BASE HEADER

As the three scenarios are not yet attributed evidence-based target figures for matters such as housing delivery we consider it appropriate to comment that any future targets should be based on a full, robust evidence base. Ambitious targets for growth should be derived from this evidence base, taking into account historic undersupply of affordable housing and consideration of the viability of development throughout the district. We recommend that the highest possible housing target be set, enabling higher volumes of affordable housing to be brought forward, with the aim of delivering sufficient high quality housing to meet need. As the 2007 SHMA indicates need for 1,019 affordable dwellings per annum, the suggested figure given at Option 3 for 800dpa is considered too low to meet even affordable housing need. The evidence should be brought up to date before any single option is taken forward, taking into account the backlog of housing need and projected growth across the Plan period.

Suggests the following points are included in future drafts of the Core Strategy:
1. Affordable housing should be given sufficient weight and status within the core strategy.
2. Links should be made between the core strategy and housing strategy.
3. There should be strong links between the core strategy and other local authority strategies, such as the community strategy community care plan, economic development strategy and transport plans, ensuring that affordable housing is given due prominence within a corporate approach.
4. Credible district wide and sub-district wide affordable housing targets should be set over the plan period.
5. Ensuring that site size thresholds for negotiating affordable housing from private developers are properly derived in the light of the local housing and land markets including viability issues. We would anticipate that the Council will consider and articulate the circumstances across the District which justify proposed site size thresholds as per relevant government guidance.
6. A local definition of affordable housing should be set encompassing intermediate, affordable rent and social rented housing, taking full account of local relationships between house prices and incomes.
7. A realistic approach towards brownfield sites to ensure that a sequential approach is not so rigidly applied so as to impede the delivery of affordable housing.
8. There should be proper targeting of individual sites for affordable housing, including identifying sites for 100% affordable housing sites throughout the district.
9. There should be a reasonable amount of flexibility regarding design and development control standards, densities etc. to assist in achieving affordable housing.
10. The provision of affordable housing is recognised per se as both a positive material planning consideration and a planning benefit.
11. A rural exceptions policy should genuinely enable schemes to be developed in the correct locations both within and on the edge of rural settlements and make allowance for cross-subsidy where viability
is challenging.
12. The provision of affordable housing should be viewed within the context of achieving balanced communities and within the wider social exclusion and housing plus agendas.
13. Recognition should be given to the advantages of working with HARPs and a suitably flexible approach should be adopted towards S106 agreements.
14. Indication of the Council's intention to adopt CIL alongside planning obligations contributions and the exemption of affordable housing developments from this, in line with Government advice.
15. Policies should be included that maximise the reuse of empty properties for affordable housing.
16. Housing demand factors should be taken into account. There is likely to be a continuing demand for family housing and this should be considered.
17. Regular monitoring of the progress in meeting affordable housing needs should take place. PPS3 discusses the requirements of Annual Monitoring Reports and sets out what the LPA should carry out on an annual basis. By referring to such indicators, the success or otherwise of the policies can be measurable against clearly defined targets, allowing measurements to be taken on an annual basis.