Cefnogi

ID sylw: 71716

Derbyniwyd: 21/02/2020

Ymatebydd: Pegasus Group

Northern Trust welcome the confirmation that the definition of affordable housing applied is as per that set out in the NPPF at Annex 2.

Gwrthwynebu

ID sylw: 71717

Derbyniwyd: 21/02/2020

Ymatebydd: Pegasus Group

Site Size
The draft text suggests that a ‘threshold of 10 units’ will be applied when considering affordable housing provision in new schemes. This does not accord with Local Plan Policy H2 which sets a threshold of 11 or more dwellings, or a total floorspace of over 1,000m2. The wording set out in the draft SPD should be amended to accord with Local Plan Policy H2.

Gwrthwynebu

ID sylw: 71718

Derbyniwyd: 21/02/2020

Ymatebydd: Pegasus Group

Site Viability
Northern Trust support the recognition that some development proposals may be unable to meet all of the relevant affordable housing requirements whilst remaining viable and deliverable. Northern Trust support the requirement to submit a viability assessment where this is the case

Gwrthwynebu

ID sylw: 71719

Derbyniwyd: 21/02/2020

Ymatebydd: Pegasus Group

Affordability and Tenure
Northern Trust welcome the Council’s recognition that the tenure split may be revised by subsequent SHMA’s or successor document to represent the most recent and robust evidence which Northern Trust welcome and fully support. In this regard, and noting that the SHMA Update is based upon data which is some 5 years old, it would important that the SPD confirms that this evidence base will be updated in a timely manner noting the NPPF’s requirement to deliver a wide range and variety of homes.

Gwrthwynebu

ID sylw: 71720

Derbyniwyd: 21/02/2020

Ymatebydd: Pegasus Group

Housing Types and Size
Mix doesn’t take into account the risks of single occupants in two-bedroom properties paying the “bedroom tax”.

Insufficient flexibility overly prescriptive rules from Councils can delay developments, and Northern Trust encourages the Council to be more flexible.

There is no sufficient evidence regarding bungalow need.

Gwrthwynebu

ID sylw: 71721

Derbyniwyd: 21/02/2020

Ymatebydd: Pegasus Group

Affordability in Perpertuity
The commentary provided under this subheading relating to Starter Homes and Discount[ed] Market Sales is confusing and no context is provided as to the purpose of this text. However, in respect of the starter homes, it is assumed that this text relates to the proposed restriction period for the resale of starter homes. It is important that any such restriction period is properly considered and evidenced noting the impact that having a restricted period which is too long can make it difficult for first-time buyers to move on to a larger (or smaller) new home and can put off first-time buyers from taking up such products.

It is unclear what the text relating to Discount[ed] Market Sales relates to or its purpose and we would reserve the right to comment on this further once this has been made clear. Nevertheless, we would note that references to ‘determined by local incomes’ in considering what is market value does not accord with the definition of such affordable housing within the NPPF.

Cefnogi

ID sylw: 71722

Derbyniwyd: 21/02/2020

Ymatebydd: Pegasus Group

Northern Trust support the recognition that affordable homes should be pepper potted across larger schemes, yet still provided in clusters. Providing small clusters allows for easy management of properties by Registered Providers.

Gwrthwynebu

ID sylw: 71723

Derbyniwyd: 21/02/2020

Ymatebydd: Pegasus Group

Although Northern Trust do not object to the suggested timescales for delivering affordable homes, or the need to ensure that affordable homes are delivered in a timely manner, it is recommended that a degree of flexibility is applied to this approach to take into account schemes where it can be demonstrated that, as a result of viability or phasing requirements, it would not be possible to bring forward the affordable housing in the manner envisaged through the draft SPD. It is therefore recommended that the suggested timescales will be applied unless evidence is provided to allow slight amendments to the timescales for affordable delivery.