Comment

Representation ID: 9948

Received: 25/07/2022

Respondent: Barton Willmore

Draft Policy DM1 (Affordable Housing) requires sites of 10 or more residential properties or 0.5 hectares or more to 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. Affordable rents will be 80% of open market rents but a lower percentage should be set where this would preclude access to housing benefit. The draft Policy is supported by the Local Housing Needs Assessment (LHNA) Addendum (April 2022) and Viability Assessment.
In relation to First Homes, PPG states that they are discounted market sale units which “a) must be discounted by a minimum of 30% against the market value” and should account for at least 25% of all affordable housing units delivered by developers through planning obligations (Paragraph: 001 Reference ID: 70-001-20210524). As such, draft policy DM11 currently goes beyond national requirements in terms of the discount of 50% against the market value. In this regard, PPG states that the First Homes Written Ministerial Statement does give local authorities the discretion to require a higher minimum discount of either 40% or 50%, if they can demonstrate a need for this (our emphasis added). In order to demonstrate need, local planning authorities should undertake a housing need assessment to take into account the need for a range of housing types and tenures, including affordable housing tenures. The assessment will enable an evidence-based planning judgement to be made about the need for a higher minimum discount level in the area, and how it can meet the needs of different demographic and social groups.
As part of the evidence base to the BBLP2040, a Local Housing Needs Assessment has been published. This includes an analysis of the impact of introducing a 40% and 50% discount on First Homes as a percentage of affordable housing; and goes on to examine a further potential strategy for meeting the Government requirement for First Homes. The LHNA and draft policy requirements are supported by the viability assessment.
In relation to viability, the Council should ensure that all of the anticipated development costs associated with all the draft Policies of the BBLP40 have been fully taken into account, in line with the NPPF, paragraph 34. This will ensure that the delivery of affordable housing is not undermined. Whilst the Viability Assessment appears to reflect these considerations, it is noted that not all schemes will be viable at any given level of affordable housing, particularly in complex urban areas such as Bedford where schemes may involve a degree of recycling of existing buildings. As such, the wording of the policy should be revised in order to allow for site and scheme specific flexibility (in accordance with NPPF, paragraph 58) where the requirements of the policy wouldn’t be viable.
In addition to the above, and in order to accord with national planning policy guidance relating to First Homes, we consider it essential that the policy is expanded, in order to allow developers to sell a First Home on the open market and remove the title restriction, as long as certain conditions are met (e.g. that the home is marketed for at least 6 months in total and that all reasonable steps have been taken to sell the property) (Paragraph: 011 Reference ID: 70-011-20210524). This will ensure that plots are not left vacant in perpetuity.