Non Site Allocation Representations Report.pdf

SECTION FOUR - SPATIAL POLICIES, KEY DIAGRAMS AND SUPPORTING DEVELOPMENT CONTROL POLICIES
4.2.13 Affordable Housing for Local Need, Policy HOU/2 AFFORDABLE HOUSING FOR LOCAL NEED
Rep No Name
22390 Denbighshire County Council - Planning Policy (Ms Angela Loftus) [5171]
Summary The amendments to policy HOU/2 (Affordable housing for local need), in respect of thresholds and quota, are noted and supported.
People Type
22376 Mrs Searl [5170]
1 Support
Summary As per comments made in relation to Policies DP/4 and DP/5 we support the acknowledgement within the policy that provision can be reduced/negotiated
subject to development viability. It is noted that his is further supported as section 4.2.23.
22336 Welsh Assembly Government (Mr Mark Newey) [2176]
1 Object
Summary The delivery of affordable housing remains a key Assembly Government priority, as well as being a priority issue for the local authority. Consequently, the
Welsh Assembly Government seeks to ensure that all avenues have been explored to maximise the delivery of affordable housing, both in terms of the scale
of overall housing provision and sites.
Paragraph 4.2.14.1 of the plan identifies an affordable housing need of 8460 dwellings over the plan period, whilst the plan makes provision for 2200.
A primary concern is how the heavy reliance on windfall housing sites in the plan will deliver the affordable housing target.
Change Sought: Further explanation and clarity on how commuted sums will assist delivery, as well as evidence to demonstrate the financial levels sought, would
be beneficial.
The plan would benefit from further clarity on how affordable housing delivery could be enhanced through the additional provision (assuming the 30%
provision sought in policy HOU/2 is applied) of approximately 330 units from the 1100 contingency sites, particularly reflecting that affordable housing is a
priority issue for the plan.
14136 Home Builders Federation Ltd (Mr Richard Price) [1934]
1 Object
Summary We have a number of concerns with Policy HOU/2:
Part 1 - Specific concerns with the policy and assumptions
The theory of Section 106 and Land Valuations
Paragraph 2.14 - Good Practice Approach
Relationship of the AHVA to the Policy
Other Section 106 Costs
Sustainable housing and the costs associated with provision.
4.2.21 Local Connection Occupancy Cascade
Paragraph 4.2.22.3
Policy HOU/2 parts 3 and 4
Section 2
The additional requirements of development
Exercise to determine the impact of the realities of development on viability and deliverability.
Changes to Building Regulations
The requirement for fire sprinklers in all new homes
Site constraints and abnormals
Cumulative impact of regulation and other requirements
Change Sought: The affordable housing viability assessment should recognise that residential land will have an inherent value of its own and it is not suitable to link the value
of residential land to the value of existing uses to artificially set what the Council believes the residential land value should be.
The Affordable Housing Viability Assessment should be undertaken with a figure of £400k per acre, or £1m per hectare as the benchmark for
assessing the viability of residential development.
1
Support
The requirements of the Planning Obligations SPG should be given greater consideration in terms of the 'other planning obligations' figure within the AHVA, to
ensure the £7,500 figure assumed is sound and robust.
The AHVA should be redone and should include more up to date and robust figures on the costs of achieving Code for Sustainable Homes Level 4. The UK
Zero Carbon Hub should be consulted in this respect.
The AHVA should make an allowance for achieving the WAG's sustainable buildings target and the imminent increase to Part L of building regulations. In this
context for Code for Sustainable Homes Level 3 plus 6 credits - the consensus from our member is that £8,000 per plot would represent the average
cost. However, for the changes to Part L, the approximate costs agreed by WAG are roughly an extra £20,000 per plot above current build costs. This is
explained in more detail in the next section.
The suggestions that, the market will improve to counteract the costs of achieving improved environmental standards on developments and increasing the
environmental standards of homes will increase the sale price are wholly unfounded and cannot be relied upon within the assessment. As such, these
assumptions should be removed.
Paragraph 4.2.21 should be removed
The requirements of paragraph 4.2.22.3 should either be contained within the policy or removed
Parts 3 and 4 of Policy HOU/2 are statements of intent and should be removed.
In light of the evidence above, we do not believe the affordable housing Policy HOU/2 should be adopted in its current form. We believe it will have a
detrimental impact on development viability and hence the delivery of housing in general in Conwy. The evidence base for the policy should be revisited and
the issues within our representation above should be taken into account when undertaking the affordable housing viability assessment. The policy should then
be re-drafted when this work has been completed.
14447 Beech Developments (NW) Ltd (Mr Mike Roberts) [1966]
1 Object
Summary We do not object to the general principle of providing 30% affordable housing in relation to housing sites where it is viable to do so (in accordance with
National Policy). However, we do object to the suggestion that affordable housing contributions should come from all sites, whatever their size.
Proper analsis and justification should be given for a more appropriate threshold which will not discourage development in the way that the present proposal
will.
Change Sought: Proper analsis and justification should be given for a more appropriate threshold for affordable housing which will not discourage development in the way that
the present proposal will.
19169 Redrow (Ms Victoria Murray) [4513]
Summary The housing land allocations in the Abergele, Towyn and Kinmel Bay area are insufficient to meeet the expressed need for affordable housing.
Change Sought: Additional housing land should be allocated in this area.
1
Object
334