methodologies can come up with different figures for housing needs and still be compatible. As the structure plan has been publicly examined they suggest the Fordham approach appear to over-estimate the AH need.
Comment
The HNA has followed good practice advice and is considered to provide a robust basis for the consideration of the need for affordable housing. Furthermore, the methodology used in the Structure Plan to determine the level of housing does not take into account the issue of affordability but is instead an overall requirement for the provision of new housing having regard to a variety of factors such as growth in household numbers.
Ashby Woulds Town Council
The Town Council doesn’t agree the annual need of 305 dwellings identified and questions the validity of the report as there were only 2,422 replies and its unclear what % this would represent and there is no proof the responses were from a wide range of interested parties. The members would also challenge the figure stating immigrant need. NWLDC should not respond to only those people ‘wanting a property’. It would be appropriate to identify how much need should be met through the planning system on a much reduced number.
Comment
The HNA has followed good practice advice and is considered to provide a robust basis for the consideration of the need for affordable housing. The good practice guide advises that it is appropriate to have regard to need arising from in migration. Paragraph 2.1 of the Fordham report notes that the overall response rate was about 25%. In addition, the data obtained was weighted accordingly to ensure that bias was excluded from the final results.
Leicestershire County Council
The annual need identified is accepted and some of this should be met through the planning process.
Comment
Noted
Question 2 Should affordable housing in North West Leicestershire be that which falls within the limits identified by the Fordham report? If not how should affordable housing be defined?
Long Whatton and Diseworth Parish Council
The definition of affordable housing seems reasonable
Comment
Noted ______
Mr Wallis Hart
There is a need for housing for retired and part-time workers. Good quality affordable housing is required.
Comment
Noted
Home Builders Federation
The HBF consider that the definition of affordable housing should include low cost market housing. As the document uses the PPS3 definition it limits the scope to social rented and intermediate housing. As it does not recognise the role of low cost market housing as a source of affordable housing the HBF objects. Low cost market housing is crucial in enabling people in the District opportunity to access the property ladder without being forced into forms of social and intermediate housing. A low cost market house can provide an affordable option. Examples of schemes are already demonstrating. It is an attempt by the industry to respond to a clear housing need.
Comment
PPS3 is clear that low cost market housing does not constitute affordable housing, although discounted market housing does. It is considered that it would not be appropriate, therefore, to include low cost market housing in the definition of affordable housing.
William Davis Ltd
The guidance set out in Circular 6/98 must form the basis of any local definition of affordability which includes “…low cost market housing and subsidised housing (irrespective of tenure, ownership – whether exclusive or shared – or financial arrangements) that will be available to people who cannot afford to rent or buy houses generally available on the open market”. Local needs assessments should be legitimately used to highlight what the local parameters of affordability are - it is considered that the Fordham assessment should have incorporated further detailed income data to make it robust.
Comment
Circular 6/98 has now been superseded by PPS3 which includes a new definition of affordable housing. The HNA has followed good practice advice and is considered to provide a robust basis for the consideration of the need for affordable housing.
Jelson Ltd
This appears to confuse the definition of affordability (need) with the definition of affordable housing (what qualifies as affordable provision to meet the need). The latter should not simply be defined by cost or rental value but also by the mechanisms in place to assist affordability. Jelson would support the inclusion of low cost market housing as a significant contributor to AH provision. If the Fordham method is to be used it must be made clear that affordability should relate to the minimum price for the minimum sized property deemed necessary to reasonably accommodate the households need.
Comment
Comments noted. PPS3 specifically excludes low cost market housing from the definition of affordable housing.
Freeth Cartwright LLP on behalf of Barratt Homes East Midlands
Affordability is an issue for consideration at the local level given employment rates and annual salaries. Circular 6/98 and emerging PPS3 provide guidance on the definition of AH which should be followed. Also many mortgage lenders are now adapting their products to enable a higher multiple of household income to be used as a basis for obtaining a mortgage.
Comment
Comments noted.
Ashby Woulds Town Council
Yes if criteria are correct.
Comment
Noted
Leicestershire County Council
Support the definition of affordable housing.
Comment
Noted
Question 3 Should the threshold for seeking the provision of affordable housing be set at 15 or more dwellings as indicated in the Fordham report or would it be more appropriate to set a lower threshold? If so what should this threshold be and what reason would there be for setting a lower threshold? Should a range of thresholds be identified with different targets for each threshold? If so how should appropriate thresholds and targets be identified?
Long Whatton and Diseworth Parish Council
The threshold should be set at 15 or more dwellings but with a review in settlements of less than 3,000 population.
Comment
Noted
Mr Wallis Hart
A lower threshold would be acceptable where development land is adjoining existing areas of low cost housing and if it would encourage greater community interaction between different age groups.
Comments
The need to encourage a greater mix of houses and residents is noted and is consistent with Government guidance which stresses the need to create mixed and balanced communities.
Home Builders Federation
The policy approach makes no allowance for site suitability, viability or deliverability. It is unclear how such onerous proportions will help to readdress the current under provision of affordable housing. Increasing the burden upon developers will make sites more costly to develop, stifle development and increase strain on RSL’s partnering with developers.
Comment
The need to ensure that sites remain viable is acknowledged. However, the Government has made it clear that new housing developments will be expected to incorporate the provision of affordable housing.
William Davis Ltd
A threshold of 15 dwellings would only be appropriate if this becomes the new national threshold set in PPS3. Circular 6/98 establishes the principle that setting a lower threshold than advocated by national policy can only be done within the development plan process. There is no policy basis for this SPD to set a lower threshold than the current national threshold of 25 dwellings. It is accepted in principle that it may be justified to have a lower threshold in rural areas if it can be demonstrated that a threshold of 15 dwellings in unlikely to yield appropriate provision in smaller villages. Assuming the advice in circular 6/98 is carried forward in PPS3 any lowering of thresholds for these areas would have to be pursued through the new LDF rather that the SPD which can only supplement policies.
Comment
It is considered that in view of the high level of need identified that it could be appropriate to set a lower threshold than that set out in PPS3. The existing local plan policy does not set a threshold but merely refers to seeking affordable housing where there is a demonstrable need. The SPD and the Fordham report will establish what the demonstrable need is.
Jelson Ltd
Suggest that targets and thresholds should be set on a site by site basis, having regard to an overall districtwide target and the demonstrable need.
Comment
Noted
Freeth Cartwright LLP on behalf of Barratt Homes East Midlands
Setting a threshold for AH at 15 or more dwellings would spread the burden on private sector provision of AH through the planning system. Barratt Homes would generally support this approach and consider a threshold of 15 dwellings be applied across the board.
Comment
Noted
Ashby Would Town Council
A lower threshold than 15 dwellings should be set to ensure a mix of provision and these should be based upon perceived and actual needs as identified by local authorities.
Comment
Noted
Leicestershire County Council
Suggested that different thresholds are required and defined in relation to individual sites.
Comment
Noted Question 4 Is it appropriate for the SPD to set an affordable housing target? Should a target of 50% for the provision of affordable housing on appropriate schemes be set? If not, what would an appropriate target be? Would it be more appropriate to regard the figure of 50% as something to be worked towards with a lower figure (say 30%) being set initially with a stepped increased to say 40% after say two years and 50% after four years? What are the potential barriers to achieving any target and what can be done to overcome them? Do you agree that it would not be appropriate to set specific targets for individual sites? If not what factors should be taken into account in identifying any target?
Long Whatton and Diseworth Parish Council
Support setting a target for the district set initially at 30% and rising to 50% after two years.
Comment
Noted
Mr Wallis Hart
Support 50% target if it can be justified but will be too high for villages without any jobs. Considered that there are a number of barriers and that compulsory purchase could be an option to overcome barriers.
Comment
The need for new housing development (irrespective of tenure) to reflect the principles of sustainability is recognised in other Local Plan policies.
Home Builders Federation
There are sites where affordable housing would be inappropriate as it would impact upon site viability. Circular 6/98 identifies that in these instances such sites should not be required to provide affordable housing. Therefore it is inappropriate for all sites to provide 40% AH and this option should be amended to “where appropriate”. The higher percentage requirements of 40%, 50% and higher is unachievable and may constrain the delivery of housing further.
Comment
The need for site viability to not be detrimentally affected is acknowledged.
William Davis Ltd
The courts have accepted that adjustments of targets via supplementary planning guidance rather than by reviewing the Local Plan itself, is not unlawful. In any case the facts clearly dictate the degree to which any change can be deemed to be justified. Circular 6/98 advises one key determinant of any affordable housing policy rests upon the rigorous nature of the housing needs assessment.
Comments
Noted
Jelson Ltd
The SPD should include a district wide target with negotiations taking place on a site by site basis, having regard to local factors. Concerned that a 50% target is unrealistic and could impact upon site viability. A staggered approach would not address these concerns.
Comments
The need for site viability to not be detrimentally affected is acknowledged.
Freeth Cartwright LLP on behalf of Barratt Homes East Midlands
Barratt Homes view that it’s not possible for the SPD to depart from Local Plan policies in a material way. The current Local Plan policy makes it clear the provision of affordable housing will be negotiated on a site by site basis. Barratt Homes consider it not to be appropriate for the SPD to set a target but should rely upon Local Plan policy. If a target is to be set by the SPD, 50% would be unrealistic and will act as a moratorium on new housing development in the District. The proportion of affordable housing should depend on the viability of the proposed development and availability of public sector grant towards affordable housing.
Comments
The need for site viability to not be detrimentally affected is acknowledged. The Local Plan policy of negotiating on a site-by-site basis would not be changed by the SPD. The SPD together with the Fordham report will guide such negotiations.
Ashby Would Town Council
It is appropriate to set a target based on perceived and actual needs as identified by local authorities. Such targets should be flexible. Targets for individual sites would not be appropriate.
Comments
Noted
Leicestershire County Council
It would be appropriate to set a target but that it should be tailored to different threshold levels. A target of 30% is considered realistic with 50% as a target to work towards.
Comment
Noted
Question 5 Is it necessary for the SPD to address the issue of tenure? If so should the SPD specify, in general terms, the tenure of affordable housing that will be sought or should such provision be considered on a site-by-site basis? Should the SPD specifically identify the breakdown of the different types of intermediate housing that will be sought or should such provision be considered on a site-by-site basis? Should the SPD seek to link the tenure of properties sought to the size of any particular site?
Long Whatton and Diseworth Parish Council
The SPD should not address the issue of tenure.
Comment
Noted
Mr Wallis Hart
Issue of tenure best addressed by those with local knowledge.
Comment
Noted
Home Builders Federation
Circular 6/98 is clear that policy should not be expressed in favour of any form of tenure. Issue should be considered on a site-by-site basis.
Comments
Noted William Davis Ltd
Circular 6/98 is clear that policy should not be expressed in favour of any form of tenure. Issue should be considered on a site-by-site basis.
Comments
Noted
Jelson Ltd
Tenure should be considered on a site-by-site basis.
Comments
Noted
Freeth Cartwright LLP on behalf of Barratt Homes East Midlands
Tenure should be considered on a site-by-site basis. Generally accepted that on smaller sites an approach that seeks only social rented is acceptable.
Comments
Noted
Ashby Woulds Town Council
Tenure should be expressed if it is considered that that is the local need.
Comment
Noted
Leicestershire County Council
Tenure can be addressed in the SPD but should be considered on a site-by-site basis and may change through time.
Comment
Noted
Question 6 Should the SPD require that a specific mix of property types be required on all developments involving affordable? If not would some form of guidance be appropriate? Should a requirement be included for the provision of bungalows as part of new developments? What are the barriers to their being provided and how could these be overcome? Should the SPD include a specific requirement for Lifetime Housing? If so should this be for all developments and what should be the requirement?
Long Whatton and Diseworth Parish Council
The SPD should not be specific as to the mix of property types.
Comment
Noted
Mr Wallis Hart
Some form of guidance is considered to be needed.
Comment
Noted
Home Builders Federation
No specific requirement should be included for Lifetime Housing.
Comment
Noted
William Davis Ltd
This issue should be considered on a site-by-site basis and the SPD should not seek to specify property types.
Comment
Noted
Jelson Ltd
A specific mix of house types on all sites should not be required.
Comment
Noted
Freeth Cartwright LLP on behalf of Barratt Homes East Midlands
A specific mix of house types on all sites should not be required.
Comment
Noted
Ashby Woulds Town Council
Some specific guidance should be included in the SPD. Should not allow development which does not include bungalows, as there is a need for such properties. Lifetime housing should be a right for all.
Comments
The Fordham report noted a need for bungalows, but it would not reasonable to refuse to grant planning permission for the failure to provide bungalows. Each case would have to be considered on its merits.
Leicestershire County Council
The SPD should provide guidance on mix of property types and should specify mix on site by site basis. Support setting of requirement for homes to meet Lifetime Homes Standards. This is reflected in the draft East Midlands Regional Plan.
Comment
Whilst the SPD could identify property types for those sites allocated in the local plan, many sites are currently unidentified and so it would not be possible to identify the mix of property types.
Question 7 Should the SPD require that a specific mix of property sizes be required on all developments involving affordable? If not would some form of guidance be appropriate?
Long Whatton and Diseworth Parish Council
The SPD should not be specific as to the types of properties required.
Comment
Noted
Mr Wallis Hart
Guidance is essential if it is based on good data. Greatest need is probably for one or two bed single storey properties. Old farm buildings need to be conserved and reused.
Comment
The reuse of old buildings is covered by other Local Plan policies. There use for affordable housing is not ruled out but it may be a matter of financial viability.
William Davis Ltd
This issue should be considered on a site-by-site basis.
Comment
Noted
Jelson Ltd
A specific mix of house types should not be specified.
Comment
Noted
Freeth Cartwright LLP on behalf of Barratt Homes East Midlands
A specific mix of house types should not be specified.
Comment
Noted
Ashby Woulds Town Council
Guidance as to the mix would be required if local need is to be satisfied.
Comments
Noted
Question 8 Do you agree that off-site provision (which could include a financial contribution) should only be agreed in exceptional circumstances? Should the SPD seek to identify what these circumstances could be or would it be better to treat each case on its merits? Should the SPD require that a financial viability test be undertaken in respect of those sites where it is suggested that either the on-site provision of affordable housing or meeting the Council’s requirements would affect the financial viability of a proposed development? If so how could this be done? How can the level of financial contribution required in lieu of on-site provision be calculated? Should the SPD and/or any Section 106 Agreement specify how any monies are to be used?
Long Whatton and Diseworth Parish Council
Agreed that off site provision should only be agreed in exceptional circumstances. Considered that it may be difficult to set financial contributions, but that such contributions should be ring fenced.
Comment
Noted
Mr Wallis Hart
Off site provision could be used to ensure that affordable housing remains available to villages at 50% of the market value. Developers could contribute towards matters identified in the villages plan (e.g. recreation land).
Comment
Off site provision could only be considered in lieu of on site provision. The need for development to contribute towards a range of social and community facilities is beyond the remit of the SPD and is covered by other policies.
Home Builders Federation
The Council cannot expect an off site contribution where it is not necessary, nor the payment of commuted sums in lieu of provision. The suitability of a site to make a contribution towards AH should be a sequential process. If a site fails at any of the hurdles as being unsuitable then no contribution should be sought by the local planning authority. Circular 6/98 (paragraph 10 (i)) states some sites will be unsuitable for the provision of AH.
Comment
Off site provision would be likely to only be sought where on site provision could not be made, but where there is a demonstrable need for affordable housing.
William Davis Ltd
Circular 6/98 makes it clear that provision can be made for off-site, rather than on-site, contributions to AH where both parties agree it is appropriate. Planning practice has established that on-site is normally preferred and off-site contributions are only acceptable in exceptional circumstances. It would be useful if the Council gave guidance in the SPD as to the type of consideration that might render off-site provision to be appropriate. Full confidential financial appraisals should be provided where a developer claims that financial viability would be compromised by the provision of AH. The Council should seek advice on such appraisals. It is difficult for the SPD to specify a precise formula for off- site contributions as the calculation should reflect the split of tenure that would have been pursued on site. Other authorities have put forward a calculation on the basis of total cost indices, but this assumes that all units would be available for social rent and is therefore unreasonable. It should not matter how precisely any monies are used so long as they can be shown to meet local affordable housing needs.
Comments
Noted
Jelson Ltd
Jelson would encourage wider consideration to be given to off-site contributions. This may provide more flexibility in the location of AH provision.
Comment
Noted
Freeth Cartwright LLP on behalf of Barratt Homes East Midlands
Barrett Homes do not agree that off-site provision should only be agreed in exceptional circumstances. There will be many circumstances where off-site provision may be more appropriate than on-site provision. For example, there maybe a need to invest in the existing housing stock rather than for new affordable housing units. There may also be circumstances from a management point of view where on-site provision is inappropriate e.g. in smaller developments. Financial viability should only be used as a test in circumstances where it is argued that no/or reduced affordable housing should be provided due to abnormal development costs. It would be better to retain flexibility in how section 106 commuted sums are spent than to be too specific in the SPD.
Comments
It is noted that examples have been provided of possible circumstances in which off-site provision could be considered appropriate. However, these are likely to be the exception rather than the norm. The need for flexibility in how commuted sums are spent is noted.
Ashby Woulds Town Council
Agreed that off site provision should only be considered in exceptional circumstances and that any financial viability test should be undertaken by independent auditor.
Comments
Noted
Leicestershire County Council
Off site provision should only be considered in exceptional circumstances but that some guidance should be included in the SPD. The latter should include information on a financial availability test. The financial contribution could be linked to the target multiplied by the average house price index of the property types to be provided. The SPD should specify how monies will be used.
Comment
Noted
Question 9 Do you agree that where affordable housing is to be provided via a Registered Social Landlord that the land to be used should be provided at nil cost, fully serviced and free of contamination? If not, what alternatives are there that would still ensure that affordable housing can be secured? Should the approach to be taken be considered on a site for site basis rather than a one-off standard approach? Do you agree that where properties are to be provided by a developer that the SPD should set out any quality standards with which they will be expected to comply?
Long Whatton and Diseworth Parish Council
Support the approach taken in the Regional Housing Strategy and consider that Eco Homes standards should be applied.
Comment
Noted
Mr Wallis Hart
Support the idea of land being provided at nil value and free of contamination etc. The quality of houses is very important and all new houses should be eco- friendly.
Comment
Noted
Home Builders Federation
No need to set out additional quality standards.
Comment
Noted
William Davis Ltd
Reference is made to the advice in Circular 6/98. There is no planning policy support for the suggestion in the Regional Housing Strategy that land should be provided at nil cost, fully serviced and free of contamination. This matter should be considered on a site-by-site basis.
Comment
Circular 6/98 has now been superseded by the new PPS3. The Regional Housing Strategy forms part of the Integrated Regional Strategy, together with the Regional Spatial Strategy and Regional Economic Strategy. Thus whilst not a planning strategy in itself there is a clear link to the Regional Spatial Strategy and as such it provides a basis for the consideration of housing issues.
Jelson Ltd
The approach set out in the Regional Housing Strategy reflects normal practice. Standards for affordable housing should be agreed between individual housing associations and developers. Comment
Noted
Freeth Cartwright LLP on behalf of Barratt Homes East Midlands
The SPD should not specify the terms of arrangement between the developer and housing associations. The SPD should not cover quality standards as these are covered through other means.
Comment
Noted although it is considered that it may be appropriate for the SPD to provide an indication as to preference.
Ashby Woulds Town Council
Support the idea of land being provided at nil value and free of contamination etc. Also support the setting of quality standards.
Comment
Noted
Leicestershire County Council
Support the idea of land being provided at nil value and free of contamination etc. Also support the setting of quality standards.
Comment
Noted
Question10 Do you agree that all Section 106 Agreements dealing with affordable housing should be standardised? If so, do you agree that the SPD should set out the S106 Agreement to be used? Do you have any examples of Section106 Agreements which you think could provide the basis for a standard Section 106 for North West Leicestershire? If so please either provide a copy or identify where they can be found.
Long Whatton and Diseworth Parish Council
Understand the preference for standard 106 agreement but consider that there should be flexibility, particularly for smaller sites.
Comments
Noted
Mr Wallis Hart
Support providing such agreements make sure that the infra-structure can cope with additional development.
Comment
Noted
Home Builders Federation
Considered that format of S106 Agreements can be standardised, although the requirements for each agreement will vary.
Comment
Noted
William Davis Ltd
Suggested that it would be useful if the SPD included a model S106 Agreement but that this should not be presented as a blue print.
Comment
Noted
Jelson Ltd
Support standard S106 Agreement in principle but the actual potential for standardisation may be limited if a more site by site assessment is to be undertaken
Comment
Noted
Freeth Cartwright LLP on behalf of Barratt Homes East Midlands
Standardisation is supported provided that there is proper consultation with the industry.
Comment
Noted
Ashby Woulds Town Council Support the development of standard agreements.
Comment
Noted
Leicestershire County Council
Support the use of standard S106 Agreements but needs to be flexibility to consider all sites individually.
Comment
Noted
Question11 Do you agree that an Affordable Housing Protocol should be developed? Which organisations should be included in the Protocol? Should a Protocol be included as part of the SPD or as a separate document? Do you have any examples of other Protocols which you think could provide the basis for a protocol for North West Leicestershire? If so please either provide a copy or identify where they can be found.
Long Whatton and Diseworth Parish Council
Support development of a protocol.
Comment
Noted
Mr Wallis Hart
Support development of protocol.
Comment
Noted
William Davis Ltd
Protocol should be separate from SPD.
Comment
Noted
Jelson Ltd
Support development of protocol.
Comment
Noted
Freeth Cartwright LLP on behalf of Barratt Homes East Midlands
Protocol should not form part of SPD.
Comment
Noted
Ashby Woulds Town Council
Support development of protocol.
Comment
Noted
Leicestershire County Council
Support development of protocol and suggest that this should be included in the SPD
Comment
Noted
Question 12 Do agree that the Housing Market Assessment approach provides the best basis for the ongoing monitoring of housing market issues, including that of affordability?
Long Whatton and Diseworth Parish Council
Suggested that Housing Market Assessments may be a useful tool.
Comment
Noted
Mr Wallis Hart
Need to ensure that housing needs of community are identified so that local community will benefit.
Comment
Noted
Home Builders Federation
Encourage further engagement with the development industry in respect of the development of housing market assessments.
Comment
Noted
Jelson Ltd
Support the use of housing market approach.
Comment
Noted
Freeth Cartwright LLP on behalf of Barratt Homes East Midlands
Housing market assessment provides best model for monitoring housing market issues and will help to bring consistency
Comment
Noted
Ashby Woulds Town Council
Support the use of housing market assessment.
Comment
Noted
Leicestershire County Council
Support use of housing market assessment for monitoring.
Comment
Noted
General Comments
Radleigh Homes
A target of 50% would be onerous and flexibility is required. Low cost market housing should not be disregarded as part of an on site affordable housing provision alongside subsidised housing.
Comment
The definition of affordable housing in PPS3 specifically excludes low cost market housing.
Ashby de la Zouch Town Council
Town Council recognises that there is an urgent need for affordable housing and welcomes the preparation of an SPD, which should include appropriate targets and thresholds without jeopardising the financial viability of new development.
Comment
Noted
Breedon on the Hill Parish Council
A recent survey identified that there is no need in Breedon, Wilson or Tonge. In addition, there is insufficient infrastructure to support new development to accommodate people moving in to the area.
Comment
Noted