Draft Affordable Housing SPD
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Draft Affordable Housing SPD
2.11
Representation ID: 28480
Received: 11/07/2014
Respondent: Savills
Agent: Savills
Where CCC is directing applicants to Pre-Application advice it should be clearly referenced that this comes at a cost to the developer.
Where CCC is directing applicants to Pre-Application advice it should be clearly referenced that this comes at a cost to the developer.
Object
Draft Affordable Housing SPD
2.12
Representation ID: 28481
Received: 11/07/2014
Respondent: Savills
Agent: Savills
A number of documents referred to in this section are not referenced. E.g. Dixon Searle's supplementary report. By virtue of it being supplementary it must supplement something?
A number of documents referred to in this section are not referenced. E.g. Dixon Searle's supplementary report. By virtue of it being supplementary it must supplement something?
Object
Draft Affordable Housing SPD
3.5
Representation ID: 28482
Received: 11/07/2014
Respondent: Savills
Agent: Savills
This does not accord with the council's pre-application which seeks detailed design before meetings are held.
This does not accord with the council's pre-application which seeks detailed design before meetings are held.
Object
Draft Affordable Housing SPD
3.11
Representation ID: 28483
Received: 11/07/2014
Respondent: Savills
Agent: Savills
It should be noted that the requirements of an outline application are indicative and subject to change. Developers should not be expected to commit too heavily at this stage without having fully designed the scheme or assessed the detail. It should be required that assessment goes as far as to say its possible, but not so far as to commit. The draft SPD seeks an indicative mix, but at the same time seeks to fix requirements. That is inherently contradictory. It also contradicts 3.12.
It should be noted that the requirements of an outline application are indicative and subject to change. Developers should not be expected to commit too heavily at this stage without having fully designed the scheme or assessed the detail. It should be required that assessment goes as far as to say its possible, but not so far as to commit. The draft SPD seeks an indicative mix, but at the same time seeks to fix requirements. That is inherently contradictory. It also contradicts 3.12.
Object
Draft Affordable Housing SPD
3.12
Representation ID: 28484
Received: 11/07/2014
Respondent: Savills
Agent: Savills
No indication is provided as to the setting of the affordable housing requirements for Cambridge. How do the chosen percentages relate to the 5 year land supply and how will they enhance the delivery of both affordable housing and the wider housing trajectory set out in the plan. This section contradicts 3.11, where it is stated that affordable elements will be fixed at outline stage.
No indication is provided as to the setting of the affordable housing requirements for Cambridge. How do the chosen percentages relate to the 5 year land supply and how will they enhance the delivery of both affordable housing and the wider housing trajectory set out in the plan. This section contradicts 3.11, where it is stated that affordable elements will be fixed at outline stage.
Object
Draft Affordable Housing SPD
3.14
Representation ID: 28485
Received: 11/07/2014
Respondent: Savills
Agent: Savills
Care needs to be taken to avoid unintended consequences, e.g. where by proposing one less unit the cost to the developer is significantly less.
Care needs to be taken to avoid unintended consequences, e.g. where by proposing one less unit the cost to the developer is significantly less.
Object
Draft Affordable Housing SPD
3.23
Representation ID: 28486
Received: 11/07/2014
Respondent: Savills
Agent: Savills
Generally welcome the acknowledgement that some cases exist where standards cannot be met, but further clarification as to the sorts of circumstances that can be considered exceptional should be provided.
Generally welcome the acknowledgement that some cases exist where standards cannot be met, but further clarification as to the sorts of circumstances that can be considered exceptional should be provided.
Object
Draft Affordable Housing SPD
3.30
Representation ID: 28487
Received: 11/07/2014
Respondent: Savills
Agent: Savills
Replace 'may' with 'will'
Replace 'may' with 'will'
Object
Draft Affordable Housing SPD
3.32
Representation ID: 28488
Received: 11/07/2014
Respondent: Savills
Agent: Savills
This does not give appropriate consideration to planning balance and the suitability and necessity of affordable housing on that particular site may not be the priority. By being overly restrictive CCC risk under provision in other key areas.
This does not give appropriate consideration to planning balance and the suitability and necessity of affordable housing on that particular site may not be the priority. By being overly restrictive CCC risk under provision in other key areas.
Object
Draft Affordable Housing SPD
3.40
Representation ID: 28489
Received: 11/07/2014
Respondent: Savills
Agent: Savills
This is considered unreasonable. Where it is clear that a development is at the margins of viability through needing to appeal a S106, it is unreasonable to then impose additional legal costs and time on that developer to agree overage. Furthermore, the process will be handled by PINS and as such it is unclear how this will be monitored, administered and ultimately achieved and all for the potential (not real) gain of a very small proportion of income. It is questionable whether in the administrative costs to the authority would outweigh any benefits.
This is considered unreasonable. Where it is clear that a development is at the margins of viability through needing to appeal a S106, it is unreasonable to then impose additional legal costs and time on that developer to agree overage. Furthermore, the process will be handled by PINS and as such it is unclear how this will be monitored, administered and ultimately achieved and all for the potential (not real) gain of a very small proportion of income. It is questionable whether in the administrative costs to the authority would outweigh any benefits.
