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Gwrthwynebu

Preferred Options

ID sylw: 50811

Derbyniwyd: 02/08/2012

Ymatebydd: Bluemark Projects

Asiant : Pegasus Group

Crynodeb o'r Gynrychiolaeth:

The Preferred Options document acknowledges that it is not possible for the overall level of housing growth proposed to meet the arising requirements for affordable housing, as the annual arising need for affordable housing is 698,which is in excess of the proposed annual requirement of 600 dwellings per annum. In addition, as the windfall element is likely to consist of smaller sites they are unlikely to contribute towards affordable housing delivery exacerbating the shortfall. The housing requirement is therefore not addressing the need for all types of housing as required by paragraph 159 of the NPPF. In addition, the title to this subsection is incorrect as the Local Plan does not meet the need for affordable housing.

As identified in the accompanying Housing Evidence Review Paper, it is advised that a higher housing requirement is appropriate taking into consideration relevant factors. Such a requirement, in the order of 17,500, is in excess of the total arising affordable housing need (12,564 dwellings based on an average of 698 dwellings per annum over 18 years) and would assist to deliver a greater amount of affordable housing.

There is concern that if the overall arising housing needs (for both market and affordable) are not catered for, the poorest in society will be further marginalised (i.e. remaining as concealed/ shared households, when accommodation within the private rented market is potentially beyond their means) and could result in such groups moving out of the District to locations where dwellings that are affordable are available. Such an outcome would have a detrimental effect on society both socially and economically. For example, family/ social networks are broken, which potentially places a greater burden on local services and it could lead to a mismatch between available local labour and jobs, which could result in increased commuting.

In terms of the proposed policy approach, which requires 40% affordable housing on developments of 10 or more dwellings in the urban area and 5 or more dwellings in the rural area, it is important that the policy approach remains flexible as this blanket level of affordable housing will not be achievable on all development sites.

It is acknowledged that an Affordable Housing Viability Assessment has been prepared in order to test varying percentages for the affordable housing policy. Such assessments are based upon key variables to test the impact of different levels of affordable housing provision. The key variables set out within the report are: market position, location, value area, density, tenure split and developer profit. There are a number of other factors which have not been taken into account such as site remediation and provision of infrastructure. These can have a huge bearing over whether a scheme is viable or not.

Assumptions in relation to each of the key variables are used to determine viability. There is concern that given no two sites are the same general assumptions in respect of the cost and revenues of development may be inaccurate. It is therefore essential that the Council allows a flexible approach to delivering affordable housing in order to ensure that development is not prevented from coming forward as a consequence of a rigid policy approach. Similar sentiments are echoed in the Ministerial Statement of March 2012 and NPPF, both of which seek to facilitate housing delivery and ensure that Local Plans do not impose unnecessary burdens that could threaten the viability of development.