EDDC Affordordable Housing Consultation

October 2009

Awliscombe Parish Council's response to EDDC Consultation on an interim Affordable Housing Policy.

East Devon District Council - Consultation Draft of:

Interim Rural Departure Site Policy for Mixed Affordable and Market Housing - October 2009

East Devon District Council is critically aware of the lack of affordable housing in the District and the low levels of affordable housing constructed in recent years. On the 22 September 2009 the Development Management Committee of East Devon District Council approved a policy (as set out below) for schemes in rural areas for a mix of market and affordable housing for a four week consultation period. Any revisions to the policy, made in the light of consultation responses, will be presented to council with a view to gaining adoption of the policy for development management (determination of planning application) purposes.

On adoption any planning application submitted to the Council that falls under the terms/coverage of this policy will be reported to the Government Office for the South West as a departure from adopted planning policy. This policy is not part of the East Devon Local Development Framework but taken in conjunction with adopted Local Plan policy will be a key consideration in the determination of planning applications. Where compliant with this interim departure policy the Council will support the application. The interim policy will be subject to a four week consultation period running from the 1 to the 30 October 2009.

Interim Rural Departure Site Policy for Mixed Affordable and Market Housing

Rural departure sites for development of a mix of affordable and market housing will be allowed provided that the following criteria are met in full:-

(a) The development is well related to and will complement and be compatible with the built form of a

settlement.

(b) The residents of any scheme will have easy walking or public transport access to a range of facilities including a state primary school.

(c) A local housing needs assessment is available showing a need for affordable dwellings in the settlement and/or in surrounding areas and the open market housing will be of a type (whether by size, form, occupancy conditions or other considerations) that will meet a local need currently under-provided for/unavailable in the locality.

(d) At least 66% of all dwellings will be affordable in perpetuity and of these at least half will be available as social rented properties.

(e) Any planning permissions granted under the terms of this policy will be for a period of one year only and the policy will apply (in the first instance and subject to annual review) to the end of year 2010 (unless superseded by an adopted Local Development Framework Policy before this time).

(f) No open market property/properties may be occupied until at least twice that number of affordable

dwellings have been built and occupied.

(g) The development will be for no more than a total of 15 dwellings.

Awliscombe Parish Council's response:

Thank you for the opportunity to comment on  "Interim Rural Departure Site Policy for Mixed Affordable and Market Housing - October 2009". The following comments from Awliscombe Parish Council are in line with and expand on our input to the East Devon Local Development Framework: Issues and Options Consultation from February 2009:

1. We agree with the basic principle and intent of this policy when combined with the points now stated.

1. It is not clear if this policy covers land outside of an existing building boundary. We believe the policy should clearly state that building outside of the existing boundary for a combined affordable and mixed development within a needs assessment is acceptable.

1. This policy does not address AONB, SSSI and other land with a special designation. This could   restrict development opportunities.  This policy needs to positively address this aspect. Development within the criteria could be granted if no alternative existed and then it could be restricted to one development within the area covered by the needs assessment.

1. Empty properties and conversions need to be part of  ‘affordable/social housing policy'. New development (Greenfield) is one aspect.  Availability for conversion of existing properties or barns should become positive statements in an affordable/social housing policy and should be a consideration, possibly a first option, before granting an application for a new development.

1. Whenever this policy is invoked all affected Parishes or Town Councils should be allowed a positive say in a planning application. 

1. Overspill from one area (covered by an assessment need) into another area (also covered by a separate assessment need) requires control to ensure (in the overspill area) a compatibility with the built form of the settlement and to ensure that the overspill's environmental characteristics are not compromised. The assessment needs of an area taking an overspill must also be allowed to continue to be fulfilled.

1. Affordable and social housing needs to be given priority to the families of local people covered by the assessment need.

1. (para. a) While development needs to be well related to existing settlement building, this should not preclude ‘eco' differences where these are proven to be essential and without an alternative to existing building characteristics.

1. (para. b) It's desirable to have ‘easy' access to transport, facilities and primary schooling, but in many rural areas/communities it may not be possible to combine the word ‘easy' with a development opportunity. The exceptions must be a positive consideration within this policy. There is also a need for a better understanding of the word ‘facilities'.

1. (para c) A housing needs assessment is developed and agreed between Parish/Town Council and next tier up of local government (planning authority). It also needs to be regularly maintained and easily accessible. This is the crux of this policy, giving real democracy addressing local needs for local people while not excluding those who can afford the ‘open market'.  It will need to be strictly adhered to by both Parish/Town Councils and the planning authority.   

1. (para d) The 66% affordable may not be of sufficient incentive to either a developer or landowner.  If the developer can show an ‘open book' as to why 66% is not financially viable then a 50 % minimum target could be set as an acceptable bottom line.
   
   It would also be desirable to have affordable ‘perpetuity' to be linked and or prioritised to the housing needs of existing local people.

1. (para e) A period of one year may not give sufficient time to allow an interim policy to move forward. Two years and 2011 would allow more time and encouragement for land to be identified and confirmed as acceptable (see 3 above), establish the (implied) ‘housing association' to manage the properties, establish finance and for Town and Parish Councils to first complete and agree a housing needs assessment.

1. (para f) A developer may feel that this is too restrictive and may be put off from even starting a development. A fully established ‘housing association' or other management body could be the only criteria needed in this paragraph.

1. (para g) Limits should be set through a combination of housing needs assessment and available land.