Non Site Allocation Representations Report.pdf

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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 <strong>Site</strong> 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 ├é┬ú400k per acre, or ├é┬ú1m 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 ├é┬ú7,500 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 ├é┬ú8,000 per plot would represent the average cost. However, for the changes to Part L, the approximate costs agreed by WAG are roughly an extra ├é┬ú20,000 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
SECTION FOUR - SPATIAL POLICIES, KEY DIAGRAMS AND SUPPORTING DEVELOPMENT CONTROL POLICIES 4.2.18 Affordable Housing Target in Conwy, 4.2.18.3 Rep No Name 22549 Awdurdod Parc Cenedlaethol Eryri / Snowdonia National Park Authority (Tim Polisi a Chynlluniau Strategol Eryri Policy and Strategic Plans Team) [1663] Summary Man sylwadau: People Type Tud 130 - 4.2.18.3 Cywiro'r frawddeg olaf - Nid ydi Awdurdod Parc Cenedlaethol yn Awdurdod Tai ac felly nid yw'n gyfrifol am gyhoeddi Strategaeth Eiddo Gwag. Mae Awdurdod Tai Gwynedd a Chonwy wedi cyhoeddi Strategaethau Eiddo Gwag ar gyfer ardal y Parc Cenedlaethol. Change Sought: Cywiro'r frawddeg olaf - Nid ydi Awdurdod Parc Cenedlaethol yn Awdurdod Tai ac felly nid yw'n gyfrifol am gyhoeddi Strategaeth Eiddo Gwag. Mae Awdurdod Tai Gwynedd a Chonwy wedi cyhoeddi Strategaethau Eiddo Gwag ar gyfer ardal y Parc Cenedlaethol. 1 Object 335
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CYNLLUN DATBLYGU LLEOL CONWY I’W
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Policy CTH/3 Buildings and Structur
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LDP - Deposit Plan INTRODUCTION 1.2
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INTRODUCTION 1.5 Rep No Name 1434 L
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INTRODUCTION 1.19 Tests of Soundnes
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INTRODUCTION 1.24 Policy Framework
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INTRODUCTION 1.26 Plan Area context
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INTRODUCTION 1.32 Rep No Name Peopl
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VISION AND OBJECTIVES 2.1 A Vision
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VISION AND OBJECTIVES 2.6 Rep No Na
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VISION AND OBJECTIVES 2.8 Rep No Na
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THE SPATIAL STRATEGY AND KEY DIAGRA
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IMPLEMENTATION AND MONITORING FRAME
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SECTION FIVE - IMPLEMENTATION AND M
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