Archived decisions
APPENDIX 2
Influencing the size, type and affordability of housing
Hampshire County Council's response to proposed Changes to PPG3 - Influencing the size, type and affordability of housing are as follows.
Question 1
We propose a greater role for regional and sub-regional planning, in recognition that housing markets do not respect local authority boundaries. Do you agree?
Response
It is agreed that housing markets do not respect local authority boundaries and that there should be a greater role for sub-regional planning. At present there are difficulties assessing overall housing need due to the differences in completion dates and methodologies of Housing Needs Surveys and a lack of data about in commuting. The collection of data using a consistent approach for housing market areas would be welcomed.
Question 2
We propose a reduction in the site size threshold (in most areas) above which affordable housing can be sought, subject to the affordable housing provision not making development unviable. Do you agree with the proposal?
Response
Yes. Hampshire County Council welcomes a reduction in the site size threshold . Six authorities already use the 15 dwellings /0.5 hectare threshold which is proposed. A further three authorities have adopted a significantly lower threshold of 5 or 6 dwellings / 0.2 or 0.25 hectares as they believe that exceptional circumstances exist within their local area. Only three authorities currently use the 25 dwelling/ 1 hectare threshold.
It is therefore suggested that the potential increase in the supply of affordable homes which would result from this change may have been over-estimated.
Question 3
We propose that affordable housing should be defined in local plans in terms of the relationship between local income levels and house prices or rents for different types and sizes of housing, and in terms of housing for identified groups such as key workers, and be based on an up-to-date assessment of housing needs.
Question 3a
Do you agree with the proposal that affordable housing should be defined in local plans in terms of the relationship between local income levels and house prices or rents for different types and sizes of housing?
Response
Support in general, however high income levels in parts of Hampshire can mask the problems faced by key workers and others on a moderate income, particularly in public sector employment with national pay scales.
Question 3b
Do you agree with the proposal that affordable housing should be defined in local plans in terms of housing for identified groups such as key workers?
Response
Yes. Agree that key workers should be seen as part of overall affordable housing and not as a separate category of housing need, in competition for funding.
Question 3c
Should key workers be defined in local plans in terms of:
(i) their income
(ii) their job;
or an alternative?
Response
Key workers should be defined in terms of their job, with an upper threshold for earnings. This threshold should be reviewed on a regular basis.
Question 4
We propose that affordable housing should not normally be defined by reference to tenure. The exception would be where this would address an identified housing need that otherwise would not be met by other types of affordable housing. Do you agree with the proposal?
Response
Yes. This should allow sufficient flexibility for the varying needs of different local authority areas.
Question 5
We propose that local planning authorities should work with developers to ensure planning objectives reflect the development potential of sites and that the affordable housing provision sought should not make development unviable. Do you agree?
Response
Yes. Providing the options of direct provision on an alternative site or off site contributions have been considered. The differences in development costs and the competing demands for section 106 agreements are recognised and in some cases it may be necessary to reduce the amount of affordable housing required or to allow off site contributions to make a scheme viable.
Question 6
We propose in paragraph 9 a number of considerations that are relevant to whether the affordable housing provision sought would make development unviable. Should the list of considerations include:
a. The costs of bringing sites to the market, including the implications of competing land uses?
b. Making realistic assumptions on levels of public subsidy available for affordable housing?
c. The need for proposed development to be attractive to the lenders of private finance?
d. Avoiding prescription of tenure?
e. Other considerations? If so please explain.
Response
No Comment
Question 7
We propose in paragraph 13 a limited number of circumstances where the presumption that affordable housing should form part of the proposed development of the site could be set aside. Should the list include where:
a. The affordable housing is more effectively secured by bringing existing housing back into active use?
b. Management of the affordable housing on site cannot be secured effectively?
c. Providing the affordable housing elsewhere in the plan area is more likely to widen housing choice and encourage better social mix?
d. Other circumstances? If so please explain.
Response
It is considered that the list should include a and c.
Question 8
We propose that local planning authorities should plan to meet the housing requirements of the whole community by planning for a mix of housing types and sizes that reflects up-to-date assessments. Do you agree?
Response
Yes
Question 9
We propose that affordable housing provision in rural areas could be supported by allocating sites solely for affordable housing, on land within or adjoining existing villages, which would not otherwise be released for housing and where this would contribute to the attainment of mixed communities. Do you agree?
Response
Yes, providing development sites are small to avoid creating affordable housing estates.
Question 10
The proposal that local planning authorities should be able to allocate sites for 100% affordable housing is limited to rural areas and to land, within or adjoining existing villages, which would not otherwise be released for housing. Should this provision be more widely available, and if so in what circumstances?
Response
No, it would be better to reduce the site size threshold/ increase the proportion of affordable housing required. Do not want to create affordable housing estates.
Question 11
Will the proposed change enable the provision of more affordable housing in your area? If so, can you say why?
Response
The majority of districts in Hampshire already use thresholds which are lower than the current 25 dwelling threshold. The proposals will strengthen local plan policies and provide the opportunities for rural areas experiencing housing pressure to secure more affordable housing.
Question 12
The proposed change requires greater attention to assessment and evaluation of impact than the current policy. We will produce practice guidance to help - with the overall intention of simplifying and speeding up the process. Read together, will the proposed change and practice guidance achieve this?
Response
Guidance is necessary in the context of the changing development plan system although in the short term this will place extra demands on staff time and resources. The guidance reflects the direction of housing policy and practice in Hampshire with the adoption of lower development thresholds and increases in joint working between local authorities.
Question 13
In the light of Question 12, can this be achieved within the current resources of your organisation?
Response
Not applicable
Question 14
Is the proposed change likely to be advantageous to small businesses?
Response
In Hampshire there are difficulties in recruiting and retaining employees in both the public and private sector because many people find it difficult to find suitable accommodation, in the same town/ village as the workplace, at a price they can afford. More affordable and key worker housing provision may address some of these problems and therefore benefit small businesses.
Question 15
Do you consider the proposed scope of the practice guide (at Annex B) covers all the topics it needs to? If not what is missing, and why?
Response
Yes, it appears to cover all the necessary topics.
Question 16
Does the proposed scope of the practice guide include topics, which don't need to be covered? If so which, and why?
Response
No Comment