Affordable Housing Delivery Plan 2008-2011
Summary of Consultation Replies and WCBC Responses/ Modifications
The Affordable Housing Delivery Statement was available for consultation from 12th January 09 to 20th February 09. The document was available to download on the Wrexham County Borough Council website and hard copies were available from the Housing Strategy service. The document was sent to local people and organisations including, Councillors, Council officers, Registered Social Landlords, neighbouring Local Authorities, the voluntary sector, house builders, estate agents and so on.
Theme / Consultee / Consultee comments / WCBC response to consulteeSubmission of document / Anwyl / The documents release may be premature as final Welsh Assembly Government (WAG) guidance is not available until end of January 09. / Following release of final guidance from the Welsh Assembly Government (WAG) minor amendments have been made, including:
The document will now be known as the Affordable Housing Delivery Statement (AHDS).
A template outlining content requirement and final summary table has been applied to the AHDS.
WAG and the WLGA have now clarified the deadline for the AHDS. Each Local Authority is required to submit an AHDS within 6 months of the final WAG guidance being published. However, as WCBC has completed a draft document, it feels that following revisions the Council should adopt the document as soon as possible.
Housing Strategy, Flintshire County Council / There is some confusion about the timing of submission of the AHDS and the draft WAG guidance.
Assessing Housing Need and Affordability / Anwyl / The NE Wales Local Housing Market Assessment provides an inadequate evidence base for these proposals as (i) the data is out of date and based on a different set of economic circumstances and (ii) no testing has been done of viability and (iii) little or no consultation or engagement with stakeholders in line with national guidance. / The current and future demand levels have been established using a combination of different sources, one of which is the NE Wales Local Housing Market Assessment. The Council also considers up-to-date information on house prices, income levels and the housing register. The Council intends on updating the Local Housing Market Assessment in the near future.
Wales and West Housing Association / The Council needs to maintain the Local Housing Market Assessment and ensure it is updated.
The document does not refer to the NE Wales Local Housing Market Assessment 2008 which provides a more robust picture of the current housing market.
Table 10.2 (p.7) suggests a surplus of 3 bed houses in the area. However, Wales and West finds turnover of 3 bed units is limited. Therefore while it appears there is a surplus, demand may best be met by such accommodation.
Home Builders Federation / Economic conditions and the housing market have changed substantially and the Wrexham LHMA 2006 and NE Wales LHMA 2008 are out of date and need to be urgently reviewed if they are to inform the AHDS.
Affordable housing policy, percentage targets and thresholds / Anwyl / Developers are facing increasing development burdens through price of land, planning contributions and availability/ cost of private finance. The affordable housing targets are economically unviable; they do not take into account the current economic climate or site characteristics, location, and marketability.
In setting the affordable housing targets, Wrexham does not seem to have assessed the financial viability of the targets.
We have concerns about the requirement of 100% affordable housing on all windfall sites additional to the Local Development Plan (LDP). The LDP requirement has not been adopted and won't be for some time yet. How does the Council know in the early years or mid-term whether the LDP requirement is going to be met?
Schemes involving 100% AH are going to be difficult to deliver without a benevolent landowner and developer.
Is the Three Dragons Development Appraisal toolkit available to developers (free) to undertake any appraisals? / All targets and thresholds set out in the draft LDP are still being discussed by members and have not yet been finalised. Will also be subject to challenge when the LDP goes on public deposit later this year.
The AHDS has been amended to allow developers to use an industry standard appraisal toolkit rather than a specific brand.
Under approved council policy off site provision is not favoured. However in exceptional circumstances provision would be in the same community council area.
Site density is a planning design issue that will be considered for each site based on individual merits.
The basis of calculation for commuted sums has been amended.
The AHDS has been amended to allow for further development in this area.
The guidance in Wales (TAN 2 para 9.1) states that the affordable housing target should take account of the anticipated levels of finance available for affordable housing and the level of developer contribution that can realistically be sought. It does not explicitly require an economic viability assessment.
The AHDS has been amended to allow for further development in this area.
Wales and West / The proposed target of 50% affordable housing will be a challenge to meet, particularly on smaller sites in rural areas and without the use of social housing grant or other public subsidy.
If off-site affordable housing provision is considered, there needs to be a mechanism to determine how the affordable housing density is calculated. Also where will the off-site provision be located e.g. within a community council area?
An alternative calculation for determining a commuted sum should be considered based on the grant that would have been required to deliver the units e.g. 58% of the WAG Acceptable Cost Guidance figure.
There needs to be a calculation established for the financial contribution for the empty property refurbishment. This requirement could make schemes unaffordable.
Together Creating Communities / The increase in affordable housing targets is positive but may be unfeasible.
Home Builders Federation / The document does not meet with national guidance (e.g. TAN2) or the legal case, Blyth Valley Borough Council v. Persimmon Homes. The affordable housing percentages and thresholds must be justified by the Council, taking into account development viability or should be removed. It is the Council’s responsibility to demonstrate the financial viability of the affordable housing target not the developers.
The affordable housing policy contravenes 3 of the Planning Inspectorate Tests of Soundness:
C2 – it does not have regard to national policy
CE2 – it is not realistic and appropriate having considered the relevant alternatives and/or are not founded on a robust and credible evidence base
CE4 – it is not reasonably flexible to enable it to deal with changing circumstances
If policies are not justified and viable, they will act as a barrier to housing delivery, which in turn could jeopardise the delivery of affordable housing.
The proposal for a financial contribution from each home for the purposes of empty property refurbishment does not say how this amount will be calculated and has not been justified.
Use of Public Sector Land / Planning Policy, Wrexham County Borough Council / The final potential 100% affordable housing sites were not identified in October 2008. Analysis of which sites are suitable will be finalised following Planning Policy Panel consideration, hopefully, towards the end of February. The potential yield may, therefore, be different to that contained in the draft Delivery Plan. / The Council is undertaking an assessment of all Council owned land to establish whether the site is suitable for 100% affordable housing development.
Together Creating Communities / The Council should consider the release of its land for 100% affordable housing units.
Affordable Housing Delivery Target / Planning Policy, Wrexham County Borough Council / There is no allowance for affordable housing to be delivered through rural exception sites.
There is no allowance for affordable housing to be delivered through the use of Council land for RSL development without Social Housing Grant - unless that is already estimated under some of the other categories in the table. / The affordable housing target has been revised to consider the numbers of housing delivered through rural exception sites and that delivered without the use of SHG.
Targets within the AHDS will be monitored within Council Priority on Affordable Housing. This will be implemented in line with the Council’s Project Management Guidelines as a ‘corporately significant project’.
Wales and West Housing Association / The document does not explain how the Council will monitor and measure the amount of affordable housing being delivered over the plan period.
Other comments/ suggestions / Together Creating Communities / AHDS tends to assume a free-flowing housing market and does not take full account of the current economic situation and the resulting freeze in the property market and the near-collapse of new build projects. Any sharp decreases in house prices would result in problems for home owners and landlords e.g. negative equity.
Suggest more partnership working with private landlords to ease supply and demand issues. However, rents must reflect the ability to pay.
The permanent night shelter is welcomed, but there are concerns that funding has only been secured for 3 years.
The empty properties refurbishment project is interesting but £100,000 funding should be increased. / The Council acknowledges that the recession is having a substantial impact on both home owners and house builders. The Council understands that affordable housing may not be sufficiently deliverable through planning contributions on private market developments and is keen to utilise other methods of providing affordable housing e.g. Council owned land and private sector partnerships, these options are being explored.
No additional funding available at present – other options and opportunities will be explored.
Table has been amended to follow final guidance and template issued by WAG.
Joint venture will be open to all RSL’s.
Covered to some extent by the existing Wrexham Housing Alliance this includes RSL’s and representatives from the development sector. The forthcoming Council Priority on affordable housing will set the framework and a successful joint venture arrangement will aim to deliver significant numbers and improve deliverability and value for money.
Housing Strategy section are looking to develop a common housing waiting list – early discussions with RSL’s have taken place but further detailed appraisal work required.
Planning Policy, Wrexham County Borough Council / What is the purpose of the “total housing units” column (and in the table title) in a table that focuses on the projected numbers of affordable homes to be provided.
Councillor O’Toole / Is it possible for WCBC to partner with other Housing Associations e.g. English Housing Associations?
Can the Council establish a single strategic housing partnership to include the Council, Housing Associations and the private sector to create a single housing strategy and delivery programme?
Planning and delivery should be more appropriate and geared to need; a common housing waiting list would help this and make the process more user friendly with a single housing application form to complete. It would also promote partnership working.
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