Response from Mr Tim Griffiths, C/o Garner Planning
1. Mr Tim Griffiths, C/o Garner Planning : 19 Dec 2017 10:48:00
Before completing this online representation please tick the box to show that you have read the guidance notes accompanying this consultation.
I have read the guidance notes
Policy Reference
AS03 - Housing Provision
1.1 Do you consider the AONB DPD to be legally compliant?
Yes
1.3 Do you consider the AONB DPD to be sound?
No
1.4 If NO please indicate the ground(s) on which you consider the DPD to be unsound
The DPD is not justified
The DPD is not effective
The DPD is not consistent with national policy
1.5 Please give details of why you consider the DPD is not legally compliant or is unsound or fails to comply with the Duty to Cooperate. Please be as precise as possible.
If you wish to support the legal compliance or soundness of the DPD or its compliance with the Duty to Cooperate, please also use this box to set out your comments.
The Policy is not justified, effective or compliant with national planning policy guidance.
The Housing Allocations in Policy AS15 comprise sites of between 0.1ha and 0.56ha intended to accommodate between 6 and 12 dwellings.
Policy AS03 indicates that the affordable housing requirement Is for no less than 50% with the caveat that where this is demonstrably unachievable a lower percentage will be acceptable.
The initial viability appraisal (October 2016) considered that 50% affordable housing would not be viable. A later viability study, completed in September 2017, considered that such a level of provision was viable. There are concerns regarding the viability assumptions to justify 50% affordable housing.
There are both market housing and affordable housing needs in the AONB but a requirement for a particularly high affordable housing may jeopardise the delivery of affordable housing.
Planning Practice Guidance indicates that contributions should not be sought for developments of 10 units or less, and which have a maximum combined gross floorspace of no more than 1,000 square metres (gross internal area). This threshold, is likely to be applicable to 5 out of 6 of the housing allocations.
Planning Practice Guidance indicates that in designated rural areas, local planning authorities may choose to apply a lower threshold of 5-units or less. Neither planning authority has made a decision to apply lower affordable housing thresholds, but if they did then for any scheme of between 6 and 10 dwellings affordable housing should be in the form of cash payments which are commuted until after completion of units within the development.
The policy indicates that the delivery of affordable housing should be phased to ensure the market is not over supplied at any one time. As any affordable housing is most likely to be delivered on sites with market housing, the implication is that planning permissions for individual sites will be phased. This is not appropriate and does not assist individual landowners in brining forward housing developments. If there is no demand for affordable housing at any one time then there can be no justification for requiring it on a particular site.
1.6 Please set out what modification(s) you consider necessary to resolve your objection and make the DPD legally compliant or sound, having regard to the matter(s) you have identified above. (Please note that any non-compliance with the Duty to Cooperate is incapable of modification at examination). You will need to say why this modification will make the DPD legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible.
Delete second sentence from first paragraph - "Proposals for new housing...50% affordable housing."
Replace with "For housing developments of over 10 dwellings, 35% affordable housing will be required. For housing developments of 6-10 dwellings, with a maximum combined gross floorspace of no more than 1,000 square metres (gross internal area) a contribution towards off-site affordable housing shall be made in the form of cash payments which are commuted until after completion of units within the development."
Insert additional paragraph that states:-
"A lower requirement for affordable housing provision will be acceptable where there is evidence that full provision would make the development unviable."
Delete last paragraph - "Affordable housing needs are forecast...Registered Providers of affordable housing."
2.1 If your representation is seeking a modification, do you wish to participate at the oral part of the Examination?
No, I do not wish to participate at the oral examination
Please tick the box if you wish to be notified when the document is submitted, recommendations published and adopted.
Please notify me
