Affordable Housing SPD

Object

Representation ID: 71626

Received: 13/02/2020

Respondent: Barton Willmore (now Stantec)

The draft should be expanded to refer to the relevant sections of the NPPF and PPG in terms of the purposes and scope of an SPD.

The draft SPD states that affordable housing policies are not defined as strategic policies within the Warwick District Local Plan. Therefore, neighbourhood plans could seek to require a different amount of affordable housing provision within their neighbourhood area, provided there is local justification. Where a ‘made’ neighbourhood plan does include different affordable housing policies to those in the local plan, these
will take precedence where they differ from the Local Plan.
Policy H2 Affordable Housing of the WDC Local Plan does not reference the ability for Neighbourhood Plans to vary the overall 40% District requirement. Reference is made to the sizes, types and tenures of homes being determined “by other local needs surveys and information” but not the overall scale of provision. However, should this element of the SPD be taken forward the text should be updated to reflect that the Local Plan policy requirement is based upon the Strategic Housing Market Assessment evidence and has been the subject of a viability assessment (in line with national policy and guidance). The draft SPD should stipulate that neighbourhood plan policies are not expected to seek in excess of the Local Plan policy requirement accordingly; any that do must be the subject of a neighbourhood plan viability assessment.

Object

Representation ID: 71627

Received: 13/02/2020

Respondent: Barton Willmore (now Stantec)

RE: SITE SIZE
The draft SPD states “where the site is a subdivision of a larger site or adjacent to another potential
housing site, the site size for threshold purposes will be taken to be the larger development site.”
A series of considerations are then set out for determining whether two or more sites should be considered as one. The draft SPD should be clear that any barriers to separate sites being reasonably considered as one whole development site, for example landownership and landowner intentions, will be fully accounted for. The draft SPD states that the density of the development will be considered in the application of the threshold of 10 dwellings. We consider that this section of the draft SPD should be reworded to make it clear that the Council is not seeking to control the density of developments beyond where density is being used to purely circumvent the provision of affordable housing i.e. the guidance should not lead to increases in density across all developments. The guidance should further clarify that in considering whether the density is ‘inappropriate’ this will have regard to all principles of good design, not just density which on its own can be a crude measure of whether not a development is suitable.

Object

Representation ID: 71628

Received: 13/02/2020

Respondent: Barton Willmore (now Stantec)

RE: SITE VIABILITY
The draft SPD provides for instances where developers may not be able to meet the affordable housing and other planning obligations in full. The ability for viability to be considered and negotiations to take place on the viable amount of provision is supported. The draft SPD should refer to the Council having regard to PPG on viability (including the standard approach to viability assessments) to ensure consistency with national policy and guidance.

Object

Representation ID: 71629

Received: 13/02/2020

Respondent: Barton Willmore (now Stantec)

RE: ALTERNATIVE DEVELOPER CONTRIBUTIONS
The draft SPD provides a calculation for off-site affordable housing financial contributions. It is noted that this seeks to reflect the increased number of market houses on a site (where an off-site financial contribution is being made) and results in a higher percentage of affordable housing being provided for via an off-site financial contribution. It should be demonstrated that this is not going over and above existing local plan polices which have been subject to viability assessment. Policy H2 states the Council will “in exceptional circumstances, accept contributions of equivalent value in lieu of on-site delivery. This should include financial contributions, land or off-site provision of affordable homes.” Paragraph 4.27 of the Warwick District Local Plan then states that a developer may be required to provide either, or both, an alternative site and financial contribution. It is therefore not clear if the ’uplifted’ off-site financial contribution contained within the draft SPD assumes a developer will not be providing land as well, or if the ‘uplift’ for the financial contribution assumes no land is provided. This should be clarified in the draft SPD. The text of the SPD should also confirm that the off-site financial contributions will be ‘rounded down’ as per the examples provided in the accompanying table.

Support

Representation ID: 71630

Received: 13/02/2020

Respondent: Barton Willmore (now Stantec)

RE: AFFORDABILTY & TENURE
The draft SPD provides an expected tenure split based upon the most recent Strategic Housing Market
Assessment (SHMA) findings but notes that these may vary site to site. In relation to the housing types and sizes, the draft SPD seeks to deviate from the SHMA and provide fewer one bed properties. This is in recognition of the limitations placed on household growth and individual lifestyle choices by one-bedroom properties. The draft SPD seeks to provide more two-bed properties and fewer one bed properties, but still within the sum of the total range for these i.e. 55-65%. The draft SPD also encourages two-bed bungalows to be provided; however, the draft SPD should recognise the potential implications for site density and design of providing such properties.

The flexible approach for site specific tenure mixes, housing types and sizes is supported. The
flexibility could be strengthened by references to the site-specific circumstances such as location, local market demand and viability being considered as part of determining the mix on site.

Object

Representation ID: 71631

Received: 13/02/2020

Respondent: Barton Willmore (now Stantec)

The draft SPD strongly encourages all developments to reduce their carbon footprint and states that a future Development Plan Document (DPD) will be produced to address design matters related to this. Whilst a positive approach to addressing carbon reduction and climate change is supported, the correct approach is to consider any requirement for standards via a DPD wherein any viability implications can be considered, in line with national policy and guidance. As part of any future standards, the Council should take into consideration the Governments recent Future Homes Standards consultations (2019) on increased Building Regulations requirements for zero carbon homes.

Object

Representation ID: 71632

Received: 13/02/2020

Respondent: Barton Willmore (now Stantec)

APPENDIX II

The draft SPD provides a template Section 106 agreement for completion alongside submission of a planning application. Whilst the bullet points specify that some details will only be required for full and reserved matters applications, the SPD should made clearer to acknowledge that some of the details required will not always be known for an outline planning application and there shouldn’t be a requirement to submit this information in these circumstances i.e. some elements, such as the overall housing mix (which is currently expected to be known with an outline planning application) will not be finalised. The SPD should also recognise that details may change during the course of the planning application.

Object

Representation ID: 71633

Received: 13/02/2020

Respondent: Barton Willmore (now Stantec)

APPENDIX III

The draft SPD sets out that a clause will be included within Section 106 agreements to manage the timescales for delivery of affordable housing alongside market housing. The timescales would require no more than 50% of the market dwellings to be occupied until 50% of the affordable houses are ready for occupation and that no more than 95% of the market dwellings are occupied until all the affordable houses are ready for occupation. There do not appear to be any provisions to deviate from this. The draft SPD and legal agreement clauses should provide site by site flexibility which enables factors, such as the scale of the site, to be taken into account.

Object

Representation ID: 71634

Received: 13/02/2020

Respondent: Barton Willmore (now Stantec)

APPENDIX III - LEGAL AGREEMENTS
The draft SPD states the standards of construction will be addressed in the legal agreement. We query the
necessity for the standards of construction to be contained within the Section 106 agreement. The approved design and plans for the development, and subsequent building regulation approvals, are the mechanisms for ensuring the necessary standards are achieved. It is considered unnecessary to provide for a further mechanism within the Section 106 agreement.