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Housing Chapter Summary Comments

 

H1: Strategic Housing Provision

H2: Provision of Affordable Housing

H3: Affordable Housing Exception Sites

H4: Adaptable and Accessible Dwellings

H5: Older Persons' and Specialist Housing Provision

H7: Self and Custom Build Homes

H8: Houses in Multiple Occupation (HMOs)

H10: Gypsies, Travellers and Travelling Showpeople

H11: Development Proposals within Solent Breezes Holiday Park

Representations on Policy H1: Strategic Housing Provision

Number of representations on policy: 53

Objection: 39

Support: 5

Comment: 9

Objections

The housing need figures in the SHMA are flawed and too low. No adjustment for household formation suppression, concern economic led assumptions are not correct, concern as to why job growth forecast is not accounted for, market signal uplift is insufficient and requirement should instead be in the region of 486 dwellings per annum. (Barton Wilmore).

The OAN is based on out of date 2012-based subnational population projections. This should be updated and HCC data shows an increase in population across all age groups, a pattern to be repeated at the sub-regional level. (Turley on behalf of Southampton Solent University).

Notwithstanding the 7% uplift to OAN it does adequately reflect the neds of the borough and wider needs in PUSH. Standard methodology sets a higher requirement and unmet need from Gosport, Portsmouth and Havant in particular, need to be considered. With standard methodology requirement and unmet need the housing requirement should be in the region of 635 dpa. (Persimmon Homes).

The Council have a duty to meet the needs of the wider Housing Market Area(s), in particular the cities of Southampton and Portsmouth. (Barton Wilmore).

The Council need to fine over 5,000 additional dwellings to take account of Standard Methodology, unmet need, an overestimation in windfall (large sites in particular) and the inclusion of 3No. Local Plan sites that are questionable in terms of being developed. An early release strategy is needed. (Persimmon Homes).

The use of a stepped trajectory/requirement delays delivery until the latter part of the plan (Turley on behalf of Reside Development Ltd., WYG on behalf of Bargate Homes and Barton Wilmore). The Newlands site would help alleviate this need and provide short term delivery. (Barton Wilmore).

The use of a stepped trajectory/requirement delays delivery until the latter part of the plan which goes against the PPG intention to have any shortfall addressed in the short term. It is simply a mechanism to minimise the backlog. (Gladman Developments Ltd. & Home Builders Federation).

The stepped trajectory/requirement raises concern as to whether the Council will be able to deliver a 5YHLS and whether 620 dwellings per annum is achievable in market terms and when considering supply chain matters bearing in mind the peak annual delivery rate was 581 for one year in 2006/07. (Pegasus Group).

The 5YHLS position is not being calculated using the Sedgefield method as suggested in the PPG and also uses 420 per annum rather than 455 per annum. (WYG on behalf of Bargate Homes and Pegasus Group).

The introduction of the stepped trajectory/requirement will have a detrimental impact on affordable housing delivery. (Turley on behalf of Reside Development Ltd.).

The delivery rates for Welborne Garden Village are optimistic and the Cranleigh Road appeal Inspector was clear Welborne would not deliver a significant number of new homes in the 5YHLS period. (Barton Wilmore). Delivery from Welborne has been continually revised downward and the 3,840 dwellings from Welborne in the plan period is considered optimistic. (WYG on behalf of Bargate Homes and Pegasus Group).

The plan has not been positively prepared as it does not seek to address the emerging Standard Methodology housing need figure and it will not be submitted within the transition period time frame. (Miller Homes).

Although the increase in housing requirement is welcomed it is important that the Council consider the implications of the Standard Methodology. The Local Plan should be flexible to meet increased uplift. (Turley on behalf of Reside Development Ltd., Persimmon Homes and WYG on behalf of Bargate Homes).

The housing need figures in the SHMA are flawed and too high potentially leading to an over-provision of need. Calculations used are projections based on assumptions, conjecture and theory. The ONS have had to correct their forecasts for future levels of fertility, mortality and net migration (with a downward trend in population forecasts).

Objection to the principle of the number of new homes. Too many with insufficient infrastructure/roads. The PUSH work on housing need has a part to play but it is for FBC to have the last word on the strategy.

The housing need numbers used are far too high given that the population in 2036 is projected to be around 13,000 greater and planning housing numbers are 11,300. This is almost one person per property. Brexit may also have implications with decreased immigration.

The policy should include a clause requiring more 1 and 2 bedroom properties and more to support young people trying to get on the property ladder. Too many of the homes getting built are 3 and 4 bedrooms.

Objection on the basis that there is no understanding as to how the quantity of the houses required was calculated and then subsequently amended.

Homes are not affordable and many bought as 'buy to let'.

The PUSH Spatial Position Statement expects there to be a shortfall of 6,300 dwellings on the mainland until 2034. This shortfall needs to be addressed prior to submissions of the Local Plan. (WYG on behalf of Bargate Homes).

The housing provision goes against the accepted concept that any major housing development would be at Welborne. Development at Welborne should be brought forward more quickly. (Fareham Constituency Labour Party).

Too much emphasis on meeting government targets rather than true town planning.

Establishing housing need should be left until after Brexit as this may change things considerably.

The policy should include a clause banning second home ownership (as done in St. Ives Cornwall).

The population increase should be slowed to reduce housing need.

If we need new housing so badly then why are the new build homes not selling?

The only type of housing that should be built is Council [affordable] housing.

Support

Support the Draft Local Plan 2036 in that it marginally exceeds OAN and also meets the requirements of the PUSH Spatial Position Statement. Support for this policy approach follows a constructive meeting under Duty to Cooperate obligations held in June 2017. (Eastleigh Borough Council).

Note PUSH OAN and Spatial Position Statement requirement is exceeded. Support intention to provide flexibility, to provide greater certainty in meeting housing requirements, and incorporate the accelerated delivery effectively brought forward by the PUSH SPS. (Test Valley Borough Council).

Support the provision of additional housing and its potential to help young people access a home.

Understand and support the need for homes and given the delays to Welborne the Council have done well to identify sites to meet the current target. Believe that there should be no further encroachment as breathing space and resources for wildlife are needed.

Support the housing building programme.

Support paragraph 5.25 and not prescribing a specific mix.

Comment

A detailed housing trajectory should be included in the plan showing delivery site by site.

Noted that FBC is seeking to identify sufficient housing sites to meet its need in the PUSH SHMA 2016 update but this would not meet the need proposed under the Standard Methodology. No stone should be left unturned to meet this new need. (Havant Borough Council).

Note PUSH OAN and Spatial Position Statement requirement is exceeded. Additional provision on new homes welcome with regard to environmental constraints that limit capacity to address the needs of the Southampton HMA in the west of the HMA. More homes will be needed for Fareham under the standardised methodology. (New Forest District Council).

In light of the potential new standard methodology FBC should consider whether there is the potential for any additional housing sites which are suitable, available and achievable. (Gosport Borough Council).

Noted that the Draft Plan meets the housing requirement set out in the PUSH Spatial Position Statement but it should actively seek opportunities to identify additional housing potential to address the shortfall. (Winchester City Council and Portsmouth City Council).

It may be necessary to plan for a higher housing requirement to meet the Standard Methodology. (Winchester City Council).

Recognise that the Draft Plan meets the SHMA OAN (2016) by over 7% and that the sources of housing supply exceed the H1 requirement of 11,300 dwellings. Important to recognise that the PUSH Spatial Position Statement (paragraph 5.30) identifies a shortfall of 6,300 dwellings (shortfall greater in the Portsmouth HMA than Southampton HMA). The overprovision in the Draft Plan reduces the mainland shortfall by 800 dwellings but if the remaining shortfall cannot be demonstrated elsewhere than the Fareham plan may be deemed unsound. (Gosport Borough Council).

Currently there is a lack of clarity of why the PUSH Spatial Position Statement and the PUSH SHMA (2016) figures vary. (CPRE).

Comments relating to the emerging Standard Methodology and how it effectively incorporates an oversupply to need to bring house prices down which is a simplistic approach to house pricing that ignores other factors. (CPRE).

Under the PUSH OAN or Spatial Position Statement it appears that Fareham are expected to take more than its own indigenous need should suggest. (CPRE).

The housing allocations only slightly exceed the housing requirement which does not enable sites to be excluded without causing problems with the overall housing supply. (The Fareham Society).

The Welborne development was originally a separate target to the rest of the borough. It is not clear at what point the figures from Welborne were integrated into the borough wide figure.


Representations on Policy H2: Provision of Affordable Housing

Number of representations on policy: 26

Objection: 8

Support: 3

Comment: 15

Objections

Affordable housing is not affordable for people on benefits, living in hostels and even for many working young people.

The opportunity for developers to push viability arguments and seek provision less than the policy requirement is too strong. The policy should be amended to reflect the authority's absolute determination to obtain 30% affordable housing.

It is not considered appropriate to be seeking a contribution from older people's accommodation towards affordable housing. This is a specialist provision which is already making an important contribution to the specialist housing needs of Fareham. (Gladman Developments Ltd.).

Paragraph 5.15 (clawback clause) is contrary to PPG which makes it clear that 'planning applications should be considered in today's circumstances' unless a scheme phases over the medium/long term. Also in other guidance. This proposed review/clawback mechanism should not apply to single phased development. (McCarthy and Stone Retirement Lifestyles Ltd).

The affordable housing requirement applying to ageing care or older persons housing should be made clear that it only applies to accommodation falling within Use Class C3 and not C2. C3 is already more viable than C2.

As all the properties built are 3 or 4+ bedroom they will not be affordable. Lack of affordable housing provided in general whereby it is not truly affordable.

Concern whether homes will be provided for local people first.

Support

Build affordable housing in all areas to support young/working adults onto the property ladder.

Support the acknowledgement of the 11 or more unit threshold for affordable housing as per PPG. (WYG on behalf of Bargate Homes & WYG on behalf of Linden Homes).

The 30% requirement is well evidenced and considered robust. (WYG on behalf of Bargate Homes & WYG on behalf of Linden Homes).

The acknowledgement of viability is welcomed and enables sufficient flexibility in the policy approach. (WYG on behalf of Bargate Homes).

Support the requirement for 10% to be affordable home ownership.

Comments

Greater clarity is required on the 10% home ownership required and how this affects the notional 65:35 split. Greater clarity on tenure split required. (WYG on behalf of Bargate Homes & WYG on behalf of Linden Homes).

An upward adjustment in the overall housing figure will help address the specific affordable need. (Persimmon Homes)

Support the underlying evidence base but do not consider the policy to be ambitious enough, and a lower threshold than 11 dwellings should be set, perhaps on a sliding scale. (CPRE).

Support the intention to provide affordable housing but would encourage provision closer to the existing target of 40% on strategic sites. (Public Health England in Hampshire County Council response).

Gosport has been able to achieve 40% affordable provision on numerous sites, FBC may wish to consider seeking a higher proportion of affordable housing. This may require reassessing the assumptions made as part of the viability evidence. (Gosport Borough Council).

Paragraph 5.18 requirement to start negotiations at a 65:35 mix is a pragmatic guideline but recognition of other tenures (such as the hybrid tenure of rent to buy) should be acknowledged and flexibility built in.

There is not enough transparency in the number/scale of affordable housing that a developer ends up providing.

More higher density low cost housing is required.

It is not clear what percentage of social housing will be provided. Any provided should remain as social housing forever.

Affordable housing should be state owned to ensure it remains affordable.

Site omitted from the plan could make a policy compliant and provide for the early delivery of affordable homes. (in relation to application for a site at Old Street, Stubbington – WYG on behalf of Bargate Homes).

Site omitted from the plan could provide approximately 20 affordable homes. (Former Orchard on the Wise Estate).


Representations on Policy H3: Affordable Housing Exception Sites

Number of representations on policy: 1

Objection: 0

Support: 0

Comment: 1

Comment

Welcome and support criterion (c) but would prefer it to be reworded to 'it is sensitively located and designed to reflect the character of the neighbouring settlement, to minimise any adverse impact on the landscape, and, if relevant, the Strategic Gaps, and to avoid any adverse impacts on the significance of heritage assets'. (Historic England).


Representations on Policy H4: Adaptable and Accessible Dwellings

Number of representations on policy: 7

Objection: 2

Support: 0

Comment: 5

Objections

Concern that sites HA1, 3 and 7 do not adequately address the requirements of Policy H4.

Concern that there is a lack of reference to the type and amount of specialist and older persons accommodation in Site Allocations HA1, 3 or 7.

The Council's own evidence suggests that high levels of owner occupiers 65+ seek to remain in their own homes. The policy is therefore unjustified. (Persimmon Homes)

Comment

Ageing population is an issue in Fareham. It would be useful to consider forecasts of the older population beyond 2011. The HCC Small Area Population Forecasts show that by 2023 a quarter of the population would be over 65. Whilst Public Health supports the requirement to build 15% of new homes to Category 2 Standards, we would suggest the Council be more ambitious and set a higher percentage in order to secure more adaptable dwellings. (Hampshire County Council – Public Health).

Concur with paragraph 5.39 that the full implications of Category 3 provision should be tested due to cost implications. Would suggest the policy includes flexibility to set aside of reduce standards on grounds of viability. (Home Builder Federation) and (WYG on behalf of 3 landowners).


Representations on Policy H5: Older Persons' and Specialist Housing Provision

Number of representations on policy: 3

Objection: 1

Support: 0

Comment: 2

Objection

Concern that there are no specific older person housing allocations (Persimmon Homes).

Comment

Disappointing that there is no definitive or robust plans to provide warden controlled housing, rest homes and/or nursing homes.

Welcome the inclusion of the policy but suggest revised wording to emphasise the support for these forms of accommodation and lifetime homes. (McCarthy and Stone Retirement Lifestyles Ltd).

Specialist uses are best located in accessible locations (Persimmon Homes)


Representations on Policy H7: Self and Custom Build Homes

Number of representations on policy: 8

Objection: 6

Support: 0

Comment: 2

Objections

Self and Custom Build should be considered as a need on top of Objectively Assessed Housing Needs (OAHN) and therefore Policy H7 is flawed as the implication will be that it diminishes the contribution of sites toward OAHN. Plots could also be left empty if demand does not exist or those on the register don't have the ability to own their own homes. (WYG on behalf of 4 developers/promoters).

The policy should be more flexible, for example proportion of plots should reflect the need demonstrated on the register (including location of need). (WYG on behalf of 4 developers/promoters).

The Adams Hendry evidence (2017) is out of date as the need now far exceeds that in the paper. (WYG on behalf of 4 developers/promoters).

PPG (paragraph 57-025) sets out that Councils should encourage landowners to consider the provision of self-build plots. The approach to this policy goes beyond encouragement and requires provision. If a specific quota is applied then it should be the starting point for negotiation. (WYG on behalf of 4 developers/promoters).

The policy does not give adequate consideration of sites containing listed buildings or where the form of development (i.e. apartment blocks) militates against self or custom build homes. Wording should include 'where appropriate in the context of the form, and scale of development proposed…' (Turley on behalf of Southampton Solent University).

The policy approach will result in an overprovision and is not justified. On large schemes the policy requirement will impact phasing, add S106 complications and slow completions. It will also create problems in reserved matters lapsing. Viability testing also required. (Persimmon Homes).

The need for self and custom build should be met through specific sites (Persimmon Homes).

Comment

Welcome the inclusion of the policy which is in line with current government objectives. Would recommend the policy includes an element of flexibility on the basis of viability to ensure the site is not delayed or prevented from coming forward. The requirement should be tested through Local Plan viability evidence to look at cumulative impacts. Policy needs to include a mechanism whereby if the plots are not taken up within a certain time frame they revert back to market housing.

As part of a planning application, Bargate Homes have agreed to consider the provision of 5% of plots as self/custom build. (WYG on behalf of Bargate Homes).


Representations on Policy H8: Houses in Multiple Occupation (HMOs)

Number of representations on policy: 1

Objection: 0

Support: 0

Comment: 1

Comment

We would welcome the specific inclusion of the need for cycle parking/storage provision for HMOs to ensure it will apply. (Hampshire County Council – Public Health).


Representations on Policy H10: Gypsies, Travellers and Travelling Showpeople

Number of representations on policy: 4

Objection: 0

Support: 1

Comment: 3

Support

Support for bullet point f) especially the reference to sewage disposal. Ensuring this is done properly is essential to prevent pollution of the water environment. (Environment Agency).

Comment

Welcome the policy. However, Winchester City Council have a shortage of travelling showpersons' accommodation and this should be acknowledged as an identified need within the terms of Policy H10 allowing a permissive approach to any sites that come forward. (Winchester City Council).

Welcome and support criterion (c) although we would prefer the criterion to read as '… that cannot be avoided or satisfactorily mitigated and/or compensated;…' (Historic England).

The need for 3 additional pitches in the next 5 years seems rather unlikely that this will be valid [fulfil need] up until 2036.


Representations on Policy H11: Development Proposals within Solent Breezes Holiday Park

Number of representations on policy: 1

Objection: 0

Support: 0

Comment: 1

Comment

Hampshire County Council has a statutory responsibility as the Highway Authority for Public Rights of Way, in addition the Countryside Service manages Countryside Sites and Country Parks throughout Hampshire. HCC Countryside Services therefore request the following amendment to this policy:

d) "Where it can be demonstrated that the proposal will not have an adverse impact on the Solent and Southampton Water Special Protection Area (SPA) and the rights of way network." (Hampshire County Council Countryside Services)



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