Comment

Representation ID: 21908

Received: 12/03/2020

Respondent: Home Builders Federation

We would recommend that the term “at least” is removed from the policy prior to each percentage requirement. Policies on affordable housing should not seek to establish requirements as minimums. This does not provide the necessary certainty for either the decision maker or applicant as to the required level of provision. The policy should set out clearly what is expected of the developer and if they meet that expectation then an application should not be refused.
It would also appear that this policy will require C3 accommodation for older people to be provide on-site affordable housing and as such provides insufficient flexibility. Such affordable housing provision has proven to be incompatible with managed sheltered housing developments. It is often the case that housing providers are unwilling to take on such units. We are therefore concerned that the policy would stifle delivery of sheltered housing accommodation. Such an approach conflicts with the positive approach towards housing delivery contained within the NPPF and as such is unsound. We would suggest that accommodation for older people not be required to provide onsite provision for affordable housing and instead be required to provide a commuted sum in lieu of provision.
It is further noted that the interim viability study has not considered a specific typology with regard to retirement homes. Such development has, for example, a higher proportion of its floorspace as communal areas and general assessments of residential viability cannot be relied on when assessing the viability of more specialist accommodation to meet the policy requirements of a local plan. We would therefore recommend a specific typology for special older people’s accommodation is tested in the viability study.