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					“A Forum for the Enhancement of the Causeway Coast.”

        8 Marine Drive, Portballintrae, Bushmills, BT57 8RP

    Response to Interim Report on the Review into Affordable Housing

The members of the Causeway Coast Communities Consortium have a particular interest in
this issue. Based as we are in a popular coastal area where house prices have been rising
rapidly because of the demand for second homes and investment properties, we have seen
first-time buyers virtually priced out of the market and this has left coastal settlements with an
ageing population and communities that are no longer sustainable in the long term. Through
our involvement in the Balanced Communities Review Group we are attempting to address
the imbalance in our towns and villages between second homes and permanent residences that
has resulted in the closure of local shops and hotels, the loss of employment and the
disintegration of communities. There is a desperate need for affordable housing for local
people, but the difficulty is that, unless safeguards are put in place, affordable housing will
simply mean cheaper second homes, and even rented social housing purchased by tenants
under the ‘right to buy’ will find its way on to the second home market.

It is against this background that the following comments must be viewed:

Chapter 2

We agree with the definition of ‘affordability’ as a proportion of income that a household
could reasonably be expected to contribute to the cost of housing and consider that this should
not exceed one third of the household income.

Chapter 3

Whilst it may be necessary for the DRD to review the Housing Growth Indicators, especially
in view of the increased numbers of migrant workers, etc., we do not believe that increasing
the housing supply will in itself solve the problem of affordability. In the past few years many
new houses have been built in villages such as Castlerock and Portballintrae, but they have
not become homes for local residents, who cannot afford to purchase them.

Between 1989 and 2001 198 new dwellings were built in Portballintrae and 1198 in
Portstewart. During this period the numbers of permanent homes in Portballintrae actually
reduced by 20. Though the residents of Portballintrae and Portstewart have done research
into the numbers of permanent/second/investment houses in their towns, as far as the
Planning Service is concerned every single unit built within the past 10 years could have
simply been added to the second home/investment stock, as they admit that they have no
control over this. This is bound to affect housing allocations.

We agree with your proposal to bring back ‘voids’ into the housing stock, and consider that
‘voids’ should include properties being held unoccupied by investors in the hope of making
capital gains in the future.

Chapter 4

We agree that ‘key site requirements’ should be extended to provide for affordable as well as
social housing, and we agree that there must be a balance between densification and the
protection of an area’s character and community.

We are, however, strongly opposed to the suggestion that there may be a requirement to
extend development limits in small settlements. In our area this will simply mean that green-
field sites within the AONB will be swallowed up to provide more and more second/holiday
homes, with little or no benefit to the resident population.

We agree that Article 40 of the Planning (NI) Order 1991 should be used more extensively to
require developers, as elsewhere in GB and the ROI, to provide a proportion of affordable
housing. One affordable house in every five built would seem reasonable, although this would
presumably increase the price of the remaining four houses. There would have to be
safeguards put in place to ensure that such houses would be retained as affordable stock when

We have serious reservations regarding the loss of open space within settlements to provide
social housing. With increased densification and smaller gardens, it becomes more important
than ever to preserve public open space wherever possible. Again, there is no guarantee that
social housing will not be sold on into the private sector and become second homes, as has
happened in NIHE estates in Portballintrae, so that the open space will be lost without any
long-term community benefit.

Whilst there may be some merit in the extension of Policy CTY6 of PPS14 to provide for
mixed social and affordable developments of up to 12 properties in the countryside, we are
not convinced that this is desirable.

We strongly support the extension of the statutory response time for planning applications
from 2 months to 3, to reduce the number of non-determination appeals, and believe that
applications should be restricted to one per site to avoid twin/multiple tracking.

We consider that it is important for the Planning Appeals Commission to remain in its present
form, and retain its independence of the planning authorities and departmental control.

Chapter 5

We agree with the selective dezoning of land not being released for housing as a measure to
discourage ‘land-banking’, but we appreciate that, if used widely, this would reduce the total
amount of potential housing sites.

We agree that the Department for Social Development should have greater powers to vest
land for housing purposes.

We fully support the reduction of the duration of planning permissions to three years and we
believe that, when planning permission is granted and work has commenced, a date should be
set for completion of the project. This would avoid the situation, as at Strand Corner,
Portstewart, where a building has remained unfinished for over 17 years.

We are in favour of a comprehensive register of surplus public sector land and agree that the
NIHE should be allowed to release land at less than market value, so long as it can be
guaranteed that this land will be used to provide affordable housing.

We think that the idea of Community Land Trusts is worth considering. With the purchaser
owning the house but not the land, both the householder and the Trust would benefit as the
householder would gain on the equity of the house if the property were sold and the Trust
would retain its interest in the land. The NIHE could adopt the same system when selling
under the ‘right to buy’.

With regard to timber-frame construction, this may succeed in reducing the initial cost of
building a new house, but since, as your report points out, the cost of the land is a major part
of the cost of a house, this may not make an appreciable difference. In our experience on the
Causeway Coast, there is no shortage of houses, but few of them are affordable to those who
need homes.

Chapter 6

We appreciate the success of the NICHA co-ownership scheme, but agree that its
effectiveness has been limited by the rise in the property market and competition from
investors. As this is the only scheme of its kind in Northern Ireland, we consider that it has a
useful role to play in assisting first-time buyers, and that its future could be ensured by
reducing the minimum share that can be purchased and raising the property value limits in
line with average house prices.

We also welcome the suggestion that the NICHA might be permitted to purchase a stock of
homes on a rolling basis for selling through the co-ownership scheme.

We agree that the threshold for Stamp Duty should be raised and possibly indexed for the
future, and we propose that all first-time buyers should be exempted from Stamp Duty.

Chapter 7

We fully endorse the proposal for rating of vacant properties and to increase liability to 200%
on premises that lie vacant for a year or more.

We welcome the suggestion to reduce VAT on refurbishments from 17.5% to 5%, but would
prefer zero rating, as with new-build, since the present system has encouraged the demolition
of perfectly sound houses rather than their conversion, which is the preferred option in

We agree that the introduction of Empty Homes Management Orders in Northern Ireland
would be a desirable measure.

We agree with the suggestion to extend the present NIHE transfer scheme to enable tenants to
change property or location as their requirements change and for cash incentives to encourage
NIHE tenants to transfer to smaller properties, provided that there is no element of
compulsion involved. We also think that a cash incentive to enable social sector tenants to
buy on the open market is worth considering.

We agree that the extension of the claw-back period with the amount of discount to be
reclaimed reducing on a sliding scale over a period of nine years might discourage purchasers
of NIHE houses from selling at a profit to second-home buyers, and would enhance the
income available to finance future housing provision.

Chapter 8

We support the case for registration of all private landlords, incorporating a mediation and
arbitration service, with sanctions for failing to register.

We agree that the NIHE should provide a handbook of good practice for landlords.

We fully support the statutory registration of Houses in Multiple Occupation and are pleased
to see that this is already taking place.

We are not happy with the introduction of rates exemption for HMOs occupied by students as
we consider that any benefit will accrue to the landlord and not to the student tenants.

Chapter 9

We agree that the Planning Service should not be subject to manpower reductions and should
receive further resources, as should the PAC.

We have, however, serious reservations about the suggestion that the Planning Service should
extend its expertise in negotiating commercially with developers. In our opinion this is likely
to weaken the effectiveness of the planners in controlling undesirable forms of development.

Chapter 10

We favour the introduction of Community Planning within the parameters of the Regional
Development Strategy.

We trust that you will find these comments helpful in preparing the final draft of your review.

Ian MacG. Binnie