Object

Representation ID: 8453

Received: 24/03/2020

Respondent: Letchworth Garden City Heritage Foundation

Agent: Planning Matters

5.2.22 - Details of how the commuted sum will be calculated should be provided: at the present time it is unclear and could be open to inconsistency.

5.2.25 & 26 - It is unclear why the basis for commuted sum payment is based solely on a 2-bedroom house. Further calculations based on smaller and larger homes should also be provided for transparency and factors possibly influencing this, such as labour and material costs, identified.

5.2.30 - The costs related to such provision may be higher and have a negative impact on scheme viability and it should be recognised that this may lead to a reduction in the overall provision of affordable housing sought.

5.2.33 - Where an identified need exists within a location specific enough to warrant affordable housing requirements, the commuted sums should be utilised in that area to the benefit of those in need.

5.2.35 - The wording of the text creates ambiguity and clarification is needed. We are concerned that this text does not support the provision of socially rented accommodation for smaller accommodation, which the Council’s evidence shows has a particularly high need. It is our view that socially rented accommodation should be promoted and provided if scheme viability allows.

5.2.42 - Were the LPA confident in NPPF’s definitions they should replicate them within the text for ease of reference. This should also reflect amendments to the Local Plan, where there is recognition of Community Land Trust and other community and co-operative providers, which are playing a greater role in affordable housing delivery.

5.2.46 - This should include the Letchworth Garden City Housing Needs Survey published last year, which was formulated in partnership with NHDC (Planning & Housing), as well as the main affordable housing providers. It is essential that these studies are of material importance, so that the affordable housing provision reflects local need, as well as District wide requirements.

5.2.54 - SHMAs are reviewed regularly and thus to refer to the current version will cause confusion at later date. Also see 5.2.46.

5.2.55 - Should only remain if it is based on an established, long-term trend for the area. To refer to current circumstances may cause confusion at a later date. The text should only be included if it is reflective of a long-term trend in the area.

5.2.58 - The dispersal affordable housing into small clusters is supported in principle, as well as pepper potting, albeit dependent on the management practices of the registered provider.

5.2.60 - The text is misleading. Policy HS5 states that at least 50% of homes can be built to the M4 (2) Accessible and Adaptable standard and, on schemes where 10 or more affordable units will be delivered, 10% of these can additionally be built to the M4 (3) wheelchair user standard, i.e. 50% of homes will be accessible and adaptable and there is no differentiation between market and affordable housing. The supporting text to the policy states “The highest M4(3) standard should only be applied to homes where the District Council will be responsible for allocating or nominating a person to live in that dwelling”, i.e. most likely to be affordable homes. Albeit the text goes onto state “A modest proportion of affordable homes will be required to adhere to this additional standard.” We also believe that M4 (2 & 3) accommodation should be provided across tenures.

5.2.64 - The provision of affordable units should be maintained as a proportion of total housing delivery. To dictate a minimum affordable housing requirement at the outset can have a negative impact on scheme viability, ignores site conditions identified post Local Plan adoption
and any other community benefits a scheme may deliver. We therefore question the validity of this paragraph.

5.2.71 - we are of the strong view that land held by the Heritage Foundation as a community benefit society, the Council should apply nomination rights for Letchworth residents or people with a close connection. The Heritage Foundation is bringing forward a range of housing sites and the relevant 1995 Letchworth Garden City Heritage Foundation Act requires us to work for the benefit of the communities of Letchworth Garden City. This is reflected in our charitable commitments. We submit that these unique circumstances should be considered in the arrangements included in Section 106 agreements on our freehold.

5.3.1 - Mechanisms should also be in place to prevent these plots to be sold for speculative
development. Further mechanisms should prioritise marketing to local people.

5.3.8 - Question the need to restrict palette choice as this may restrict innovation.