AFFORDABLE HOUSING DELIVERY STATEMENTS
CONSULTATION REPORT AND SUMMARY OF RESPONSES
2009
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Analysis of Responses to the Consultation on the Affordable Housing Delivery Statements Draft Guidance Background The One Wales coalition agreement gave an undertaking to increase the supply of affordable homes in Wales by at least an extra 6,500 over the next four years. One Wales also identified a key role for locally prepared Affordable Housing Delivery Plans (now called Statements) in achieving the target. Consultation was sought in 2008 on the draft guidance that seeks to implement the One Wales commitment. The Consultation asked for general comments on the proposed document together with three specific questions:Q.1 Do you think Affordable Housing Delivery Statements should be linked to Social Housing Grant allocations and if so in what way? Q.2 How would you aim to use Social Housing Management Grant funding and which housing market Local Authority Partners would you aim to work with? Q.3 How does your Council propose to prioritise the delivery of affordable housing? E.g through a strong retained housing strategy team or through the use of Council land for affordable housing? Overview of Responses 36 responses to the consultation document have been received (reflected as 34 entries in the response matrix as there were 2 joint responses) and the main points raised are outlined below. Some respondents submitted “free standing” responses and did not answer the specific questions set out in the consultation document. In the circumstances every effort was made to link responses to specific areas of the document. Where this was not possible the essence of such responses were fully considered. Comments have not been attributed to organisations in this report because it was not made clear that this would be the case when the Consultation began. Outcome Negative or Positive Response The proposed draft Affordable Delivery Housing Statement has been positively received by the majority of the respondents. However, the responses by local authorities have contained more detailed 2
comments which may be expected as they are at the front line of delivery. Summary of Question Specific Responses Q.1 Do you think Affordable Housing Delivery Statements should be linked to Social Housing Grant Allocations?
Many respondents felt there should be a link between Social Housing Grant and Affordable Housing Delivery Statements because Delivery Statements would show a picture of wider affordable housing need and the role for Social Housing Grant alongside other housing mechanisms would be clear. People also said that planning gain eg s106s were only one of a series of means of achieving affordable housing and it was important to look at the overall approach to housing including the role of Social Housing Grant. “Affordable Housing Delivery Statements should heavily influence the allocation of Social Housing Grant” “Essential to make link with Social Housing Grant” “Linking Social Housing Grant allocations to Affordable Housing Delivery Statements should be tied to local authorities‟ demonstration of their use of available tools” “Affordable Housing Delivery Statements should be linked to Social Housing Grant – levels of need identified in Affordable Housing Delivery Statements should be taken into account” “Necessary as part of the allocation process for Social Housing Grant to give consideration to schemes promoted by Affordable Housing Delivery Statements” Q.2 How would you aim to use Social Housing Management Grant funding and which housing market Local Authority partners would you aim to work with?
The closing date for Social Housing Management Grant bids was 17 October 2008. The aim is for new posts to be established by April 1 2009. There were 6 bids in total from 8 local authorities with 2 local authorities bidding jointly, aimed at implementing the Delivery Statements. Some bids were from single local authorities rather than from partnerships and these are in the process of being considered. Respondents to the consultation were concerned that the posts were time-limited. 3
Most respondents would use Social Housing Management Grant to provide additional staff such as Affordable Housing Enablers, or s106 Officers. Research also played a large part in the Social Housing Management Grant bids. Specifically research into overoccupation, land-banks and empty homes. Q.3 How does your Council propose to prioritise the delivery of affordable housing? E.g through a strong retained housing strategy team or through the use of Council land for affordable housing?
A lot of information came back about what Councils and partnerships were doing to progress affordable housing at a local level. This included use of Council land, strategic partnerships, a robust retained housing function, research into under-occupancy of social housing and how to move people into vacant one-bed flats (obtained through s106s) and out of family sized housing. This gave us a picture of what was taking place locally which was impressive. More General Comments 1. Timescales for consultation are a concern highlighted in responses as were resources to deliver the target number of affordable homes. There were suggestions to extend the four year period of the Affordable Housing Delivery Statements to beyond 1st April 2011. A briefer type of statement has been mentioned by three respondents to date as a way forward. One authority said that where Social Housing Management Grant resources are to be utilised in the employment of s106 officers, it would be advisable for this role to deal with all planning matters. Duplication of work in relation to preparation of Local Development Plans, Unitary Development Plans and Affordable Housing Delivery Statements was also a concern. Working across governmental boundaries is to be encouraged, respondents said. Welsh Assembly Government could explore the possibility of providing incentives for authorities to create regional/sub regional partnerships to deliver targets for affordable housing. These partnerships should be evidencebased and the evidence contained in the Affordable Housing Delivery Statements. 4
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Affordable housing secured via s106 is dependent on the entire site being developed. If financial viability of a development site in its entirety does not stack up, there is a serious risk of the development site not coming forward. Greenfield sites are likely to yield higher affordable housing percentages due to fewer constraints. This could lead to significantly more greenfield land being allocated for housing within Local Development Plans contrary to existing advice in the Ministerial Interim Planning Policy Statement 01/2006 which seeks to use brownfield land in the first instance. In view of the current economic climate and the downturn in the housing market the target of 6,500 may be unattainable. High levels of affordable housing are reliant on high levels of open market housing, therefore incentives will benefit very few of the local authorities.
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Other comments - Housing Local authority comments The proposals were called “burdensome and bureaucratic” “Welsh Assembly Government should publish its own definition of affordability which goes further than Technical Advice Note 2” “….has developed a table of affordable values for assisted home ownership” “Welcome link to empty homes” Several Councils “More appropriate if authorities could provide a short, focused affordable housing delivery statement” “Welcome opportunity to prepare Affordable Housing Delivery Statements” “Endorse Welsh Local Government Association response on Affordable Housing Delivery Statements” “Need to be aware of current market conditions” Several Councils “Timing of Social Housing Grant and Affordable Housing Delivery Statements will not coincide”
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“Push life-cycle of Affordable Housing Delivery Statements back to 2012, extend time for them to be required until 2013” “Risk assessment is required” “Supports principle but wants to adopt Carmarthenshire model” “Opposed to new statutory plan and the additional demands such a duty would bring” “Welcomes principle of Affordable Housing Delivery Statements and has started work on it”
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Non-local authority comments “More flexible approach to be taken so Registered Social Landlords able to build open market housing to cross subsidise the delivery of affordable units”. “Market intelligence should be improved”. “Welcomes four year affordable target. Concerns over Councils‟ ability to resource”. “There should be more housing mechanisms to deliver affordable housing” “Need to support all local authorities; those who are providing affordable housing and those who are struggling” “Population and housing projections do not tie up with Housing Market Assessment”. “The definition of „local‟ should be given more attention. We understand the Welsh Assembly Government is also committed to revising and re-issuing „local‟ criteria”. “Affordable Housing Delivery Statements should contain reference to the important contribution and effective use empty homes make to supply. Welcome introduction of Affordable Housing Delivery Statements and their aim to strengthen local authority response to the need for affordable housing”. “Should recognise Affordable Housing Delivery Statements as one of a range of measures. Further clarification may be needed as to specific roles and responsibilities between housing and planning”.
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Planning comments - Local authority “Affordable Housing Delivery Statements are potentially a useful tool to lower existing adopted plan thresholds in advance of Unitary Development Plan” “Indication that Affordable Housing Delivery Statements would have no status unless linked to adopted Development Plan” “Once Local Development Plans are in place need to remove requirement to produce Affordable Housing Delivery Statements” “Statutory position of Affordable Housing Delivery Statements needs clarification” “Affordable Housing Delivery Statements not necessary for those with adopted Unitary Development Plans and/or Local Development Plans” “Will take resources away from Local Development Plan preparation” “Already have existing Unitary Development Plan and Supplementary Planning Guidance on affordable housing” “Arrangements may confuse the public”
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Non-Local authority organisations “Supports Affordable Housing Delivery Statements as an interim measure pending adopted Local Development Plans”. “Requirement is untimely and over-burdensome and would detract from Local Development Plans preparation. Over emphasis on contribution of planning system. Affordable Housing Delivery Statements should only apply to authorities without adopted Unitary Development Plans. Local Housing Market Assessment would form a material consideration, therefore you do not need Affordable Housing Delivery Statements”. “Wales should have set a national indicative minimum size threshold as in England, 15 units. Affordable Housing Delivery Statements may be a more appropriate and immediate mechanism for the achievement of the One Wales target rather than the Local Development Plans” “Economic viability should be considered as a key factor in the amount of Affordable Housing. S106s are now in decline compared to a few years earlier. Would Affordable Housing Delivery Statements supersede any adopted Affordable Housing Supplementary Planning Guidance? Welsh Assembly Government must look at other ways to provide Affordable Housing given current market conditions”. “No planning status can be afforded to policies in the Affordable Housing Delivery Statements unless Local Planning Authority has an adopted Development Plan or there is an emerging Development Plan”. “The effects of the Welsh language should be taken into account by planning authorities in accordance with their development plan”.
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Conclusion 52% of respondents representing Councils 48% of respondents organisations were were Councils from or other organisations stakeholder did not
11% of respondents stated categorically they support AHDS; these were all local authorities
25% of respondents answered the questions posed by WAG; out of these; 80% said there should be a link between Social Housing Grant and AHDSs; however out of all overall respondents this was 22% of all respondents saying there should be a link. (not all respondents specifically answered the questions). The overall feeling from the consultation appears to be that the proposed Affordable Housing Delivery Statements will be a valuable tool in delivering the target 6,500 affordable homes. The introduction of Affordable Housing Delivery Statements shows the Assembly Government‟s commitment to delivery. Clearly, some councils had reservations regarding Delivery Statements and the resources required to prepare them. There were no detractors from Affordable Housing Delivery Statements outside local government; with the Registered Social Landlord sector and Homelessness organisations being very keen to see Delivery Statements implemented. The introduction of a four year statement makes clear the amount of affordable housing that can be delivered with land and other resources available and encourages a proactive approach. The consultation process has helped to bring about a greater shared understanding of how varying market conditions affect supply, and the Affordable Housing Delivery Statements will reinforce consistency. Further, it will provide an opportunity to build upon and strengthen the planning policy base. The Welsh Assembly Government has taken into consideration responses and revised and clarified the guidance on Affordable Housing Delivery Statements in liaison with the Welsh Local Government Association.
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List of Respondents Local Authorities and Local Authority Organisations 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. Ceredigion County Council City and County of Cardiff Caerphilly County Borough Council Blaenau Gwent County Council Bridgend Council Pembrokeshire County Council Conwy County Borough Council Denbighshire County Council Torfaen County Council Vale of Glamorgan Council Swansea City Council Wrexham County Borough Council Gwynedd Council Neath Port Talbot Council Carmarthenshire County Council WLGA (Welsh Local Government Association) AWCHOP (All Wales Chief Housing Officers‟ Panel)
* NB Respondents 16. and 17. submitted a joint response.
Others 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. 31. 32. 33. 34. 35. 36. Community Housing Cymru Wales and West Housing Association Devco GENuS Pembrokeshire Housing Pembrokeshire Coast National Park Authority Snowdonia National Park Environment Agency Wales South East Wales Strategic Planning Group Wales Council for Voluntary Action Planning Officers Society for Wales Home Builders Federation Royal Institution of Chartered Surveyors Wales Redrow Homes Welsh Language Board Shelter Cymru Chartered Institute of Housing Cymru Welsh Refugee Council Councillor Paul Hinge (Board of Cymdeithas Tai Cantref)
* NB Respondents 6. and 23. submitted a joint response.
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