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.