Cefnogi

ID sylw: 65176

Derbyniwyd: 24/06/2014

Ymatebydd: Sundial Group Ltd

Asiant : Mr Marcus Bates

The Affordable Housing mix needs to respond to the evolving requirements of Registered Providers and allow for flexibility to assist with delivery.

Gwrthwynebu

ID sylw: 65244

Derbyniwyd: 27/06/2014

Ymatebydd: Deeley Group Ltd

Asiant : Delta Planning

Cydymffurfio â’r gyfraith? Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Nac Ydi

Deeley Group object to part (b) of policy H2 regarding Affordable Housing. It is considered that the threshold of sites of 5 or more dwellings or 0.17 hectares is too low and disregards the costs of developing small sites over larger one's. This policy will have an adverse effect on the ability of developers to bring forward small sites which can provide a valuable contribution to housing provision across the district. If a higher threshold is introduced this will encourage more sites to come forward and more affordable housing provision to be provided in the District.

Gwrthwynebu

ID sylw: 65291

Derbyniwyd: 25/06/2014

Ymatebydd: A C Lloyd Homes Ltd

Asiant : Delta Planning

Cydymffurfio â’r gyfraith? Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Nac Ydi

A C Lloyd Homes object to part (b) of policy H2 regarding Affordable Housing. It is considered that the threshold of sites of 5 or more dwellings or 0.17 hectares is too low and disregards the costs of developing small sites over larger one's. This policy will have an adverse effect on the ability of developers to bring forward small sites which can provide a valuable contribution to housing provision across the district. If a higher threshold is introduced this will encourage more sites to come forward.

Gwrthwynebu

ID sylw: 65477

Derbyniwyd: 27/06/2014

Ymatebydd: King Henry VIII Endowed Trust (Warwick)

Asiant : AMEC

Cydymffurfio â’r gyfraith? Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Ydi

We broadly support the 40% affordable housing target to meet local needs. However the policy wording may not allow sufficient flexibility to take into account viability or site specific factors. Not in all cases will 40% affordable housing be viable.

Viability is referred to in the second paragraph of the policy; however this appears to relate solely to the form of provision, its location on site and the means of delivery.

Whilst we acknowledge that the SHMA is an important source of housing needs information, applying this policy rigidly may not necessarily assist in meeting local housing needs. The SHMA is only a 'snapshot' in time and will not always reflect the dynamic nature of the housing market. We would emphasise the need for flexibility to ensure that a wider range of factors can also be taken into account in determining the overall housing mix. These may include site specific factors relating to the existing local area or site specific viability factors.

There is a very real danger that pockets of relative social exclusion may result and indeed that the mix prescribed for the urban extension may prejudice its compatibility and full social integration into the main core community to which it relates. Such dangers are obviously exacerbated in circumstances in which relatively high percentages of affordable housing and, within this, relatively high proportions of social rented tenures are being inflexibly required, with no scope for reasonable negotiation.

Gwrthwynebu

ID sylw: 65526

Derbyniwyd: 27/06/2014

Ymatebydd: Sharba Homes Group

Asiant : PJPlanning

Cydymffurfio â’r gyfraith? Nac Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Nac Ydi

We seek clarification on this policy over whether Growth Villages, as defined in policy H1 fall under point A or point B, as the policies map does not identify rural areas explicitly.

Cefnogi

ID sylw: 65527

Derbyniwyd: 27/06/2014

Ymatebydd: Keith Wellsted

Needed

Gwrthwynebu

ID sylw: 65884

Derbyniwyd: 27/06/2014

Ymatebydd: Centaur Homes

Asiant : McLoughlin Planning

Cydymffurfio â’r gyfraith? Nac Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Nac Ydi

The Policy could be interpreted to seek higher levels of affordable
housing and, therefore, lacks any precision or certainty for applicants. In accordance with the SHMA, the amount of affordable housing required in the
District is broadly proportionate to 40% of the total housing need, excluding any
requirement that arises assisting adjacent authorities with their housing need. The
insertion of "up to 40%" merely reflects the need for flexibility with proposals
involving an odd number of houses.

Cefnogi

ID sylw: 65996

Derbyniwyd: 27/06/2014

Ymatebydd: West Midlands HARP Planning Consortium

Asiant : Tetlow King Planning Ltd.

We are supportive of the 40% affordable housing target. However the policy wording currently states that residential development "will not be permitted unless provision is made for a minimum of 40% affordable housing" We are of the opinion that such a blanket policy does not allow the flexibility a developer may require to bring forward sites that may not be viable at such a high rate of delivery. In the interests of delivering more affordable housing it would be of benefit to the Council to make clear that lower contributions may be acceptable providing the developer can offer clear evidence to justify
a lower target.

Gwrthwynebu

ID sylw: 66048

Derbyniwyd: 27/06/2014

Ymatebydd: Home Builders Federation Ltd

Cydymffurfio â’r gyfraith? Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Ydi

This policy proposes that a minimum of 40% affordable housing to meet local needs is provided on residential developments of 10 or more dwellings within the urban area and 5 or more dwellings within the rural areas. The form of affordable housing, its location on the site and its means of delivery will be subject to negotiation at the time of a planning application.

Policy H2 together with other policy requirements such as Policy CT5 Infrastructure Contributions to Meeting Places, Cultural Facilities and Public Art, Policy CC3 Building Standards Requirements, and DM1 Infrastructure Contributions are not justified by the viability assessments, which demonstrate that at the Baseline Market Position no development was viable at 40% affordable housing provision.

Gwrthwynebu

ID sylw: 66092

Derbyniwyd: 27/06/2014

Ymatebydd: Gleeson Developments

Asiant : Savills (L&P) Ltd

Cydymffurfio â’r gyfraith? Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Ydi

Policy H2 refers to a need for a minimum of 40% affordable housing to meet the local needs. However, the evidence base does not justify this level of affordable housing. Indeed, the Base Line Market Position in the Viability Assessment Final Report (Nov 2011 DTZ) which pre-dates the NPPF and NPPG confirms that no development was viable at 40% (paragraph 10.6). Paragraph 10.8 of the Affordable housing Viability Assessment states: "....DTZ would suggest Warwick District Council consider producing a zoned affordable housing policy which has different affordable housing percentages by area."

This stance should be considered in policy H2. Policy H2 should therefore be re-written to ensure that the level of affordable housing renders development viable.

Gwrthwynebu

ID sylw: 66112

Derbyniwyd: 27/06/2014

Ymatebydd: CALA Homes (mids) Ltd

Asiant : Cerda Planning Ltd

Cydymffurfio â’r gyfraith? Nac Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Nac Ydi

However, Policy H2 together with other policy requirements such as Policy CT5 (Infrastructure Contributions to Meeting Places, Cultural Facilities and Public Art), Policy CC3 (Building Standards Requirements), and Policy DM1 (Infrastructure Contributions) result in a level of financial contribution that render development unviable.

The consultants, DTZ, who prepared the Council's Affordable Housing Viability Assessment suggest Warwick District Council consider producing a zoned affordable housing policy which has different affordable housing percentages by area. This recommendation should be considered by the Council.

Gwrthwynebu

ID sylw: 66122

Derbyniwyd: 27/06/2014

Ymatebydd: Mr and Mrs Martin

Asiant : Cerda Planning Ltd

Cydymffurfio â’r gyfraith? Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Ydi

Policy H2 together with other policy requirements such as Policy CT5 (Infrastructure Contributions to Meeting Places, Cultural Facilities and Public Art), Policy CC3 (Building Standards Requirements), and Policy DM1 (Infrastructure Contributions) result in a level of financial contribution that render development unviable. Indeed, it is not justified by the LPA's own viability assessments, which demonstrate that no development was viable when providing 40% affordable housing.

The consultants, DTZ, who prepared the Council's Affordable Housing Viability Assessment suggest Warwick District Council consider producing a zoned affordable housing policy which has different affordable housing percentages by area. This recommendation should be considered by the Council.

Gwrthwynebu

ID sylw: 66192

Derbyniwyd: 27/06/2014

Ymatebydd: Hallam Land Management and William Davis

Asiant : Marrons Planning

Cydymffurfio â’r gyfraith? Nac Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Nac Ydi

In its present form there are a number of concerns about this policy, it is considered inconsistent with the advice in para. 50 of the NPPF and on that basis is unsound.

If market conditions for the development of land for new homes were to fall back from those currently experienced, securing the provision of at leat 40% of the new homes as affordable on any one site, may render a development proposal unviable.The policy as presently drafted is insufficeintly flexible to allow for such future circumstances.

It is considered that by including in Policy H2 the expression that on all qualifying sites, a minimum of 40% of the new housing must be affordable, then there will be flexibility in the application of the policy over time.

Gwrthwynebu

ID sylw: 66246

Derbyniwyd: 24/06/2014

Ymatebydd: Crest Strategic Projects

Asiant : d2planning

Cydymffurfio â’r gyfraith? Nac Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Nac Ydi

Objections are lodged to the proposed 40% affordable housing provision. This is contrary to the evidence which concludes that 35% affordable housing is a viable level. The purpose of the Plan led system is to provide certainty to developers, landowners etc. If the Council ignore their own evidence and adopt a higher threshold for affordable housing, there will be no guarantee that they would adopt a flexible approach once the 40% threshold was adopted.

This approach is totally contrary to the guidance in the NPPF which requires that viability of affordable housing and other policy requirements of the plan are deliverable and to ensure that these do not render development unsuitable and thus that plans undeliverable. The onus should not be placed on the developer to provide viability but for the Council to ensure that viability has been assessed when arriving at the initial figure for affordable housing within policy. This is in line with the NPPF but also the decision in Blyth Valley DC v Persimmon Homes (North East) limited (2008).

Concerns are also expressed at the content of the viability assessment which underpins the affordable housing policy. It considered that either a number of costs have not been taken into account e.g. biodiversity offsetting, flood mitigation etc or that the figures included within the viability assessment are too low e.g. planning contributions.

Gwrthwynebu

ID sylw: 66293

Derbyniwyd: 26/06/2014

Ymatebydd: Mr H E Johnson

Asiant : Bond Dickinson

Cydymffurfio â’r gyfraith? Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Ydi

We support the Council's intention to provide affordable homes.
However, we object to a blanket requirement of 40%: this is too prescriptive. It is not justified or effective and the policy is therefore unsound. The policy should make it clear that the amount of affordable housing will be determined on a site by site basis with an overall aim of achieving 40% where possible and viable, in order to be sound.

Gwrthwynebu

ID sylw: 66348

Derbyniwyd: 27/06/2014

Ymatebydd: David Wilson Homes

Asiant : Turley

Cydymffurfio â’r gyfraith? Heb nodi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Heb nodi

We support this policy, however we recommend that the Council applies a flexible approach to viability and deliverability as emphasised in the Framework which states that 'the sites and the scale of development identified in the plan shoul not be subject to such a scale of obligation and policy burden that their avility to e developed viably is threatened'.

This applies equally to the setting of and appliocation of affordable housing policies.

Gwrthwynebu

ID sylw: 66469

Derbyniwyd: 27/06/2014

Ymatebydd: Gladman Developments

Asiant : Stansgate Planning

Cydymffurfio â’r gyfraith? Nac Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Nac Ydi

Sets out that development will not be permitted unless provision is made for 40% affordable housing of sites of 10 or more dwellings, or 0.3 ha or more within the urban areas, and on sites of 5 or more dwellings or 0.17 ha within rural areas.
Policy Analysis
Council should ensure that its affordable housing requirements are based on robust evidence, taking account of development viability. In this regard we note that the authority's most recent Affordable Housing Viability Study was published in 2011, with a further addendum prepared in 2012. Concerned as to whether this evidence is out-of-date inadequate to support the LP's proposals.
Conclusions on Soundness
In light of the time that has passed since publication of affordable housing viability evidence, query whether this is still up to date and sufficient to support the approach set out in Policy H2.

Gwrthwynebu

ID sylw: 66549

Derbyniwyd: 27/06/2014

Ymatebydd: Taylor Wimpey

Asiant : Barton Willmore

Cydymffurfio â’r gyfraith? Nac Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Nac Ydi

Policy H2 should be re-worded in order to clarify that the overall requirement of 40% affordable housing can be reduced based on viability. In its current form the policy appears to allow for the: form of provision of affordable housing; location on the site of affordable housing; and the means of delivery of affordable housing to be subject to negotiation at the time of a planning application, and it states that the viability of the development will be a consideration in such negotiations.
However, this does not clearly state that the actual proportion of affordable housing can be negotiated based on the viability of a site, which when considered against paragraph 173 of the NPPF is something which a developer should clearly be capable of doing.

Cefnogi

ID sylw: 66589

Derbyniwyd: 27/06/2014

Ymatebydd: Catesby Property Group

In general terms we support draft Policy H2 which seeks to secure affordable housing as part of new development. In particular, we support the recognition that the location and means of delivery will be the subject of negotiation and will account of site specific factors such as viability, in accordance with paragraphs 173 and 174 of the NPPF. We would also support a policy which provides flexibility in terms of the sizes, types and tenures of affordable homes provided and which does not seek to set out a prescribed mix. The affordable housing mix needs to respond to the evolving requirements of Registered Providers and allow for flexibility to assist with delivery to meet housing need and align with their funding constraints.

Gwrthwynebu

ID sylw: 66751

Derbyniwyd: 27/06/2014

Ymatebydd: Mr Edward Walpole-Brown

Asiant : Brown and Co

Cydymffurfio â’r gyfraith? Nac Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Nac Ydi

We feel the Policy is unsound and needs to be challenged on the basis that it
indicates there should be a minimum of 40% affordable. We should suggest that it
should be up to 40% subject to viability and establishing local needs. Whilst it is
accepted there may be an affordable housing problem, much of this has been due
to the lack of supply of housing land as a result of ineffective Plans from the past
and the inability to delivery adequate land for housing growth.

Gwrthwynebu

ID sylw: 66770

Derbyniwyd: 26/06/2014

Ymatebydd: Burman Brothers

Asiant : Nigel Gough Associates Ltd

Cydymffurfio â’r gyfraith? Heb nodi

Cadarn? Heb nodi

Dyletswydd i gydweithredu? Heb nodi

Understand Council's desire to see to provide a requirement on all principle sites of up to 40% affordable housing, this has got to be properly tested for each allocation in terms of tenure/mix

Gwrthwynebu

ID sylw: 66834

Derbyniwyd: 27/06/2014

Ymatebydd: Europa Way Consortium

Asiant : AMEC

Cydymffurfio â’r gyfraith? Ydi

Cadarn? Nac Ydi

Dyletswydd i gydweithredu? Ydi

We are concerned that the wording requiring a minimum of 40% affordable housing may not allow sufficient flexibility to take into account viability or site specific factors. Consideration of viability is required to be consistent with para 173 of the NPPF.

With regard to sub point ii) sizes, types, and tenures of homes; flexibility is needed to allow for changing housing needs and market conditions over the time required to build an urban extension. Flexibility is needed to facilitate a wide range of factors being taken into account in determining overall housing mix.

We would recommend changing the words 'determined on' in the first line to 'guided by'.

There is a very real danger of creating pockets of relative social exclusion if the proportions of social rented tenures are inflexibly required.