Object

Representation ID: 7363

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

The overall approach to requiring provision of affordable housing on major housing developments aligns
with the provisions of the NPPF (2023) and will support wider housing needs. Given that affordable housing
needs are likely to change over the course of the Plan period and across the borough, it will be important
that affordable housing is provided to meet local needs at the time of development coming forward and taking into account site-specific circumstances.

It is crucial that the Local Plan supports additional overall housing supply, including affordable housing supply, in order to support local needs and contribute to addressing the local affordability issues.

Proposals of a 30% affordable housing threshold for
developments of 10 or more dwellings would equate to the delivery of only 37 affordable housing units
per annum across the Plan period based on the LHN

Indeed, to deliver the required level of affordable housing provision per annum across the Plan period (78
dwellings), as set out in the Housing Market Assessment , there would need to be the delivery of 260 residential units per annum.

It is clear that even a slight upward adjustment in the affordable housing requirements of Policy H7 would
not meet the shortfall and therefore there is a clear need for more market housing to be delivered across
the Plan period in order to help meet this estimated need and facilitate additional affordable housing
provision (as the majority of affordable housing is delivered as part of the delivery of housing sites led by
market housing).

Affordable housing is not only provided through planning gain, but also through wholly affordable sites such as the 40 dwellings under construction at Brooke Road, Oakham on the former allotment site. Consideration of overall housing numbers is a matter for the spatial strategy. The affordable housing provision is the greatest practicable in the context of the Whole Plan Viability Assessment.

Object

Representation ID: 7517

Received: 08/01/2024

Respondent: Wing Parish Council

It is good to see “perpetuity” for local people being included. However, it is not just “affordable” and “rural exception” housing that needs to remain in perpetuity for people with local connections. This policy could be more
imaginatively considered so preventing buy to let landlords block purchasing properties/developments (as in Wing and Uppingham) or properties being purchased as second homes/holiday lets.

New national rules on short-term lets were announced on 19 February. The 'disclaimer' on the Whole Plan Viability Assessment is reasonable and the basis of the report is sound and objective, as set out in its methodology.

Object

Representation ID: 7559

Received: 08/01/2024

Respondent: House Builders Federation

HBF have reviewed the HDH Whole Plan Viability Assessment. HBF suggest that without the clear
and robust evidence of the costs of going further and faster than government policy, the viability assessment is not robust and has not demonstrated any such policies
could be implemented without impacting viability. As such HBF do not believe the current evidence is robust enough to support a 30% affordable housing requirement.
The viability study, and therefore the policy requirements and section 106 asks, must be kept under review as the Plan progresses, especially as the costs of BNG and
Future Homes emerge. HBF also suggests that there is no need to repeat national guidance or any specific
reference to requirements set out in the NPPF and the PPG within the policy.

Comments on viability have been noted.

Policy H7 does not duplicate national policy, but does cross-reference it in places so as to provide justification and context. An appropriate balance has been struck.

Object

Representation ID: 7681

Received: 08/01/2024

Respondent: South Luffenham Parish Council

As older people down shift to smaller housing and to be near public services, does the percentage of affordable housing require review. Unless jobs are to be created near to where affordable housing is to be developed. Rutland house prices are above the National average and there is a net migration to neighbouring Leicester and Peterborough for commuting, so cannot see the demand from 1st time buyers.

When a household in Rutland downsizes from a larger property to a smaller one to meet changing needs, this does not necessarily need an extra dwelling as the original dwelling is normally freed up. If the original dwelling is an affordable one, there is usually an affordable older person's dwelling in the existing stock that can be made available. Policy H4 covers new specialist stock for older people. Some of this specialist stock will need to be affordable, but this is contained within the overall 30% total affordable homes.

Object

Representation ID: 7769

Received: 08/01/2024

Respondent: McCarthy Stone

Agent: The Planning Bureau Limited

Our assessment of the viability of older persons housing identifies a number of characteristics of older persons housing that add additional cost to the typology that have not been included within the Viability Assessment. It is our view that the older persons housing typology should be re-run using all characteristics and if older persons housing is found to not to be viable to deliver 30% affordable housing the policy should be amended to reflect the outcome. This would accord with the typology approach detailed in Paragraph: 004 (Reference ID: 10-004-20190509) of the PPG on viability which states that. “A typology approach is a process plan makers can follow to ensure that they are creating realistic, deliverable policies based on the type of sites that are likely to come forward for development over the plan period.” If this is not done, the delivery of much needed specialised housing for older people may be significantly delayed with protracted discussion about other policy areas such as affordable housing policy requirements which are wholly inappropriate when considering such housing need.

Noted.

Appendix 18 shows that the sheltered and extra-care flats modelled were on brownfield sites.

Object

Representation ID: 7868

Received: 07/01/2024

Respondent: CPRE Rutland

The definition of affordability from the NPPF is acknowledged, but simply meeting this is very unlikely to
result in homes that are genuinely affordable to those most in need. Can the council not go further in some meaningful way?

78 per annum, from the HMA, out of the 123 required, seems like a very high proportion.

– Will affordable homes be required to remain affordable in perpetuity?

A wide range of affordable housing to meet needs will be provided. Affordable rented housing is modelled (capped at the Local Housing Allowance level) as the preferred option for developer-led sites in the Whole Plan Viability Assessment. This is because it is more viable and allows the preferred 2:1 ratio between rented and purchase affordable options and the 30% affordable housing provision to be maintained.

Delivery of affordable housing will be through a combination of developer-led sites with a minimum of 30% provision, wholly affordable sites, and exception sites (under Policies H8 and H9).

There is often a right to purchase rented properties and shared ownership properties outright unless a rural exemption can be put in place. Most occupants do not exercise these rights and the property remains for future occupants. Receipts contribute to new affordable housing provision. Section 106 agreements generally seek for this to be within Rutland. Special protections are in place for rural exception sites (see Policy H8). The 30% discount for First Homes is maintained for future purchasers. If this is not possible for a particular sale because it does not sell within a prescribed period of time, then the national model agreement allows a financial contribution for affordable housing to be paid to the Council.

Object

Representation ID: 7917

Received: 08/01/2024

Respondent: Ryhall Parish Council

H7 Affordable Housing -Support

Same comments as H4

We note the Housing Market Assessment Report 2023 concluding that there is an annual need for an additional 78 traditional affordable housing units per year. How would this be achieved given that we would require well over 50% of planned housing to be affordable within our stated Housing need. Secondly given the ageing population demographic, it would also seem logical to provide more detail on over 60’s housing needs. Given that affordable housing is not considered viable on small scale development, how does RCC intend to manage this strategy?

The 30% minimum provision is the maximum amount which is viable in the context of the Whole Plan Viability Assessment. There is sufficient detail on older people's accommodation in Policy H4 and its supporting text. The HMA also has considerable information on the housing needs of older people, which will inform affordable housing delivery.

Object

Representation ID: 7986

Received: 03/01/2024

Respondent: R S Hurwood

Social Housing
I have been told that Uppingham holds Lyddington’s allocation for social housing: where are the details of this in the plan?

Lyddington and Uppingham are shown as separate areas in the Housing Market Assessment. Uppingham will have more affordable housing built in it than Lyddington because of their different places in the settlement hierarchy, and Uppingham will similarly be expected to meet needs from a wider area within Rutland. It would still be possible for Lyddington to have affordable housing, such as under Policy H8, should sufficient suitable land, need and funding be available.

Object

Representation ID: 8023

Received: 08/01/2024

Respondent: Messrs J, P & P Turner; Scott & Scott (Ayston) Limited; Peterborough Diocesan Board of Finance

Agent: Silver Fox Developments

The evidence base clearly suggests that the local planning authority should be urgently considering an uplift to the housing requirement, as we suggest above, in order to bring forward sufficient affordable housing over the plan period to meet needs. Unfortunately, this is not reflected in the emerging local plan or in its housing requirement.
Accordingly, an upward adjustment should be made to the housing requirement to maximise opportunities for the urgent delivery of affordable housing to meet the very pressing needs in Rutland in this regard, and the clear backdrop of Rutland’s affordability issues.

The high need for affordable housing is noted. 30% affordable housing is the most that can be viably provided in the context of the Whole Plan Viability Assessment. Other sites will be wholly affordable, such as some sites under Policies H8 and H9 and the 40 dwelling site currently being built at Brooke Road, Oakham. Overall housing numbers are a matter for the Spatial Strategy policies.