Affordable housing

A revised policy<br>Phase one - overall percentage on all sites allocated for housing development

Supplementary planning guidance

1    Justification
The purpose of this Supplementary Planning Guidance (SPG) is to respond swiftly to the recommendations in the council's Housing Needs Survey and to the Government's proposals for increasing affordable housing provision in Thames Gateway.

2     Evolution of existing policy approach
2.1       Policy H6 in the Gravesham Local Plan 1st Review  (adopted in
            November 1994) relates, in part, to the provision of affordable housing
            and states:-

The council will support proposals in appropriate locations by housing associations, the private sector and other organisations which incorporate -

             (i)  a proportion of dwellings which will be suitable for and affordable by
                  those on low incomes, whether for rent or for purchase.  In 
                  particular,when considering schemes for development on larger sites
                  (in excess of one acre), the council will encourage
                  developers to incorporate such proposals wherever possible.

2.2     Subsequently, Circular 6/98: "Planning and Affordable Housing" and
          Planning Policy Guidance Note 3: "Housing" (March 2000) set
          out government guidance on a range of issues relating to the provision of
          housing.  These are required to be taken into account by regional planning
          bodies and local planning authorities in preparing regional planning
          guidance and development plans and may also be material to decisions on
          individual planning applications and appeals.

2.3       In April 2000, the council adopted a planning guidance note
           (PGN) in relation to affordable housing delivered through planning
           agreement.  The PGN - "Affordable Housing Provision" set out the
           requirement that on all eligible development sites (defined as 25 or more
           units/1 hectare or more in the urban areas and 15 or more units/0.5
           hectare or more in the rural areas), 25 per cent of the units developed
           should be provided for affordable housing.  The expectation was that
           developers would work with one of the council's joint
           commissioning housing association partners to deliver the affordable
           housing.  The range of affordable housing tenures was detailed as
           including social rent, shared ownership and low cost market for sale.  The
           PGN set out that the payment of a commuted sum in lieu of affordable
           housing provision would only be considered in exceptional circumstances.

2.4      The PGN did not have the status of Supplementary Planning Guidance
           but was intended for advice.  It is circulated to housing developers in the
           borough to assist with negotiations on affordable housing.

2.5      The PGN was prepared in conjunction with the first stage deposit version
           of the Gravesham Local Plan 2nd Review.  This was published for public
           consultation in May 2000 and included the following policies on
           affordable housing -

Policy H9 - Affordable housing
On all sites which are proposed for housing development, 25 per cent of residential units shall be for affordable housing, on the basis of the following size thresholds:-

(i)         in the urban area of Gravesend/Northfleet, sites over 1 hectare or where
            25 units or more are proposed;

(ii)        in the following villages, sites over 0.5 hectare or where 15 or more units
            are proposed:-

            Cobham                                  Higham Upshire
            Sole Street                              Lower Higham
            Culverstone Green                  Three Crutches
            Hook Green                           Shorne
            Meopham Green                    Shorne Ridgeway
            Vigo Village                            Lower Shorne
            Istead Rise

Affordable housing is defined as -"Houses for either rent or sale at discount compared to open market value, where a planning agreement ensures that this discount remains available in perpetuity to people identified by the council as being in housing need"

Policy H10 - Payment in lieu of affordable housing
In exceptional circumstances and at the complete discretion of the council, where it can be demonstrated that the inclusion of an element of affordable housing within the development site would be inappropriate, direct provision by the developer of affordable housing on another site may be considered as an alternative.

In such circumstances, the council will expect provision to be made at a level above the specified target for on-site provision, as set out in Policy H9, to take into account the additional scope which is created for market housing to be provided on the original site.

3    Need for revised policy approach

3.1     During 2001, the council commissioned Fordham Research
          (FR) to undertake a comprehensive housing needs survey across the
          borough.  The resulting report identified a need for the provision of 409
          affordable homes each year over the next five years in order to meet
          existing and future housing needs.  The survey demonstrated that the
          overwhelming tenure type required was social rented.  At current rates of
          new build, FR recommended that a 50 per cent affordable housing
          requirement could be justified together with redefined site eligibilty
          thresholds of 15 or more units in the urban areas and two or more units in
          the rural areas (defined as those villages with a population below 3,000).

3.2     The council is very conscious that the provision of affordable
          housing via the planning process is just one of a number of contributions
          required from development sites.  Also frequently required are
          contributions to education, highways, public transport, leisure and social
          and community infrastructure.

3.3     An important consideration in setting the range and level of development
          contributions required from any particular site, is the capacity of the site to
          fund such contributions.  Within Gravesham, the large scale development
          opportunities are associated with brownfield land and consequently it is
          likely that substantial abnormal site costs will need to be factored in.  A
          balance has to be achieved so that the level and range of contributions do
          not render development unviable but at the same time ensure that fully
          sustainable communities are forthcoming.

4    Towards a revised policy - phase one

4.1     A report on affordable housing issues was submitted to the Cabinet on 21
          October 2002, when it was resolved that:-

         1   the proposals as set out in the main report revising the council's
              affordable housing policy be approved, subject to a minimum of 20 per
              cent of all housing on sites in the urban area (66.67 per cent of the
              affordable housing) to be developed for social rented housing;

         2   the key worker housing policy as set out in the main report be
              approved;

         3   officers be authorised to carry out a public consultation exercise on the
              new affordable housing policy and key worker policy prior to their
              being adopted as Supplementary Planning Guidance.

4.2     Further to (3) above, a public consultation exercise was carried out in
          November/December 2002.  In view of the specialist nature of the
          Supplementary Planning Guidance (SPG) it was decided not to invite
          comments from the general public at that stage but rather to target a wide
          range of interest groups, including parish councils, housing associations,
          developers (national and local) and major employers (re: key workers
          policy).  The intention was to keep the SPG under review and to consult
          on it again at the second deposit stage of the Local Plan Second Review.

4.3     The proposals referred to in (1) above, were to increase the overall
          percentage requirement for affordable housing on all suitable sites to 30
          per cent; to set the threshold for affordable housing in the urban area to 15
          units or more or 0.5 hectare or more; and in the rural area, to require one
          affordable house for every two developed.

4.4     It was clear from the representations received that there was considerable
          concern about the revised affordable housing policy being adopted as
          SPG.

4.5     Whilst recognising that the normal approach is to change the policy
          through the local plan process, the council wishes to proceed
          more quickly in view of the recommendations on affordable housing in the
          borough-wide Housing Needs Survey and the government's action plan
          for Thames Gateway set out in "Sustainable Communities: Building for the
          Future" (ODPM, February 2003).

4.6     In order to take matters forward, but also to respond to the concerns of
          consultees, it was proposed that a phased approach be adopted, in
          advance of the publication of the second stage deposit version of the
          Gravesham Local Plan Second Review.

4.7     A further report was therefore submitted to the Cabinet on 17 March
          2003, when it was resolved that:-

          1   an overall percentage figure of 30 per cent be sought for affordable
               housing on all suitable sites and that such a policy, with supporting text,
               be adopted as Supplementary Planning Guidance;

          2   the council's guidance note on affordable housing be revised
               to incorporate policies on urban and rural thresholds, social rented
               housing and key workers, as outlined in the report to Cabinet of 21
               October 2002 (minute 84 refers);

          3   the precise wording of the policies and supporting text be delegated to
               officers.

4.8     Phase one of revising the policy is to increase from 25 to 30 percent the
          overall percentage figure being sought for affordable housing on all suitable
          sites.  As a consequence, the introduction to Policy H9 in the first stage
          deposit version of the Gravesham Local Plan Second Review is amended
          as follows:-

"On all sites which are allocated for housing development, the Borough Council will seek to achieve 30 per cent affordable housing .....".

4.9       The size thresholds remain unchanged.  The remainder of the policy is as
            set out in paragraph 2.5.

4.10     This amendment brings the council's policy into line with that in
            the Dartford Borough Local Plan Review, thus ensuring a consistent Kent
            Thameside approach.

4.11     The overall percentage figure of 30 per cent will now form the basis of
            negotiations with developers and will be taken forward into a revised
            Policy H9 in the second stage deposit version of the Gravesham Local
            Plan Second Review.

5    Towards a revised policy - phase two

5.1       Reference was made in paragraph 4.6 to a phased approach regarding
            changes to the existing affordable housing policy.

5.2       As part of the second phase, the council wishes to see
            amendments to the urban and rural thresholds.  It is proposed to set the
            threshold for affordable housing in the urban area to 15 units or more or
            0.5 hectare or more, whilst in the rural area, for every two houses
            developed, one would be required for affordable housing.

5.3       There is also a desire to concentrate provision on social rented housing,
            as recommended in the Housing Needs Survey.

5.4       Finally, there is the very important issue of key worker housing.  The
            Borough Council's 2002/2007 Housing Strategy sets out the following
            milestone:-

"To establish a definition of 'key worker' and develop a key worker strategy within the Local Plan Second Review process and with supporting Supplementary Planning Guidance (2002/2003)."

5.5       It is proposed that the matters referred to above will be incorporated in a
            revised version of the PGN - "Affordable Housing Provision" (see
            paragraph 2.3).  It is also intended to revisit the definition of affordable
            housing.

5.6       Whilst the policies in the revised PGN will not be enforceable, as they
            have not been adopted as Supplementary Planning Guidance, they will
            form the basis for negotiation with developers and they would be a
            material consideration in the determination of planning applications.

5.7       Furthermore, the revised PGN will prepare the way for the introduction
            of a revised affordable housing policy in the second stage deposit version
            of the Gravesham Local Plan Second Review.