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 Suffolk 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.