Affordable Housing Draft Supplementary Planning Document

Consultation Statement May 2012

1 Introduction

A draft Supplementary Planning Document (SPD) has been prepared to assist with the implementation of policy DM18 of the Development Management Policies.

Preparation of the Affordable Housing Draft Supplementary Document has been undertaken in accordance with Waveney’s Statement of Community Involvement (2006).

A preliminary consultation of 6 weeks was carried out with selected stakeholders between the 26 th August 2011 and 7 th October 2011 to determine the potential content of the Affordable Housing SPD. The responses received to this consultation are detailed in the ‘Regulation 17 Consultation Statement’ which can be found on the Council’s website, together with the SPD and other supporting documents.

Following the preparation of the Affordable Housing Draft Supplementary Planning document a public consultation was undertaken. This offered members of the public an opportunity to comment. The consultation included Town and Parish Councils within the District, adjoining local authorities, statutory consultees, members of the Developers Forum 1 and people who have informed the Council they wish to be notified of such consultations.

Consultees were contacted by email, or where appropriate, by post and the public consultation was advertised in local newspapers on Friday 2 nd March 2011 and a press release issued (these are included at Appendix 1 and Appendix 2).

The consultation was open for six weeks between 2nd March 2012 and 13th April 2012. Statutory organisations, together with other bodies the Council considered necessary to consult were contacted (Appendix 3). In addition 2265 individuals on the LDF General Notification List were consulted.

There were 27 respondents to the consultation. A summary of responses to the consultation and how the Council has responded to the issues is provided below. The summary also includes proposed officer changes to the document that were considered appropriate.

1 The Developers Forum consists of local developers, housing providers and Council officers with events taking place quarterly to share information.

2

The Affordable Housing SPD has been subject to an Equality and Diversity Impact Analysis screening assessment. This concluded that no changes to the document were necessary.

The document has also been subject to a Strategic Environmental Assessment (SEA) scoping report and a Habitats Regulations Assessment (HRA) screening assessment. Both concluded that a full SEA and Appropriate Assessment were not needed and no changes to the document were necessary.

The document has been prepared and approved in conjunction with the Local Development Framework Working Group. This working group consists of thirteen Elected Members and Council Officers.

3 Summary of Comments and WDC Responses and Actions to the Affordable Housing Draft SPD

Paragraph/ Respondent Comment WDC Response WDC Page No Action

1. Introduction No further major development should The Supplementary Planning Document does not No change. Para 1.2 S Fryer be permitted as infrastructure cannot promote additional development in Waveney but will cope. ensure that development that does take place includes affordable housing as part of the scheme. Para 1.2 S Minns Phased approach should apply to larger The affordable housing percentage would initially be No change. developments where parts of the site set on the number of dwellings for the whole come forward for development. development proposal. Options will be available for renegotiation where viability issues are raised. Para 1.3 Officer Update the paragraph following The affordable housing policy DM18 built on the As detailed. publication of the NPPF. intentions of Planning Policy Statement 3 (PPS3) ‘Housing’ and Planning Circular 05/2005 to provide mixed and balanced communities. The housing policy HC1 in the Area Action Plan also follows this approach. PPS3 has been replaced by the National Planning Policy Framework (NPPF). The NPPF sets out the need to provide decent homes for the whole community. The provision of affordable housing in accordance with the affordable housing policies DM18 and HC1 will help to achieve the objectives of both PPS3 and its replacement the NPPF.

Para 1.4 Graham Decision to charge for pre-application The charging for pre-application advice is outside the No change. advice is a retrograde step and will scope of this consultation, however this comment will result in submission of applications be passed to the Head of Planning for consideration. without advice. 2. Purpose

4 Rather than seeking to create mixed The aim of the adopted policy is to create an No change. Para 2.1 Paul Johnson communities the Council should integrated community. The Council do not support consider housing in common property segregation. groups, i.e. housing for the elderly, or housing for families and not try to mix incompatible groups of people. 3. Waveney Policy and Strategy Para 3.3 Officer Update the paragraph following These policies reflect the advice formerly set out in As detailed. publication of the NPPF. PPS3 ‘Housing’, the National Planning Policy Framework and evidence from the Council’s Insert the word formerly and remove the Strategic Housing Market Assessment (2007). word ‘draft’ from before ‘National’ Para 3.5 S Fryer Travellers do not need housing. The Council has a strategy to meet the housing No change. needs of all, including the travelling community, who Who will be able to afford these homes? may for various reasons need permanent housing.

Affordable housing is not open market housing at a reduced price, but housing that is available for reduced rent or shared ownership with a housing provider. Para 3.6 S Fryer The number of empty homes should The Council has a strategy for bringing empty homes No change. more than cover people in need of back to use as affordable rented accommodation. affordable homes. However despite the number of empty properties, those actually available are insufficient to meet current need for affordable homes. Para 3.6 S Minns The Housing Market Assessment is out The Housing Market Assessment is due for review, No change. of date. however the underlying issues regarding affordable housing remain unchanged as highlighted in Para. 3.8. Para 3.7 S Fryer The number of affordable homes It is accepted that there will always be a shortfall in No change. needed each year will not be met. the amount of affordable homes that can be provided Where are people going to live? as part of new housing development. The policy

5 aims to achieve as many as possible. Para 3.8 Officer To take account of future changes to The HMA is due to be reviewed and updated in the As detailed. the way need could be assessed. near future. A more up to date picture of housing Additional sentence to end of need is available from the Homechoice Register paragraph. which in 2011 clearly indicated that affordable housing need continues to grow. In the future alternative methods for assessing the need for affordable housing need may be used. Para 3.8 Savills Once the revised HMA has been Acknowledge that the SPD will need to be reviewed No change. undertaken the SPD will need to be following an update of the HMA. However do not updated. Progressing with the SPD agree that the SPD should be delayed for this to take ahead of the updated HMA appears place. As stated in this paragraph the Housing inappropriate and the document is likely Register provides the most up to date information on to be rendered out of date very quickly. the type, mix and amount of affordable housing required. Para 3.9 Officer Amend last sentence to reflect status of The official national definition of affordable housing As detailed. NPPF. as set out in Annex 2 of the National Planning Policy Framework is: -

Para 3.9 Officer To take account of revised wording Amend to definition of affordable housing used in the As detailed. contained in the published NPPF. NPPF (Not written in full here see SPD).

Para 3.9 R O Vinton Housing needs of many people can be Paragraph 4.10 suggests that opportunities should No change. accommodated in blocks of apartments be taken to build energy efficient homes and this is with shared facilities. These properties also a requirement of adopted Development should be zero carbon and energy Management Policies. The detail suggested in the efficient. This would free up bigger response to the consultation is considered too houses to meet housing needs of specific for this SPD but will be a consideration in families. determining planning applications for new housing. Para 3.9 May be helpful to include definitions of This is the definition of affordable housing as stated No change. County older and disabled people alongside in the National Planning Policy Framework.

6 Council that of affordable housing. Not just Therefore this section is not an appropriate place to those over retirement age but make include definitions of older and disabled people. clear that aging is not linked to a Definitions of housing for older people and supported person’s age but to their health. housing are already included in the glossary. 4. Affordable Housing Requirements Para 4.0 S Fryer What about accessible homes? This Supplementary Planning Document is No change Table 1 specifically relating to adopted policies for the provision of 'affordable homes', within this definition, accessible homes are included in the mix of housing types and tenures required. See paragraph 4.6. Para 4.0 S Fryer Why is there an exception? The exceptions are explained at paragraph 4.2. The No change. Table 1 Council would not expect some types of housing development to contribute to or provide affordable housing because they are already have restricted occupancy. Para 4.0 A Harvey Threshold is too low to allow small In Waveney the majority of new housing sites are No change. Table 1 businesses to grow. small. Developers are aware of the requirement to Table 2 provide affordable housing, which is much needed in the District. The 5 threshold is supported by viability evidence that was used to develop the adopted policy and criteria within that policy allows individual developers to challenge the level required should viability issues arise.

Para 4.1 A Harvey Threshold of 5 dwellings is too low. In Waveney the majority of new housing sites are No change. Should be 20 with a sliding scale for the small and far below the suggested threshold of 20. Council’s target. Developers are aware of the requirement to provide affordable housing, which is much needed in the District. The 5 threshold is supported by viability evidence that was used to develop the adopted policy and criteria within that policy allows individual developers to challenge the level required should

7 viability issues arise. Para 4.1 Y Reeves Will never happen. Comments noted. No change. Para 4.1 B Jones Not all sites should be required to As a general rule a mix of housing types and tenures No change. accommodate affordable homes. will be expected to be included within all new Consideration needs to be given to the housing developments, although there is some social impacts of mixing different inbuilt flexibility to this approach. The ultimate aim is tenures. to ensure that no segregation occurs within the community. Para 4.1 Waveney & Means 80% to 65% of housing will be Comment noted. No change. Yare Housing unaffordable. Association Para 4.1 Waveney & Unambitious set of targets. Up to the end of December 2014 developments of 5 No change. Table 1 Yare Housing Development up to 20 units has to only and above will be required to provide affordable Association provide up to 1 affordable property, and housing or contribution toward affordable housing at in most cases 0. With a list of over 80 20%. This percentage will mean that a 20 unit individuals/couples/families waiting for scheme will have to provide 7 affordable units, not 1 affordable rented accommodation in as suggested. It is agreed that more affordable units alone these targets will do little are required, however the adopted policy percentage to help them. has been set using viability evidence to take into account site viability. Para 4.1 Waveney & Previous comment error, misread table Noted. No change. Table 1 Yare Housing as percentages not numbers. Association Para 4.1 S Minns The Council needs to make clear how it Paragraph 6.18 details how the contributions will be No change. intends to spend any financial allocated and the timescale that the Council has to contributions and in what time frame in spend the contributions. this DPD in the interests of transparency. Para 4.1 All developments should be required to Comments noted. The policy states that all sites of 5 No change. Town Council make a contribution (fixed or or more should contribute to the provision of percentage) to the development of affordable housing. This is adopted policy and affordable homes in Halesworth and supported by viability evidence. The Council could

8 ring fenced until needed. Even a single not justify a requirement for contributions from plot should contribute. smaller sites. Para 4.2 Officer Revise bullet point 4 to clarify that the • Dwellings that have limited occupation, such As detailed. exemption only applies to dwellings that as student accommodation, agricultural are not available for sale on the open workers accommodation, by planning market. conditions or legal agreement and not fully open market housing. Removal of conditions or legal agreements would trigger payment of appropriate affordable housing contributions. Para 4.2 Officer Add additional bullet point 5 to clarify • Age restricted accommodation by planning that age restricted accommodation is conditions or legal agreement, which is not only exempt from providing affordable available for purchase on the open market. housing where it is not for sale on the Removal of conditions or legal agreements open market. would trigger payment of appropriate affordable housing contributions; Para 4.3 Savills The Viability of development is being Affordable housing will be considered through No change. considered through the work on the Section 106 rather than CIL. Policy DM18 was based Community Infrastructure Levy. It on a viability study carried out in 2009 which looked seems inappropriate to move forward at various economic circumstances. Notwithstanding with advice on affordable housing this, there is flexibility within the policy to consider delivery in advance of the work on the viability and the potential for negotiation to take CIL. The SPD is based on work in 2009 account of other contributions including CIL and is so likely to be out of date, payments forms part of the guidance in the SPD. especially given the infrastructure requirements being suggested in the Lake Lothing AAP. We consider these matters needs to be looked at holistically through the CIL

Para 4.5 Officer Amend sentence to acknowledge that The commuted payments are currently based on As detailed. an alternative approach to setting open market plot values, although in future an commuted sum payments may be used alternative method may be used to calculate the

9 in future to align with the approach sums payable to align with the approach taken for taken for setting the Community the Community Infrastructure Levy. Infrastructure Levy figures: Para 4.5 Officer Amend sentence to reflect recent The figures for April 2012 are included in Appendix As detailed. update of information: A. These will be reviewed annually. The commuted sum will be calculated using the formula set out below. Para 4.5 A Harvey Threshold too low to allow small In Waveney the majority of new housing sites are No change. Figure 2 businesses to grow. Incentives to large small. Developers are aware of the requirement to developers only. provide affordable housing, which is much needed in the District. The 5 threshold is supported by viability evidence that was used to develop the adopted policy and criteria within that policy allows individual developers to challenge the level required should viability issues arise. Larger housing developments are also required to contribute towards other infrastructure costs including open space, schools, roads etc. as well as affordable housing. Sometimes the contributions will require prioritisation depending on the needs of a particular area and the viability of the scheme, which may result in reduced affordable housing. Para 4.6 P Webster There is a need for one bedroom The aim of the adopted policy is to provide affordable No change. properties because of the way housing homes to meet an identified need and this will benefits are paid to single people. include smaller properties where required. Para 4.6 Suffolk For clarity the form of housing that will The Housing Market Assessment provides general No change. County be required should be based on the guidance, however the type of housing needs to be Council Housing Market Assessment as well as determined when a development proposal is the housing register as referenced in submitted. The housing register will always be the Policy DM17. most up to date information available. Strongly support the reference to supported housing and housing for

10 vulnerable people in this paragraph. Para 4.6 Support 90%/10% ratio with the Support noted. No change. and greatest need for rented housing. Society Para 4.7 – Suffolk Do not oppose any of the guidance Agree to amend para 4.10 to include after the third Amend as 4.10 County although as the document refers to sentence: - detailed. Council affordable housing for elderly and vulnerable people it is suggested that a The location of housing for the elderly, disabled and description of preferred locations for Lifetime Homes should be considered in relation to supported housing could be included accessibility to public transport, shops and other i.e. in locations where key facilities such services and facilities. as public transport, community facilities, Agree to amend para 4.10 to include after the third retail, healthcare etc are accessible. sentence: - If a proportion of units built to Lifetime Homes standard are included as part of the development, a location close to services and facilities should be considered. A useful guide to older people, the built environment and the wider context of housing the ageing population is the Governments recent ‘Lifetime Neighbourhoods’ paper. Para 4.9 S Fryer Higher density will mean smaller Density of new housing development will be No change. gardens, people like gardens. dependent on the character of the area and the type of new housing proposed. A mix of types and sizes will be encouraged and determined through the planning application process using adopted policies.

11 Para 4.9 Natural Note the minimum density standards for Amend third sentence for clarity: - Amend as particular areas with lower densities to Higher densities will be sought in the most detailed. respect landscape character, however accessible locations such as and the important to consider every scheme on Market Towns, in accordance with the Core Strategy its merits. spatial strategy (Policy CS01) although lower or higher densities may be acceptable to take into The text should elaborate on the ‘most account existing local character and the physical accessible locations such as Lowestoft’ environment of the site and its surroundings. to provide a clear settlement hierarchy as Core Strategy Policy CS01. Para 4.10 Homes and Seek the Council’s statement on Local Amend paragraph 4.10 to make reference to the Amend as Communities Standards Framework and an Design and Quality Standards and Strategy detailed. Agency acknowledgement of the awareness of documents. quality and standards for affordable housing as set out in HCA guidance. Policy DM02 of the Development Management Policies DPD sets out criteria for achieving ‘good’ design that applies to all new development including affordable housing. The Homes and Communities Agency expect new affordable homes to meet core standards for internal and external environments and sustainability. These standards are set out in their Design and Quality Strategy and Standards publications. Design and layout of new affordable housing should be considered in conjunction with all policies and guidance contained in these documents and policies that relate to individual site allocations and the Area Action Plan area. Para 4.10 Natural Suggest cross reference to Policy CS02 Comment noted. DM02 is already referred to and No change. England of the Core Strategy to ensure clear covers in more detail the issues of sustainable consistent guidance in relation to development and green space/open space. The SPD sustainable development. Further text is expected to be read in conjunction with the DM should be included to set out guidance policies and CS policies not in isolation.

12 for incorporating green infrastructure. Para 4.10 S Fryer All new housing should have enough The appropriate level of car parking for each No change. parking. development will be determined using adopted policies, through the planning application process. Para 4.10 Halesworth Agree that design and layout Comments noted. Policy DM02 in the Development Amend as Town Council considerations important and would Management Policies DPD makes clear that local detailed. emphasise the need for flexibility in character is important. Reference is made to this design to suit local situations, safety policy and need to use all relevant policies to requirements and future enlargement of determine applications in the paragraph and it is not properties. considered necessary to repeat them here. Will amend paragraph 4.9 to include clearer reference to local character and the physical environment of the site and its surroundings.

Amend third paragraph 4.9 to read: -

Higher densities will be sought in the most accessible locations such as Lowestoft and the Market Towns, in accordance with the Core Strategy spatial strategy (Policy CS01) although lower or higher densities may be acceptable to take into account of existing local character and the physical environment of the site and its surroundings. 5. Delivery of Affordable Housing Para 5.2 Halesworth It is essential that this parallel Comment noted. No change. Town Council development of affordable and market housing is achieved as stated in para. 5.2 Para 5.3 Halesworth Strict measures must be in place to Comment noted. However, in some cases tenants No change. Town Council ensure that the long term availability of have the right to buy their properties outright, which affordable housing is secured as stated is beyond the scope of planning legislation to control. in para 5.3 and that this principle cannot

13 be overridden by future sale of property. Para 5.4 Officer Revise text in brackets to take account Affordable housing must be occupied by a qualifying As detailed. that the way housing allocations are person allocated through Gateway to Homechoice made could change in the future: (or other such register or eligibility criteria that may….)

Para 5.4 and Halesworth Consider that allocation of properties in Comment noted. The allocation and letting of No change. 5.5 Town Council Halesworth should be by a local body properties is not under the control of the local and that homes are provided for local planning authority and therefore cannot influence the people or people who work in allocation criteria of the housing team. The only Halesworth. A letting policy that meets exception to this is where housing is constructed as the needs of Halesworth rather than an exception site and occupancy clauses can be Waveney will ensure support for included in the section 106 agreement. affordable housing projects by the community. Para 5.5 S Fryer Single people need affordable housing. The aim of the policy is to provide affordable housing No change. for people who are unable to afford market housing. Para 5.6, Halesworth Overriding principle that affordable Comments noted. Agree that affordable housing No change. 5.7,5.8 Town Council housing must remain available in should be retained where possible as affordable perpetuity. Assurance on this point is accommodation, however in towns the right of crucial to gaining community support. individuals to ultimately acquire properties to full Definitions in these paragraphs need private ownership has to be exercised. Affordable further consideration. housing cannot therefore be maintained in perpetuity as desired. Funds raised from sales are used to fund new affordable homes. 6. Financial Matters Para 6.0 Homes and Welcome the recognition of financial Support welcome. No change. Communities matters in delivering affordable housing. Agency Para. 6.0 Halesworth Section dealing with ways in which Comments noted. The Council needs a flexible No change. Town Council affordable housing allocations can be approach to dealing with viability to ensure that all varied for the benefit of the council or development contributes to providing affordable

14 developer. Recent discussions suggest housing even if this is less than the policy requires. that landowners will accept less money Open book accounting and strict time frames for for land if it can be developed. The delivery of new development will ensure that at the viability argument seems to provide any time of development the amount of affordable developer an opportunity to negotiate housing in relation to the viability of the site is amount of affordable housing appropriate and acceptable. downwards. Rigorous examination of reasons for variation is essential and must be open to public scrutiny. Para 6.1 Officer The Section 106 Developers Guide to Remove last sentence of paragraph ‘Currently in As detailed. Infrastructure Contributions in Suffolk’ draft form but should be adopted for use in early has now been adopted for Council use. 2012’. Para 6.1 S Fryer Vital that developers contribute to Developers are already required to make No change. schools, doctors etc. contributions for other infrastructure including schools. Para 6.1 S Minns Financial viability is not fixed and The Council recognises that markets play a role in No change. changes with time. Market forces play a financial viability and expect that developers will big part. It is naive to think that it doesn't consider requirements for affordable housing as part change overtime particularly with land of the purchase price. The Council also recognises banks. The Audit Commission produced that from purchase to development viability could a good guide on this issue which the change, hence the considerations given to Open Council has a copy of. This section Book accounting, renegotiation of Sec 106 does not reflect economics. agreements etc. The Council’s approach takes account of changing markets to the benefit of the developer, which will help prevent land banking and ensure an appropriate affordable housing contribution is made. Para 6.2 Savills The Viability of development is being Affordable housing will be considered through No change considered through the work on the Section 106 rather than CIL. Policy DM18 was based Community Infrastructure Levy. It on a viability study carried out in 2009 which looked seems inappropriate to move forward at various economic circumstances. Notwithstanding with advice on affordable housing this, there is flexibility within the policy to consider

15 delivery in advance of the work on the viability and the potential for negotiation to take CIL. The SPD is based on work in account of other contributions including CIL 2009 and is so likely to be out of date, payments forms part of the guidance in the SPD. especially given the infrastructure requirements being suggested in the Lake Lothing AAP. We consider these matters needs to be looked at holistically through the CIL

Para 6.5 A Harvey No incentives for small businesses. The adopted policy contains criteria to allow flexibility No change. Figure 5 Benefits large developers only. in the amount of contributions individual developers have to provide if viability issues are raised. Larger development proposals are required to contribute to other infrastructure costs such as open space, schools and roads etc. The table simplifies the negotiation process. Para 6.5 R O Vinton Housing should be affordable to run not Adopted Development Management policies will be No change. just to build. Energy efficient. used to determine applications for new housing and energy efficiency is a consideration. However, this level of detail is too specific for inclusion in the SPD. Paragraph 4.10 recognises the need for innovative design including maximising energy efficiency, but leaves the detail to other policies. Para 6.6 S Minns Support. Noted. No change. Para 6.10 Suffolk County Could improve paragraph to include Other obligations are referred to in para 6.1 and No change. Council reference to all other planning again under 6.7. Para 6.10 moves the discussion obligations a developer could be forward and relates specifically to affordable housing expected to pay not just affordable provision and consideration of reduced contributions. housing. Para 6.12 Officer Insert additional word in first sentence ‘Where a developer demonstrates to the satisfaction As detailed. to make clear that negotiations are for of the Council that a proposed scheme is not proposed schemes not completed currently viable…’

16 development: Para 6.19 Officer Add additional wording to end of Other options for the delivery of affordable housing As detailed. sentence for clarity: where off-site contributions are available could include purchase of existing empty homes or other properties for sale on the open market including the potential to buy back former social housing, for affordable rent. Para 6.27 Officer Remove ‘arising from the variation’ from In doing so the developer will be expected to agree As detailed. the end of the sentence to remove to a development or phase completion date and ambiguity from this sentence and for further viability assessment once the development clarity. has been sold or let, with provisions for the Council to recover any overage profit above 20% Gross Development Value not exceeding the total value of the original obligations. 7. Rural Exception Sites Para 7.0 Halesworth Exceptions sites are required to be Comments noted. The council will take a flexible site No change. Town 100% affordable housing, however by site approach for proposals for affordable housing Council consideration should be given to the on exception sites, however as a general rule these viability of this requirement to make the will only be permitted for 100% affordable housing. prospect more attractive to landowners. Para 7.2 Natural Suggest that DM22 is amended to Comment noted. This is adopted policy DM22 of the No change. England include ‘sensitive to the local landscape Development Management Policies DPD and should character and be within walking be used in conjunction with the spatial strategy. distance …’ Unsustainable locations Outside the scope of this consultation. promote reliance on the car. Para 7.2 Suffolk Acre Do not agree with the rural exception Affordable housing in rural locations will always have No change. policy effectively removing the to be justified by a housing needs survey. Policy opportunity to develop affordable DM22 housing development in the countryside says housing schemes only in villages with that ‘wherever possible’ it should be well related to services. It is important to maintain an existing settlement, therefore the policy is already flexibility to respond to housing need flexible in not stating development ‘must’ be located enabling people to continue to choose in a serviced village.

17 to live in villages they have a local connection to. Review of housing need should be flexible to respond to demand accordingly. Para 7.3 Suffolk Acre Suggest that need is always determined In some cases housing need can be determined No change. through both the housing register and through the housing register without the need for an housing needs survey. additional housing needs survey. Para 7.6 Suffolk Acre Suggest including that planning Considering need in the determination of the No change. applications are also determined by the planning application is covered by para 7.3 and it is level of support received from considered unnecessary to repeat this in para 7.6. parishioners which will be gathered as evidence in the housing needs survey. Para 7.6 Natural Support para 7.6 which asserts that in Comment noted. This SPD is to be used in No change. England determining applications for sites in the conjunction with all the policies in the Development countryside, a key consideration will be Management DPD. Do not consider it necessary to the impact on the village character and highlight particular policies or repeat guidance. rural landscape. Suggest cross reference to DM27. Para 7.10 G Burns Support. Affordable housing should be Comments noted. No change. located where there are adequate employment opportunities for a growing population. Para 7.10 Southwold Support that Southwold and Reydon is Support noted. No change. and Reydon included as a Rural Exception Market Society Town Para 7.12 Officer As an exception site the housing will be Affordable housing delivered as an exception site will As detailed. provided to meet an identified need in initially be allocated to people who have a strong the area, however, this need may shift local and/or work connection. Subsequent and could provide housing for people in occupancy could include people with a housing need surrounding parishes or even district from surrounding parishes or District wide where wide. Referring to ‘family’ connection is there is a local connection. inconsistent with homelessness

18 legislation.

Insert ‘initially’ in first sentence, remove ‘family’ after ‘local’ from sentence and add additional sentence: Para 7.12 Southwold Support aim for affordability in Support noted. No change. and Reydon perpetuity. Society Appendices Appendix A Officer Revise commuted sum payments in Commuted Payments April 2012 As detailed. table to reflect April 2012 figures and Figures for 2012 are set out below. To be reviewed update associated text. annually.

*See Appendix 4

Consideration of values based on all the completed sales evidence available to the District Valuation Officer in the Waveney District Council area since June 2011 for plots and infill developments.

Appendix D Officer Add note. As detailed. * Note that this list is not intended to be exhaustive but is representative of the Housing Associations operating in the Waveney Area.

Appendix E Southwold Suggest there should be a model Comment noted. Although Appendix E is not a Amend as and Reydon clause to cover perpetuity. comprehensive list agree to add exception clause. detailed. Society However to retain perpetuity on an exception site, Renegotiation of Section 106 the Mortgagee in Possession clause would not be Agreements should only be in included in the agreement. exceptional circumstances. Add to Appendix E: -

19

Affordable Housing Exception Sites

a)That all of the units will be used in perpetuity for the purposes of providing affordable housing.

b) Where any units are to be made available for shared ownership, the occupiers shall not be permitted to staircase above 80% of the value of such units at the date upon which the right to staircase is exercised.

c) Where any units are to be made available for shared equity, a discount of at least 25% below market value shall be retained. Bibliography Bibliography Officer Add reference to NPPF. National Planning Policy Framework (DCLG, 2012) Amend as http://www.communities.gov.uk/publications/planning detailed. andbuilding/draftframework Habitat Regulations Screening Report Habitat Natural Satisfied that the SPD will not materially Comments noted. No change. Regulations England change Development Management Screening Policy DM18. As noted DM18 has Report already been screened for likely significant effects on Natura 2000 sites and the SPD simply provides additional guidance. No significant effects on Natura 2000 sites are predicted. Strategic Environmental Assessment Screening Opinion Strategic Natural Satisfied that the SPD will not give rise Comment noted. No change. Environmental England to any significant effects that have not Assessment been assessed as part of a

20 Screening Sustainability Appraisal for a higher Opinion level planning document. General Comments General Natural Overall support for the SPD. Support and comments noted. The general approach No change. Comment England to development in Waveney will be expected to be in There are a number of places in the accordance with the settlement strategy set out in SPD where the text could be the Core Strategy and policies contained in the strengthened to ensure the natural Development Management Policies DPD. Do not environment is appropriately consider it necessary to repeat this in the SPD which safeguarded and residents of affordable is guidance for the aforementioned documents. housing schemes have sufficient The SPD should not be writing new policy. Higher access to green infrastructure, the open level documents will be reviewed and amended countryside, local services and public where considered appropriate. transport.

The NPPF has now superseded planning policy statements and guidance. The SPD should seek to bridge gaps between national and local policy. General Barton Wider concerns and objections to the Comments noted. The SPD is a general guide to the No change. Comment Wilmore on LPA’s infrastructure proposals for the implementation of policy DM18 therefore detailed Behalf of AAP area and potentially negative guidance for specific sites is not included. Section Sanyo impact on viability of the Sustainable 6.0 on Financial Matters clearly sets out that the Urban Neighbourhood. Request that the Council will look at sites on an individual basis and LPA prioritise its entire list of major where viability issues are raised infrastructure infrastructure items requiring part or requirements and affordable housing requirements whole payment by will be looked at in the wider context and a flexible landowners/developers. The LPA approach will be taken regarding prioritisation. should provide clear indication in its emerging Development Brief and Affordable Housing SPD as to whether

21 the provision of affordable housing is given a higher priority than other infrastructure items. General Southwold Concern that affordable housing is Comments noted. Affordable housing that is No change. Comment and Reydon allowed to become market housing or to provided in a town or village that is not classed as an Society be occupied by a non- qualifying exception site can become full market housing. person. Occupation of the dwellings is controlled by the Housing Authority. General Anglian No comments to make. Comment noted. No change. Comment Water General Suffolk Helpful document. SCC’s interests Comments noted. It is not considered necessary to No change. Comment County primarily focussed on statutory role as repeat NPPF policy in the SPD. Council provider of social housing, though also have an interest in ensuring housing is affordable. Pleased to see earlier comments have been incorporated into the document. Waveney may wish to consider if the document meets the requirement in para. 54 of the National Planning Policy Framework relating to consideration of allowing market housing to support the delivery of affordable housing in rural areas. General S Minns Premature to the publication of the Do not agree. The SPD will be reviewed in light of No change. Comment National Planning Policy Framework the NPPF as necessary and amended if and where and consultation should be suspended. required. General Highways No comment to make. Noted. No change. Comment Agency General D Beamish Smaller 1 and 2 bedroom properties Comments noted. Adopted policy sets out a No change. Comment should be provided for single parents, requirement for this type of accommodation. couples and single local people not

22 currently priority on the housing list. General E Currell Support the need for more affordable Comments noted. Most new development will also No change. Comment housing, providing all infrastructure and have to contribute towards other infrastructure. other essential services are in place, including new bridge, better education, training and jobs. Solar energy should be prioritized above wind power. General C Blois Due to water shortages in the area, no Comments noted. For the most part affordable No change. Comment more houses should be built. homes will be provided on sites that have already been allocated for development, taking into account the views of water providers. General B Carroll Do not see why developers have to Comment noted. Without a policy requiring No change. Comment make a financial contribution for developers to fund/provide affordable housing it is affordable housing. This is only added unlikely that any would be delivered. No market to the cost of other houses and the housing is truly affordable. The local authority has a purchaser pays. duty to provide homes for all. Why are homes provided for travellers and why are they to be mixed with other housing?

General E Mutimer Affordable housing is necessary, Comments noted. The SPD will provide clear No change. Comment however concerned that decisions on guidance for developers and the LPA for the housing applications do not reflect determination of applications to ensure housing is wishes of community. located in the right place and to meet local needs for affordable housing. General P Warnes Believe there is a need to make a Comments noted. Agree that a balance needs to be No change. Comment balance between affordable and other made between providing housing and employment housing but that employment is more opportunities and this is the Council’s aim. important, then affordable housing wouldn’t be needed. More of the area should be used for industry/commercial. General Homes and The document clearly explains the Support welcomed. No change.

23 Comment Communitie council’s objectives for affordable s Agency housing for the district and the AAP area. Support the principle of the document and welcome the opportunity to engage with WDC to assist with the delivery plan. General Halesworth Halesworth is a community that is not in Comments noted. The purpose of the SPD is to No change. Comment Town balance, with a greater proportion of deliver affordable housing as a result of new housing Council elderly and fewer younger people than development and to implement adopted policies, not the national and local average. The to allocate additional sites. planning system has consistently failed to meet targets for affordable housing. High prices make it difficult for young people to stay or move into the town. Loss of secondary education and poor sports facilities are further problems. Only 2 allocated sites that will only provide 31 affordable units up to 2025. Allocated sites will not achieve the purpose of this document. General Halesworth Document must enshrine the flexibility Comments noted. The SPD is guidance for the No change. Comment Town of ‘localism’. This will render these implementation of the affordable housing policy as Council schemes viable, with community adopted. The Localism Agenda provides additional support include higher percentages of mechanisms for delivery of new development which affordable housing. the Council supports but do not consider necessary to incorporate into the SPD.

24 25 Appendix 1: Public Notice Displayed in Lowestoft Journal, Beccles and Journal and Waveney Advertiser 2/03/2012

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Appendix 2: Press Release

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Appendix 3: Organisations Consulted

Statutory Bodies

Anglian Water The Home Office BNP Paribas Real Estate (on behalf of The National Federation of Gypsy Liaison Royal Mail) Groups British Telecom The Planning Inspectorate Broads Authority The Southwold & Reydon Society Department for Business, Innovation & T-Mobile (UK) Limited Skills Department for Culture, Media and Sport UK Power Networks Department for Education Vodafone Group plc Department for Transport Waveney Practice Based Commissioning Department for Work and Pensions Department of Constitutional Affairs Development Agency East of England Local Government Association East of England Public Health and Social Care Directorate East of England Strategic Health Authority English Heritage Environment Agency Essex & Suffolk Water plc Great Yarmouth Borough Council Highways Agency Homes and Communities Agency Hutchinson 3G James Paget Healthcare Trust District Council Ministry of Defence N Power Renewables National Express East Anglia National Grid National Grid Property Holdings Ltd Natural England Natural England Network Rail Network Rail NHS East of England NHS Great Yarmouth & Waveney Norfolk County Council O2 (UK) Ltd Office of Government Commerce Orange South Norfolk District Council District Council (Architectural Liaison Officer) Suffolk County Council

28 Local Bodies / Other Organisations

Active Waveney Sports Partnership RSPB East of England Agency for the Legal Deposit Libraries SAVO Ancient Monuments Society Sport England Associated British Ports St Edmundsbury Borough Council Council Suffolk Acre Beccles & Bungay Journal Suffolk Amphibian & Reptile Group British Library Suffolk Coast and Heaths AONB Unit Bungay Chamber of Trade Suffolk Fire & Rescue Service (Lowestoft) Bungay Society Suffolk Fire & Rescue Service (Planning & Review) Church Commissioners Suffolk Preservation Society Churches Together Suffolk Wildlife Trust Crown Estate Office Sustrans CTC Right to Ride Network (Waveney) The Beach Radio DIAL Lowestoft and Waveney The Beccles Society East Anglian Ambulance NHS Trust The Broads Society Fields in Trust (FIT) The Bungay Society First Eastern Counties The Colville Gospel Trust Flagship Housing Group The Community Forum Forest Heath District Council The Gypsy Council Forestry Commission The Halesworth & Blyth Valley Partnership Halesworth Playing Field Association The National Trust, East of England Regional Office Health & Safety Executive The Theatres Trust HM Prison Service Therese Coffey MP for Suffolk Coastal Home Builders Federation Upper Waveney Valley Countryside Project Ian Real Waveney Cycling Campaign Internal Drainage Board Waveney Tourism Forum Borough Council Woodland Trust Job Centre Plus Job Centre Plus Cambridgeshire & Suffolk Sports & Social Centre Business Association Learning Skills Council for Suffolk Legal Deposit Office Lowestoft & Waveney Chamber of Commerce Lowestoft Civic Society Lowestoft College Lowestoft Harbour Maritime Businesses Group Lowestoft Journal Mr Brandon Lewis, MP for Great Yarmouth Mr Peter Aldous, MP for Waveney Naji Darwish NATS Safeguarding Northern Area Education Office Positive Changes 4 Young People

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Town and Parish Councils

Alburgh Parish Council Kessingland Parish Council Ashby, and Parish Lound Parish Council Council Barnby Parish Council Mendham Parish Council Barsham & Parish Council Metfield Parish Council Beccles Town Council Parish Council Belton with Browston Parish Council Mrs M Rogers, Parish Council Clerk Benacre Parish Meeting Parish Council & Flixton Parish Council Parish Council & Parish Council Oulton Parish Council Parish Council Parish Meeting Bramfield and Parish Council Reydon Parish Council Brampton with Parish Council & Weston Parish Council Broome Parish Council Parish Council Bungay Town Council Rushmere Parish Meeting Burgh St Peter with Wheatacre Parish , , Willingham & Council Parish Council Town Council Clerk Southwold Town Council , Linstead Parva & Linstead Parish Council Magna Parish Council Cookley & Walpole Parish Councils Parish Meeting Corton Parish Council Three Saints Parish Council Parish Meeting Parish Council Denton Parish Council with Henham Parish Council Ditchingham Parish Council with Mells Hamlet Parish Council Earsham Parish Council Parish Council Ellingham Parish Council Parish Council Flixton, SE St Cross & St Margaret Parish Wortwell Parish Council Council Fritton with St Olaves Parish Council Wrentham Parish Council , & South Cove Parish Council Geldeston Parish Council Gillingham Parish Council Parish Council Haddiscoe Parish Council Halesworth Town Council Halesworth Town Council with Hulver Street Parish Council Holton Parish Council Holton Parish Council Parish Council Hopton-on-Sea Parish Council Parish Council Parish Meeting Parish Council Parish Meeting

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Town, Parish and Ward Councillors

Beccles North Normanston Beccles South Oulton Blything Bungay Carlton Southwold and Reydon Carlton Colville St Margaret’s Gunton and Corton The Saints Halesworth Wainford Harbour Whitton Kessingland Worlingham Kirkley Wrentham Lothingland

Developers Forum and Local Housing Associations

AAK Design Associates Ltd M. Dixon (Agent) Arnolds Chartered Surveyors M S Oakes Ltd Ashgate Construction Limited Oakwood Construction ASD Architecture Oldman Homes Ltd Badger Building East Anglia Ltd OWL Partnership Orwell Housing Association Orbit Group B. Cutts (Agent) P. England (Agent) Barsham Securities Ltd Paul Robinson Partnership Brian Haward Chartered Architect P. Tungate (Agent) Brian Sabberton Ltd Persimmon Homes (Anglia) Ltd Broadland Housing Trust Chaplin Farrant Ltd PDA Architectural Chediston Homes Ltd P J Spillings Circle Anglia Pure Architecture Ltd Cotman Housing Association Cripps Developments Ltd Purple Property Ltd Duncan and Son Ltd Riddle Construction Ltd Flagship Housing RRS Saffron Housing Trust Ltd Garret Design Sprake and Tyrrell Ltd Gilbert Builders Taylor Properties Graham Ling Architectural Consultant Technicus Consulting Heritage Construction Tredwell Developments Hopkins Homes Ltd Utting Construction Howard Group New Homes Land Division Vaughan Keal Associates J. Bennet (Architect) WAS Ltd. J. Kelly (Agent) Warnes and Son Ltd J. Putman (Agent) Wellington Construction Ltd K Holdings Ltd (Anglia)

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Appendix 4: Officer Change to Appendix A Table

Reydon Southwold Lowestoft Rest of District 1 bed flat £44,000 £107,500 £24,000 £34,000 2 bed flat £54,000 £117,500 £29,000 £39,000 2 bed plot £68,000 £145,000 £38,000 £57,000 3 bed plot £83,000 £180,000 £47,000 £67,000 4 bed plot £93,000 £200,000 £57,000 £75,000

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