Draft Affordable Housing SPD
Representation ID: 28625
Respondent: South Cambridgeshire District Council
The SPD should be more explicit about the partnership working arrangements with SCDC on major developments regarding lettings. This would help reinforce the message that the two authorities work closely together on spatial planning matters.
Much of the draft SPD can be supported, however in a few instances the approach proposed in the SPD is likely to differ from that likely to be followed in South Cambridgeshire when our own Affordable Housing SPD is reviewed later this year because they are not consistent with the NPPF or otherwise appropriate. The proposed representations are intended to help to ensure that a common approach is followed across the two districts to financial contributions, and to assist the general refinement of the wording of the SPD.
A link to the draft SPD is provided at the background papers section of this report.
Welcome and support the Affordable Housing SPD subject to the following representations and comments.
2.4 The NPPF sets out Government policy rather than guidance. Practice guidance is provided in the NPPG.
2.11 Specialist Housing - Where group homes are provided we would question whether it is viable or feasible to require an affordable contribution within the scheme.
3.3 The SPD should be more explicit about the partnership working arrangements with SCDC on major developments regarding lettings. This would help reinforce the message that the two authorities work closely together on spatial planning matters.
3.36 Should there be a cap on the overage to prevent the effective affordable housing provision ever being the equivalent of more than the 40% affordable housing provision required by the policy at the time of determination of a planning application?
4.5 Should this paragraph also allow affordable housing to come forward in advance of the market housing? This was quite a common occurrence nationally and locally in the depths of the recession and should not be hampered by the SPD.
Section 5 Building Design Within the Building Design section there is no mention of a minimum standard relating to the Code for Sustainable Homes, although there is reference within paragraph 8.9 in the Implementation and Monitoring section which lists the standard affordable housing clauses that form part of the Section 106 agreement. It is not clear therefore whether the SPD is seeking a minimum level.
Section 7 Occupancy Within this section, reference should be made to allocations through the sub-regional Home-Link Choice Based Lettings scheme.
Calculation of Financial Contributions (Appendix 2)
The NPPF at paragraph 50 states that affordable housing should be provided on site, unless off-site provision or a financial contribution of broadly equivalent value can be robustly justified. Because the subject of this statement is the affordable housing that has not been provided on site, this must mean that the financial contribution must be of broadly equivalent value to the affordable housing that has not been provided on site.
However the approach followed in the draft Cambridge SPD is different. In summary it calculates the market value of the affordable housing (using either the value of the land or of the housing floor space depending on the scale of the development) and requires a percentage of this as a financial contribution. This approach is not considered to be consistent with the 'broadly equivalent value' test of the NPPF which relates to the value of the foregone on site affordable housing.
Paragraph 50 of the NPPF goes on to say that 'Such policies should be sufficiently flexible to take account of changing market conditions over time'. However the SPD does not explain what review mechanism is in place for the calculation of financial contributions and whether they will be updated on an annual basis.
The consultation SPD goes in to a lot of detail in terms of commuted sum calculation but appears to be inconsistent in terms of sections:
(i) How to calculate an affordable housing contribution for proposals of 2 to 9 dwellings; and
(ii) How to calculate an affordable housing contribution for 10 or more dwellings (top-up financial contributions where use of the affordable housing policy percentage produces fractions of units).
The first method considers a commuted sum based on the whole development floorspace whereas when working out the commuted sum for the fraction of units in section (ii), it is based on a percentage of 'unit type that would have been allocated for affordable housing'.
Not only is this inconsistent but it also leads to a problem - what if the developer disputes which unit should be provided as affordable housing? Furthermore why is the fraction not based on the total remaining floor area as per the first method?
Appendix 6 Paragraph 10 Affordable housing mix
This section should include a table showing the housing mix which would currently best meet the housing needs of households on the Cambridge housing needs register. In contrast to such a table derived from actual needs, table 12 of the SPD provides a housing mix for affordable housing derived from SHMA data which has to be mathematically 'dampened' to yield a credible mix which reduces the number of 4 and 3 bedroom properties and includes a greater proportion of one and two bedroom properties.
The proposed mix only makes provision for 20% 1 bedroom properties despite issues such as the spare bedroom subsidy (also known as the bedroom tax) which can make larger properties difficult to let to households in the most housing need and would appear to not take full account of evidence in the SHMA that the projected increase in household types to 2031 in Cambridge will be concentrated in smaller households (Table 3 of Chapter 14 of the SHMA).
Housing colleagues and the s106 officer have contributed to the preparation of the Council's response to the draft Affordable Housing SPD.