Comment

Representation ID: 9575

Received: 20/07/2022

Respondent: L&Q Estates Limited

Draft Policy DM1(S) sets out the Council’s approach to affordable housing. We have a series of comments.
Firstly, the draft policy states that sites of 10 or more residential units, or 0.5 hectares or more will provide 30% affordable housing with 75% of the dwellings as social or affordable rented properties, and the remainder (25%) as First Homes at a 50% discount.
L&Q understands that the National Planning Practice Guidance requires new development to provide 25% of new dwellings as First Homes. However, we do query the proposed level of discount identified. Amongst other criteria, the NPPG requires that First Homes must be
discounted by a minimum of 30% against the market value, and that after the discount has been applied, the first sale must be at a price no higher than £250,000 (in this location). The Guidance goes on to state that a 40% or 50% discount can be set by a local authority where
they can demonstrate a need for this. L&Q, as a Registered Provider of affordable housing, has concerns that the Council’s proposed approach will affect development viability and the subsequent impact on the delivery of more genuinely affordable tenures such as social/affordable rent. Our concerns extend further in this case given that the discount offered is at 50%. Where viability is impacted, this could reduce overall housing supply across all tenures.
Draft Policy DM1(S) goes on to state that ‘Affordable rents will be 80% of open market rents but a lower percentage should be set where this would preclude access to housing benefit.’
L&Q support this policy position as we understand the importance of genuinely affordable rents for residents accessing housing benefit.
It also states that ‘where shared ownership is offered it will be on the basis of a range of initial share purchases from 10 - 80%.’ Firstly, it is highlighted that under the Council’s general affordable homes approach (75% social/affordable rent, and 50% First Homes), there would be no scope for shared ownership products. Secondly, the scale of 10 – 80% represents a
significant range, and we would query whether a model with an 80% initial share would represent a genuinely affordable housing offer. We would also highlight the important and effective role that intermediate tenures such as Shared Ownership play in opening up routes
to home ownership for those with affordability restrictions. This exacerbates our concerns over the absence of products like Shared Ownership and the promotion of First Homes.
Draft Policy DM1(S) goes on to state that on sites providing a mix of affordable and market homes, the Council will expect the affordable housing to be integrated within the market housing and affordable housing clusters should not exceed 15 dwellings and should not be readily distinguishable from market housing. Whilst L&Q promote high quality, tenure neutral
design across all its developments, for flatted developments we require social/affordable
rented to be provided within a dedicated core which enables us to deliver affordable service charges and provide effective housing management for those residents.