Policy H2.1 - Affordable Housing 14th March 2005 Cyngor Sir CEREDIGION CEREDIGION County Council UDP – Public Local Inquiry Proof of Evidence Proof Number: LA No. 292 H2.1 Policy: Affordable Housing Ceredigion UDP Public Inquiry Proof No LA/292 Page 1 of 79 Policy H2.1 - Affordable Housing 14th March 2005 Ceredigion UDP Public Inquiry Proof No LA/292 Page 2 of 79 Policy H2.1 - Affordable Housing 14th March 2005 I. Contents I. Contents 3 II. Introduction 4 Policy 4 III. Summary of Representations 5 Deposit Objections and LPA Responses 5 Proposed Changes Objections and LPA Responses 12 Further Proposed Changes Objections and LPA Responses 13 IV. Conclusion 28 Further proposed changes 28 Appendix 1 32 List of Objections by Objectors 32 Appendix 2 40 Representations received to the UDP Deposit Version 40 Appendix 3 49 Representations received to the UDP Proposed Changes Document (February 2004) 49 Appendix 4 51 Representations received to the UDP Further Proposed Changes 1 (September 2004) 51 Ceredigion UDP Public Inquiry Proof No LA/292 Page 3 of 79 Policy H2.1 - Affordable Housing 14th March 2005 II. Introduction This is the proof of evidence of Llinos Thomas, representing Ceredigion County Council, whose details and qualifications are displayed in the Programme Office and at all Inquiry venues. This introduction explains how to use this document (proof). The proof covers all the objections to Housing – policy H2.1 Affordable Housing. Different objectors may have made the same or a very similar point regarding this policy, the LPA has tried to identify the issues arising out of the objections and then to address each issue, once, in this proof. Each issue is numbered and you can identify the issues which the LPA believe relate to your objection in Appendix 1. Each issue is supplemented by detailed reasons for that objection. Also, Appendix 1 lists any Proposed Change that may resolve the issues identified. A detailed summary of your objection is contained in Appendix 2 for objections to the Deposit Version and Appendix 3 for objections to the Proposed Changes documents (February 2004 and September 2004). Any further changes proposed by the LPA are noted at the end of the proof in the Conclusion and are included in a box(s). The further proposed changes are indicated by bold italic text for any additional wording and a double strikethrough for any further deletions. Some of the further proposed changes may not directly relate to any issues identified as part of the consultation exercises. Where relevant, these amendments are being proposed to correct typographical errors or to improve the grammar and or the clarity of text or to update references where needed. These are not in any way intended to alter the sense of the document. Such changes are included along with any further changes being proposed in response to objections received in the conclusion, where the whole policy together with any further proposed changes is reproduced. Policy The Policy shown is the Further Proposed Change 1 version (September 2004). The removal of bold text and the reinstatement of strike through text represent the original text of the policy in the Deposit version of the UDP. PC 550 H2.1 Affordable Housing 1. Where larger housing development (10 units in the main towns and 5 units elsewhere) is proposed (that is, residential development on a site, or part of a site that is capable of accommodating 10 units or more in the main towns and 5 units or more elsewhere), the Council will seek to negotiate the inclusion of an element of affordable housing, where there is a demonstrated need for affordable housing. Adequate planning conditions or obligations will be used to ensure that the benefits of such housing will be passed on to future occupiers. Ceredigion UDP Public Inquiry Proof No LA/292 Page 4 of 79 Policy H2.1 - Affordable Housing 14th March 2005 III. Summary of Representations A total of 25 representations were received to Policy H2.1, of which 4 supported the policy. A further 2 representations of objection were received to the amendment included in the Proposed Changes document (February 2004). Subsequently 48 Objections and 6 supports were received to the policy as set out in the ‘Further Proposed Changes 1 (September 2004)’ document (PC 550). Deposit Objections and LPA Responses 1. Issue 1: The policy approach is criticized because: 1.a. No valid local housing needs assessment (LHNA) has been undertaken. A LHNA should be undertaken and consulted upon. 1.a.1. Guidance permits LPAs to include policies for affordable housing within UDPs where it is known that need for affordable housing exists (PPW, March 2002, Para 9.2.15). In order to be able to implement such policies the need must be defined. Such need can be demonstrated by local housing needs assessments (LHNAs) or by other reliable and robust data sources such as housing registers of local authorities (LAs) and registered social landlords (RSLs). At the time of producing the Deposit Version the LPA had not undertaken a LHNA. However, several factors clearly demonstrated that there was a need which justified the inclusion of affordable housing policies. Therefore two policies were included within the Deposit Version aimed at increasing the supply of affordable housing across the County. 1.a.2. Since then a Countywide LHNA has been undertaken by the Council. Ceredigion UDP Public Inquiry Proof No LA/292 Page 5 of 79 Policy H2.1 - Affordable Housing 14th March 2005 1.a.3. The purpose of LHNAs is to provide an indication of housing needs which can then inform LA policies, including planning and housing policy. Such assessments provide statistically robust information regarding need and are produced in accordance with good practice issued nationally. It would be inappropriate to put the results of such assessments out to consultation – because the information given within the LHNA is factual and statistical and therefore there is nothing that can be consulted upon. 1.a.4. An up to date LHNAs will therefore aid in the effective implementation of this Policy and hence help secure a provision of affordable housing during the plan period. LHNAs will have an important role to play in identifying the level, tenure and type of affordable need within the County throughout the plan period. 1.a.5. The LHNA deals with the issue of affordability and acknowledges that the needs of those affected by that issue may be different. Neither the LHNA or the Policies adopt a "one size fits all" approach and the question of what is an affordable dwelling is in both documents seen in the context of the range of needs identified. 1.a.6. Further detail regarding the consideration given to the use of specific local needs assessments is set out in Topic Paper 3: Sustainable Communities – Housing and Social Sustainability (Section 8). 1.b. Building enough houses to meet the demands from those moving into the County in order to reduce house prices for local people is flawed because: (a) It will not provide for local affordable need, (b) It places the needs of local people secondary to those moving in to the County; and (c) This approach will negatively impact the Welsh language. Ceredigion UDP Public Inquiry Proof No LA/292 Page 6 of 79 Policy H2.1 - Affordable Housing 14th March 2005 1.b.1. The purpose of this policy is to ensure that sites capable of accommodating large scale residential development (defined as 10 or more units within the main towns and 5 or more units elsewhere) provide affordable housing as part of the overall development. The total number of units (both open market and affordable) capable of being accommodated within a particular settlement is controlled by the figure set out in the Appendix to Volume 2B and the relevant policy (H1.2 and H1.3). The approach advocated by this policy is not therefore one of meeting the demands of those moving into the County in order to reduce prices. 1.b.2. The emphasis of the policy is on meeting ‘local affordable need’ – therefore occupancy restrictions will be applied to dwellings permitted in accordance with these policies to ensure that they are occupied by those who are in need locally of ‘affordable housing’. The LPA have proposed a number of changes to the policy (PC 550) and to the glossary (PC 552), which supplements the policy, to clarify this approach. 1.b.3. Providing for the housing needs of a community is seen as the best way of sustaining the local community, which in turn will help sustain the Welsh language. Making sure that occupancy conditions are applied to ensure that affordable housing is directed to the needs of local people, will therefore help sustain communities and in turn the Welsh language. The relationship between the Welsh language and housing is explored in Topic Paper 3: Sustainable Communities – Housing and Social Sustainability (Section 7). 1.c. Providing social housing next to private housing is problematic. 1.c.1. This statement is not supported by evidence and the LPA do not accept this view as correct. The policy is considered to be in accordance with guidance in seeking to ensure the promotion of social integration and to avoid ghettos as Ceredigion UDP Public Inquiry Proof No LA/292 Page 7 of 79 Policy H2.1 - Affordable Housing 14th March 2005 has occurred in the past. National guidance seeks to ensure that, in providing for affordable housing, development incorporates a reasonable mix and balance of housing types and size to cater for a range of housing needs (PPW, March 2002, Para 9.1.2, 9.2.14 and 9.2.15).