8.9

Showing comments and forms 1 to 3 of 3

Object

Draft Affordable Housing SPD

Representation ID: 28499

Received: 11/07/2014

Respondent: Savills

Agent: Savills

Representation Summary:

The standard approach set out here to occupation of market units, code for sustainable homes etc. places a significant burden on the developer. There is nothing within this document to show that the cumulative impact of all the obligations set out here and within other planning policy documentation do not adversely impact upon the delivery of the plan. This should be clarified as a matter of significant importance.

Full text:

The standard approach set out here to occupation of market units, code for sustainable homes etc. places a significant burden on the developer. There is nothing within this document to show that the cumulative impact of all the obligations set out here and within other planning policy documentation do not adversely impact upon the delivery of the plan. This should be clarified as a matter of significant importance.

Object

Draft Affordable Housing SPD

Representation ID: 28548

Received: 04/07/2014

Respondent: bpha

Representation Summary:

Para 8.9. The requirement that the affordable housing must be completed before 50% of the Market Housing can be occupied may seem high leading to areas RSL stock only where there is clustering. Sustainability issues surrounding higher numbers of RP's stock with no privately occupied properties. May hinder balanced communities as they settle in.

Full text:

Dear Sirs,

Please see bpha's responses and generic comments to the recent consultation on the above document:


* Housing clusters should be self contained so that RP's can manage their own properties without the need to buy into third party management companies.

* Access to flats in a single core at 15 units. Can this be 16 flats i.e. 4 flats per floor, 4 floors.

* Para 4.11 - 75:25 split. This paragraph refers to the tenure split being for the life of the Cambridge Housing Strategy 12/15. This may mean developers may argue that this split is irrelevant for schemes which go beyond 2015

* Will any 'off site' affordable contributions collected on non qualifying sites be available as grant from Cambridge City Council to RP's for other developments?

* Schemes of over 20 units require a 5% wheelchair design requirement. Will there be any opportunity for part of this to be made up from private sales units rather than all falling to RP's?

* The introduction of minimum space standards will drive up costs for RSL's but rent caps in place, will squeeze RSL's and may hinder delivery.

* Lifts in flat blocks. This needs to be discretionary. Cost of lift provision and on going maintenance is a very costly burden for RSL's and residents who pay for this service through service charges. Requirements for a lift should be considered on the basis of the client group - storey height and number of dwellings served by the lift.

* Para 8.9. The requirement that the affordable housing must be completed before 50% of the Market Housing can be occupied may seem high leading to areas RSL stock only where there is clustering. Sustainability issues surrounding higher numbers of RP's stock with no privately occupied properties. May hinder balanced communities as they settle in.

Object

Draft Affordable Housing SPD

Representation ID: 28622

Received: 14/07/2014

Respondent: Universities Superannuation Scheme Ltd (USS)

Agent: Deloitte

Representation Summary:

The standard clauses for any s106 Agreement which prevent development commencing until completion of a transfer of an affordable housing site or lease or that affordable housing must be completed prior to 50% of market housing being occupied, are potentially onerous.
Flexibility needs to be built in to the standard clauses to reflect the different way affordable housing can be negotiated and delivered. For example, there may be instances where delivery of affordable housing may be dependent on forward selling a proportion of market housing and this may be above 50%. Again this may be related to exceptional costs being borne by the development or uncertainty from developers as to values they might receive from registered providers for affordable units Individual site characteristics mean that blanket policy requirements should be tempered by a level of flexibility in the application of policy requirements.

Full text:

On behalf of our client, Universities Superannuation Scheme Investment Management (USSIM), please find below representations on the draft Affordable Housing SPD.

Viability (pages 12-15)

Whilst it is recognised that contributing towards affordable housing provision should be reflected in the price paid for the land, this is not always the case. Historic purchases based on previous market values can continue to be a burden even in the improving economic climate. It is important that Cambridge City Council applies the affordable housing target sensitively, taking full account of individual site circumstances, including financial viability. Until land values adjust to reflect policy requirements, which is still a long way off, application of policy needs to be undertaken carefully to encourage development to come forward. The SPD should also reflect that some sites may be carrying exceptional costs such as infrastructure or contamination costs.

Monitoring and implementation (Section 8)

The standard clauses for any s106 Agreement which prevent development commencing until completion of a transfer of an affordable housing site or lease or that affordable housing must be completed prior to 50% of market housing being occupied, are potentially onerous.
Flexibility needs to be built in to the standard clauses to reflect the different way affordable housing can be negotiated and delivered. For example, there may be instances where delivery of affordable housing may be dependent on forward selling a proportion of market housing and this may be above 50%. Again this may be related to exceptional costs being borne by the development or uncertainty from developers as to values they might receive from registered providers for affordable units Individual site characteristics mean that blanket policy requirements should be tempered by a level of flexibility in the application of policy requirements.