AFFORDABLE HOUSING READING BOROUGH COUNCIL LOCAL DEVELOPMENT FRAMEWORK - Information to support the Sites and Detailed Policies Document

 
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AFFORDABLE HOUSING READING BOROUGH COUNCIL LOCAL DEVELOPMENT FRAMEWORK - Information to support the Sites and Detailed Policies Document
READING BOROUGH COUNCIL
    LOCAL DEVELOPMENT FRAMEWORK

      AFFORDABLE HOUSING
    Information to support the Sites and
         Detailed Policies Document

                 July 2011

1                        AFFORDABLE HOUSING BACKGROUND PAPER
CONTENTS

1. INTRODUCTION                                                      3

2. POLICY, GUIDANCE AND ADVICE                                       3
   National Policy                                                   3
   Regional Policy                                                   5
   Local Policy                                                      6
                                                                     7
3. RESULTS OF PREVIOUS CONSULTATION

4. CURRENT CHARACTERISTICS AND FUTURE TRENDS                         8

5. POLICY DISCUSSION                                               21

6. PREFERRED APPROACH AND REJECTED ALTERNATIVES                    25
   Preferred Approach                                              25
   Rejected Alternative Approaches                                 26

7. REFERENCES                                                      27

APPENDICES                                                          28

2                                     AFFORDABLE HOUSING BACKGROUND PAPER
1.    INTRODUCTION

1.1   Core Strategy Policy CS16 sets out the strategic affordable housing policy for the
      Borough primarily in relation to sites of 15 or more dwellings. However, in the
      context of then (drafting of the submission document was finalised at the end of
      2006) emerging national policy direction, it provided context for a separate policy
      to enable affordable Policy to be sought on sites of less than 15 dwellings. Policy
      DM6 deals specifically with the provision of affordable housing on sites of less than
      15 dwellings in the context of the guidance in the current version of PPS3
      “Housing” and in conformity with the Core Strategy Policy.

1.2   Reading Borough experiences high levels of need for affordable housing. The
      evidence submitted as part of the submission of the Core Strategy in 2007 (and
      adopted in January 2008) remains valid, certainly in terms of the high levels of
      need for affordable housing in the Borough. The development of small sites make
      an important contribution to the Borough’s housing land supply. Provision of
      affordable housing on such sites will provide a significant contribution to the
      provision of affordable housing in the Borough. Such contributions can be made
      viably, in reasonable market conditions, on small sites, in accordance with the
      thresholds and targets set out in Policy DM6.

2.    POLICY, GUIDANCE AND ADVICE

      National Policy

2.1   Under government guidance in PPS3 (published at the end of 2006), in their Local
      Development Documents, Local Planning Authorities should:

      •      Set an overall (i.e. plan-wide) target for the amount of affordable housing
             to be provided. It should reflect an assessment of the likely economic
             viability of land for housing within the area, taking account of risks to
             delivery and drawing on informed assessments of the likely levels of finance
             available for affordable housing, including public subsidy and the level of
             developer contribution that can reasonably be secured;
      •      Set separate targets for social-rented and intermediate affordable housing
             (RBC current seek 70% / 30%);
      •      Specify the size and type of affordable housing that is likely to be needed
             in particular locations and, where appropriate, on specific sites (set out in
             SPG);
      •      Set out the range of circumstances in which affordable housing will be
             required. The national indicative minimum site size threshold is 15
             dwellings. However, under PPS3, Local Planning Authorities can set lower
             minimum thresholds, where viable and practicable.            Local Planning
             Authorities will need to undertake an informed assessment of the economic
             viability of any thresholds and proportions of affordable housing proposed,
             including their likely impact upon overall levels of housing delivery and
             creating mixed communities.

3                                                 AFFORDABLE HOUSING BACKGROUND PAPER
•         Set out the approach to seeking developer contributions to facilitate off
                      site provision, where such provision can be robustly justified, in lieu of on-
                      site provision (of broadly equivalent value).

2.2         Affordable housing includes social rented and intermediate housing, provided to
            specified, eligible households whose needs are not met by the market. Affordable
            housing should:

                 •    Meet the needs of eligible households including availability at a lost low
                      enough for them to afford, determined with regard to local incomes and
                      local house prices.
                 •    Include provision for the home to remain at an affordable price for future
                      eligible households or, if these restrictions are lifted, for the subsidy to be
                      recycled for alternative affordable housing provision’.

            Social rented housing is:

            ‘Rented housing owned and managed by local authorities and registered social
            landlords, for which guideline target rents are determined through the national
            rent regime. The proposals set out in the Three Year Review of Rent Restructuring
            (July 2004) were implemented as policy in April 2006. It may also include rented
            housing owned or managed by other persons and provided under equivalent rental
            arrangements to the above, as agreed with the local authority or with the Housing
            Corporation as a condition of grant.’

            Intermediate affordable housing is:

            ‘Housing at prices and rents above those of social rent, but below market price or
            rents, and which meet the criteria set out above. These can include shared equity
            products (e.g. HomeBuy), other low cost homes for sale and intermediate rent.’

2.3         Policy DM6 was conceived and drafted to comply with the guidance and definitions
            in PPS3. However, following approval of the draft SDPD by Council on 25th January
            2011, DCLG published a new technical change to PPS3 (on 14th February 2011) in
            order to include the new Affordable Rent product within the definition of
            affordable housing 1. A revised version of PPS3 was published on 9th June 2011, to
            provide technical amendments to Annex B: Definitions, to reflect the introduction
            of Affordable Rent. Affordable Rent is defined in PPS3 as:

                       “Rented housing let by registered providers of social housing to
                      households who are eligible for social rented housing. Affordable Rent is
                      not subject to the national rent regime34 but is subject to other rent
                      controls that require a rent of no more than 80 per cent of the local
                      market rent25, 36.
1
    The draft definition was as follows:

       “Rented housing provided by registered providers of social housing, that has the same characteristics as social rented
       housing except that it is outside the national rent regime but is subject to other rent controls that require it to be
       offered to eligible households at a rent of up to 80 per cent of local market rents.”

4                                                                      AFFORDABLE HOUSING BACKGROUND PAPER
The main wording changes from the draft definition are underlined. PPS3 (2011)
      includes the following footnotes:

             “34 The national rent regime is the regime under which the social rents of
                  tenants of social housing are set, with particular reference to the
                  Guide to Social Rent Reforms (March 2001) and the Rent Influencing
                  Regime Guidance (October 2001).
             35
                Including service charges, where applicable.
             36
                 Local market rents are calculated using the Royal Institution for
                  Chartered Surveyors (RICS) approved valuation methods. The Tenant
                  Services Authority has issued an explanatory note on these:
                  www.tenantservicesauthority.org/upload/doc/RICS_rental_valuation_n
                  ote_20110118140714.doc”

      In writing this, it is not apparent how this product differs from Intermediate rent
      housing in terms of affordability, although it is clear that this is likely to be the
      main product that will be funded by the HCA in the future in terms of grant. There
      will be an ongoing review of any policy implications arsing from this change. There
      will obviously be some implications for the viability of development involving
      affordable housing where grant would have previously been expected.

      Regional Policy

2.4   While the Secretary of State has announced his intention to abolish RSS and this
      forms part of the Localism Bill, RSS will remain part of the development plan until
      that part of the Bill is enacted. Under the regulations, LDF’s have to demonstrate
      conformity with the relevant regional strategy.

2.5   Adopted during Summer 2009, the housing policies in the South East Plan are
      designed to provide the region with an integrated, strategic approach to housing
      provision which supports an urban renaissance, delivers sustainable development
      and which provides everyone with the opportunity of a decent home. Amongst
      various objectives the housing policies seek to, “Secure a step-change in the
      delivery of affordable housing.”

2.6   Policy H4 (Affordable Housing) states that Local Development Documents will
      contain policies to deliver a substantial increase in the amount of affordable
      housing in the region. Local Development Documents will set targets for the
      provision of affordable housing, taking account of the results of housing need and
      market assessments and having regard to the overall regional target that 25% of all
      new housing should be social rented accommodation and 10% other forms of
      affordable housing (Equivalent to a 70/30% split). Where justified by housing need
      assessments, Local Development Documents should specify the tenure of housing
      being sought. There will be a presumption in favour of on-site affordable housing
      provision. To help ensure the delivery of affordable housing, Local Development
      Documents will provide comprehensive policy and guidance on financial viability
      and the role of public subsidy …….” The full policy wording is attached at
      Appendix 1:

5                                                 AFFORDABLE HOUSING BACKGROUND PAPER
The government has announced its intention to abolish Regional Strategies.
         Nevertheless, the South East Plan remains part of the development plan and. SEP
         policies therefore remain relevant to LDF policy development.

         Local Policy

2.7      The Reading Borough LDF Core Strategy contains policy CS16 which states:

              All developments of 15 dwellings and above, or of any alternative lower
              threshold contained in a future adopted Development Plan Document will
              provide 50% of the total number of dwellings in the form of affordable
              housing to meet the needs of the area, as defined in a housing needs
              assessment.

              Affordable Housing is subsidised housing that enables the asking price or
              rent to be substantially lower than the prevailing market prices or rents in
              the locality 2, and which is subject to mechanisms that will ensure that the
              housing remains affordable for those who cannot afford market housing.

2.8      As indicated above, PPS3 provides for affordable housing to be sought on sites of
         below 15 dwellings, where viable and practicable. The council has long considered
         it desirable for thresholds to be reduced to below 15 dwellings. A considerable
         and disproportionate number of applications propose 14 dwellings to avoid
         affordable housing provision. In addition there is no good reason why smaller sites
         cannot viably make a contribution to the significant need for affordable housing
         that exists in the area. Policy DM6 provides a development plan policy to seek
         provision on such smaller sites in a way that is viable and practicable.

2.9      The Reading Borough Sustainable Community Strategy (2008) 3 puts forward a
         community vision and priorities for Reading.

              ‘Our vision is to maintain and improve the quality of life in Reading,
              embracing the challenges of a dynamic, inclusive urban community of the21st
              century. Everyone will have the opportunity to benefit from all that Reading
              can offer. Everyone has a part to play in shaping our future’.

2.10     Decent and affordable housing is a priority in achieving that aim. Chapter 7 of the
         Strategy sets out a vision for housing in the Borough:

              “Reading’s residents will have available to them a range of attractive,
              affordable and realistic housing choices. The housing stock itself will be safe,
              secure, and environmentally sustainable and this, together with a range of
              high-quality housing services, will make a positive contribution to people’s
              lives, both at an individual, personal level and also in terms of their wish to
              live in thriving, stable neighbourhoods. At the broadest level, ensuring that

2
  Planning Policy Statement 3: Housing (PPS3) underpins the delivery of the Government’s strategic housing policy objectives
and the goal is to ensure that everyone has the opportunity to live in a decent home, which they can afford in a community
where they want to live.
3
  Reading Borough Sustainable Community Strategy (2008), see:
http://www.reading.gov.uk/councilanddemocracy/General.asp?id=SX9452-A78364E2

6                                                                    AFFORDABLE HOUSING BACKGROUND PAPER
Reading has a well-housed population will make a very significant contribution
               to the success of the local economy.”

         The Strategy notes that housing is identified as one of the most serious issues
         facing Reading today with affordability being the most obvious problem. A key
         solution is to increase the overall supply of new housing, including widening the
         range of subsidised housing options in all tenures. Priorities for housing in the
         strategy are to increase the overall supply of new housing, including affordable
         housing in all tenures. The LDF is seen as an important tool in achieving this
         increase.

         A draft review of the Reading Borough Sustainable Community Strategy (2011) 4
         revolves around the themes of People, Place and Prosperity. The need for housing
         and affordable housing is crucial to all three themes, and is referred to at various
         points in the draft document.

         Housing Strategy

2.11     The latest Reading Borough Council Housing Strategy, Firm Foundations, covers the
         period 2009-2014 5. The strategy sets out 10 objectives. The planning system is
         seen as relevant to the delivery of most of these objectives but particularly the
         following:

                Strategic Objective 1:
                Ensure the sustainable delivery of new build housing to meet identified
                needs whilst achieving best use of available land.
                Strategic Objective 2:
                Increase the availability of appropriate specialist accommodation for those
                that need it.
                Strategic Objective 3:
                Make best use of existing housing stock within the town.

2.12     The Strategy indicates that planning policy will also be reviewed in relation to
         decreasing the threshold on which affordable housing provision will be requested.
         This will assist the authority in achieving a target of 40% of all new homes in the
         town to be affordable housing, with a target of 50% on all sites subject to section
         106 agreements and above 14 units.

3.       RESULTS OF PREVIOUS CONSULTATION

3.1      The consultation carried out in the early part of 2010 attracted several
         representations on SDPD Draft Policy DM6, making the following points:

           •    The council needs to be clear that the policy is backed up by appropriate
                evidence on viability;

4
 Draft Reading Borough Sustainable Community Strategy (2011), see http://www.reading2020.org.uk/library/public/file88/
5
 Firm Foundations see:
http://ww2.reading.gov.uk/documents/Housing_and_Benefits/Strategies%20and%20Plans/HousingStategy2009.pdf

7                                                                 AFFORDABLE HOUSING BACKGROUND PAPER
•    Objections to the reference to an open book approach to determining
                viability in relation to individual applications;
           •    Objections to the policy requiring for the provision of affordable housing to
                be dispersed throughout the development. This is seen as impractical in
                terms of management and unreasonable from a market perspective;
           •    There is some contradiction in the policy that needs to be clarified.

3.2      The point about the wording of the policy being unclear is accepted and some
         wording changes have been made to, hopefully, add clarity to the policy. The
         Council’s responses to the remaining points generally note the comments but do
         not accept that they warrant any change in the policy.

3.3      The Second Pre Submission consultation undertaken during February, March and
         April 2011, produced very similar comments to the 2010 consultation from the
         same parties.

4.       CURRENT CHARACTERISTICS AND FUTURE TRENDS

         Population Forecasts including household growth and types

4.1      The 2008 Mid Year Population Estimates indicated a population of 149,100 for the
         Borough at 2008. It forecasts a population of 161,400 at 2016 and one of 173,000
         at 2026 6. Based on these projections, ONS produced projections for total
         households which were published in November 2010. For Reading households are
         forecast to grow from 58,000 in 2006 to 66,000 in 2018 and to 71,000 in 2026 7.
         Average household size is forecast to fall from 2.48 to 2.34 between 2006 and
         2016.

4.2      2011 population projections for Reading prepared by the Greater London Authority
         Intelligence Unit 8 are based on ONS assumptions but also relate population growth
         to forecast housing supply. They use the Council’s own housing trajectory/forecast
         of housing completions as the basis for the forecast housing supply. The table In
         Appendix 2 provides the resulting projections for Reading. These projections
         indicate that there will be a population of 166,570 in 2016 (compared to 151,324 in
         2006) and 181,417 in 2026. They forecast 69,200 households in the Borough in
         2016 (compared to 61,900 in 2006) and 75,900 in 2026. The GLA projections
         therefore indicate a faster rate of population and household growth for Reading
         compared to the ONS forecasts.

         Housing Data and Information

         Housing in Reading
4.3      Reading’s continued economic success means that there is high demand for
         housing, resulting in higher than national and regional average house prices that
         have fallen relatively little even in the current economic recession. Because of

6
   Table 2c at: http://www.statistics.gov.uk/downloads/theme_population/snpp-2008/InteractivePDF_2008-basedSNPP.pdf
7
  See Table 406 at:
www.communities.gov.uk/housing/housingresearch/housingstatistics/housingstatisticsby/householdestimates/livetables-
households/
8
   Berkshire Demographic Projections: 2010, GLA Intelligence Unit, February 2010

8                                                                AFFORDABLE HOUSING BACKGROUND PAPER
this, the property market has become increasingly inaccessible to those on low to
         middle incomes, due to the shortage of affordable housing 9.
4.4      A profile of housing in Reading:
            •    Number of dwellings: 64,388 10
            •    Tenure
                 o Homes owner occupied: 35,639(55.3%)
                 o Rented from a private landlord: 17,806 (27.4%)
                 o Houses of Multiple Occupation (HMO) – 5.5% (1.4% Licensable)
                 o Student accommodation: 1.9% (1254)
                 o Rented from a RSL: 3,762 (5.8%)
                 o Rented from Reading Borough Council (Including those in the PFI Area):
                    7,178 11.1%
                 o Miscellaneous: 0.4%
            •    74% of Reading households live in detached, semi-detached, or terraced
                 houses, while a relatively high proportion (18%) live in flats or apartments.
            •    Reading ranks 3rd in the South East 11 for the percentage of homes without
                 sole use of bath/shower and/or toilet, and 4th in terms of ‘overcrowding’ 12.
                 Almost 8% of Reading households lack central heating.
            •    Nearly all new homes built in recent years have been built on land that had
                 been previously developed (“brownfield” sites). 13
            •    Households on the Council’s Housing Register: 7852 (April 2011), compared to
                 5993 (April 2010). Up from 4834 (April 2009). As can be seen Housing
                 registrations are growing rapidly in the current climate.

         Reading Housing Stock

4.5      The Housing Stock in Reading was estimated at 64,759 at 31/03/2010.
         Approximately 17.5% of the stock is owned by the local authority or Registered
         Social Landlords (now known as Registered Providers).

         House Prices

4.6      Information from the Land Registry plots the changes in house prices in Reading
         Borough since 2000.

9
  Housing that is available below market rent and will include shared ownership and sub-market rent properties (such as key
worker accommodation) as well as those available at social rent (Housing Associations, council housing).
10
   Berkshire Demographic Projections: 2010, GLA Intelligence Unit, February 2010.
11
   out of the 67 local authorities in the South East (excluding London)
12
   assumes that every household requires a minimum of two common rooms
13
   Berkshire Joint Strategic Planning Unit, Planning Commitments for Housing, annual publication.

9                                                                   AFFORDABLE HOUSING BACKGROUND PAPER
Reading Average Residential Property Prices
                                  Semi-                          Flat
        Year      Detached                     Terraced                        Overall
                                detached                     /Maisonette

      June          £248,365     £139,585       £113,103       £102,689        £132,129
      2000

      June          £256,300     £144,044       £116,717       £105,970        £136,350
      2001

      June          £300,183     £168,707       £136,701       £124,114        £159,695
      2002

      June          £324,315     £182,270       £147,690       £134,092        £172,534
      2003

      June          £338,798     £190,410       £154,286       £140,080        £180,239
      2004

      June          £352,472     £198,095       £160,513       £145,734        £187,513
      2005

      June          £363,524     £204,306       £165,546       £150,303        £189,241
      2006

      June         £400,837     £225,277       £182,538       £165,731        £208,666
      2007

      June         £411,252     £231,130       £187,280       £170,037        £214,087
      2008

      June         £347,898     £195,524       £158,430       £143,842        £180,963
      2009

      June         £377,804     £212,332       £172,049       £156,208        £196,675
      2010
                   £373,931      £210,155       £170,285       £154,606       £194,589
      April
      2011

      %             50.56%        50.56%         50.56%         50.56%          50.56%
      change
      2000-
      2011

4.7   The more detailed changes in average house prices along with changes in sales
      volumes are illustrated in the graph below. They show that despite a halving of
      sales volumes from their height, house prices remain relatively close to values not
      long before the recession, perhaps reflecting a low supply of housing for sale.
      Since April 2009, property prices have continued to increase steadily, albeit
      relatively flatly over the recent 12 months, despite the current economic situation.
      As can be seen from the figures, Reading remains a high house price area. It
      follows that affordability remains a major issue for the borough. It is noticeable

10                                                AFFORDABLE HOUSING BACKGROUND PAPER
that prices have started to fall again since November 2010, albeit very slowly,
     reflecting continuing uncertainty in the market.

                 Detached        Semi-        Terraced     Maisonette/Flat     All
                    (£)       Detached (£)       (£)            (£)            (£)
      Apr-09      344,467       193,596       156,867         142,424        179,130
      May-09      344,725       193,741        156,985        142,531        179,264
      Jun-09      347,992       195,577       158,472         143,881        180,963
      Jul-09      355,641       199,876        161,956        147,044        184,941
      Aug-09      358,970       201,747       163,472         148,420        186,672
      Sep-09      359,294       201,929       163,619         148,555        186,841
      Oct-09      359,229       201,892        163,590        148,527        186,807
      Nov-09      357,127       200,711       162,633         147,659        185,714
      Dec-09      364,325       204,756       165,910         150,634        189,457
      Jan-10      367,932       206,783       167,553         152,126        191,332
      Feb-10      373,371       209,840        170,030        154,375        194,161
      Mar-10      378,528       212,738        172,378        156,507        196,843
      Apr-10      373,194       209,740       169,949         154,301        194,275
      May-10      377,571       212,201        171,942        156,111        196,554
      Jun-10      377,804       212,332       172,049         156,208        196,675
      Jul-10      378,340       212,633        172,293        156,429        196,954
      Aug-10      380,089       213,616       173,089         157,152        197,865
      Sep-10      378,759       212,868       172,483         156,602        197,172
       Oct-10     379,237       213,137        172,701        156,800        197,421
       Nov-10     379,120       213,071       172,648         156,752        197,360
       Dec-10     375,116       210,821       170,825         155,096        195,276

11                                               AFFORDABLE HOUSING BACKGROUND PAPER
Jan-11     370,479          208,215    168,713          153,179     193,035
             Feb- 11     365,929          205,657    166,641          151,298     190,708
             Mar-11      369,190          207,490    168,126          152,646     192,122
             Apr- 11     373,931          210,155    170,285          154,606     194,589
             Source: Land Registry 2011

                                     House Price Change April 2009-Apr 2011
                                            Average All Dwellings

     200,000
     195,000
     190,000
     185,000
                                                                                        All   (£)
     180,000
     175,000
     170,000
     165,000

              Jun-09
         Apr-09    Aug-09    Dec-09
                        Oct-09    Feb-10    Jun-10
                                       Apr-10              Dec-10
                                                      Oct-10
                                                 Aug-10         Feb-11

           Private Rent Information

4.8        There is no authoritative data on average market rents in Reading. A number of
           the letting agents in the town provide data on the average rent that they are
           letting particular properties. An exercise to average a number of these provides
           the following information:

           Average monthly cost of a privately rented property in Reading (July 2011,
           Home.co.uk 14):

                         ƒ   1 bed properties:                 £633
                         ƒ   2 bed properties:               £1,021
                         ƒ   3 bed properties:               £1,056
                         ƒ   4 bed properties:               £1,101
                         ƒ   5+ bed properties:              £1,218

           This compares with similar data for April 2009:

14
     www.home.co.uk

12                                                     AFFORDABLE HOUSING BACKGROUND PAPER
ƒ    1 bed properties:                £654
                    ƒ    2 bed properties:                £787
                    ƒ    3 bed properties:                £884
                    ƒ    4 bed properties:               £1203
                    ƒ    5+ bed properties:              £1976

       As can be seen the cost of 2 and 3 bedroom properties have increased dramatically
       in 2 years whereas for the larger sizes of property, rental levels have fallen fairly
       dramatically

       Affordable Housing Completions

4.10   Information on affordable housing provision since 1990 is contained in Appendix 3.
       Provision since 2001 is set out below in Table 4.

                          No of affordable unit          HSSA Affordable Housing
                          completions via planning       Completions including
        Year              permissions (on fully          Homebuy and non
                          completed sites).              planning provision.
        2001/2                                                      173
        2002/3            51    +£188,000                           149
        2003/4            30                                        302
        2004/5            195   +£100,000                           360
        2005/6            309   +£372,000                           311
        2006/7            91    +£80,000                            180
        2007/8            210                                       302
        2008/9            229                                       294
        2009/10           121                                       184
        2010/11

        Total             1236                                      2255
        Divide      by    155 dwellings per annum.      251 dwellings per annum.
        number      of
        Years

4.11   The figures above in column 2 are taken from planning records and trace
       applications subject to Section 106 agreements for the provision of affordable
       housing. Numbers in relation to each individual scheme have then been cross
       checked against Housing Section records for provision on a scheme by scheme
       basis. The figures do not include any housing bought for the purpose of renting or
       reselling as affordable housing or affordable housing resulting from schemes such
       as the Homebuy or deposit guarantee schemes. They therefore solely reflect
       affordable housing provision resulting directly from the operation of planning
       policy and agreements under Section 106.

4.12   For comparison, the total numbers of affordable housing provided in the Borough
       each year, as recorded on HSSA (Housing Strategy Statistical Appendix) returns to
       DCLG and its predecessors provides the estimate in column 3 for total affordable
       housing provision in the Borough. The Council’s Housing Section produce their own
       annual provision figures derived from their liaison work with partner organisations

13                                                   AFFORDABLE HOUSING BACKGROUND PAPER
including partner registered providers. This includes details of provision arising
       from non planning provision such as instances where registered providers purchase
       new or second hand properties on their own account. It also includes houses
       purchased as a result of the Homebuy initiative, the Deposit Guarantee Scheme
       and other non planning additions to the affordable housing stock.

4.13   As can be seen from the results in the table of affordable housing completions
       existing local plan policies and their interpretation through the SPG on Planning
       Obligations, and the adopted LDF Core Strategy, along with the separate efforts of
       the Council’s Housing and Planning Sections, have been very effective in producing
       new affordable housing in the Borough over many years.

       Right to Buy

           Number of dwellings
           sold under Right to
           Buy
                                  Outturn    Outturn    Outturn    Outturn   Outturn    Outturn
                                   2005       2006       2007       2008      2009       2010
           17. Number of           45         13              17        13          4         10
           dwellings sold under
           RTB

           An average of 17 dwellings per year are lost from the Affordable Housing Stock as a result
           of the Right to Buy Scheme.

       Housing Needs

       The assessment of need for affordable housing in Reading

4.14   Government policy, including national and regional planning guidance, requires
       Local Authorities to have an up-to-date assessment of housing need on which to
       base affordable housing policy. In 2000, Reading Borough Council commissioned
       ORS (Opinion Research Services, a spin-out company of the University of Wales at
       Swansea) to undertake a Housing Needs & Aspirations Survey (HN&AS).

4.15   It was the Council’s intention to match or exceed good practice recommended by
       Government at that time as it wished to examine and understand the dynamics of
       demand and need within the whole of Reading’s housing market, rather than just
       the need for affordable housing.

4.16   The Council therefore invited a cross-sector group of stakeholders to contribute
       their expertise to enabling ORS to evolve its survey-methodology to best capture
       and analyse the characteristics of Reading’s complex and highly pressured housing
       market. This cross-sector group subsequently steered the study. The group
       comprised:

       •     Reading Borough Council
       •     The Housebuilders Federation

14                                                       AFFORDABLE HOUSING BACKGROUND PAPER
•   The DTLR Research Division
       •   The Berkshire Joint Strategic Planning Unit
       •   Thames Valley Housing Association (on behalf of Reading BC’s five housing
           association partners)
       •   Haslams’ New Homes Consultant

4.17   Relevant key findings of the Housing Needs & Aspirations Survey were:

       •    Over each of the 5 years 2003-2008, Reading will require some 6660 annual
            housing “transactions” (i.e., sales/purchases and lettings/re-lettings) across
            its entire housing market, to meet both the demand for open-market housing
            and the need for affordable housing;

       •    The existing housing stock and the anticipated net additions to it will provide
            some 5604 of these transactions annually;

       •    The shortfall in Reading’s housing supply is therefore some 1056 units in each
            of the 5 years. (This does include an element to clear within 5 years the
            backlog-need of newly-forming households which are currently living within
            other, existing, households)

       •    Of the 1056 households each year for whom there is a shortfall of housing
            supply, 390 (37%) households would be able to buy or rent at open market
            values, i.e. without some degree of subsidy.

       •    The remaining 666 households (63%) would require some form of affordable
            housing.

       •    The needs identified are split between the tenures in terms of household
            incomes and house prices in the following way:

            o   social rented, 37%

            o   intermediate sale (e.g. shared ownership), 27%; and

            o   sub market rented accommodation, 36%

       It is anticipated that the provision of a range of tenures in the proportions
       described will appropriately provide for the range of needs identified including the
       needs of key workers who are currently unable to afford housing at open market
       prices.

       Berkshire Strategic Housing Market Assessment

4.18   This Study was jointly commissioned by the six Berkshire Unitary Authorities and
       was prepared by DTZ during 2006 and the early part of 2007. The final report of
       the study was submitted to commissioning local authorities at the beginning of May
       2007. It covers some 230 pages. The Study was prepared and conducted in
       accordance with the CLG draft Housing Market Assessment guidance. The DCLG
       published the final guidance on 30th March 2007. The study is wide-ranging and

15                                                 AFFORDABLE HOUSING BACKGROUND PAPER
very detailed. The analysis below is based on the details contained in the
       summary document.
4.19   The first step of the study was to analyse housing market areas. The study found
       that Berkshire is made up of 2 separate functional housing market areas, albeit
       facing different influences, with East Berkshire strongly influenced by London, and
       West Central Berkshire, within which Reading is the main attraction, showing a
       higher level of economic self-containment.
4.20   Reading is the main hub of the West Central Berkshire Area being the main centre
       of employment. The study found that Reading formed part of a market that
       includes West Berkshire, Wokingham and Bracknell, stretching also into parts of
       South Oxfordshire.

       Demographic Drivers

4.21   The current (2004) population of the West Central Berkshire area is 584,000.
       Overall growth in population over the period 1981-2004 was 19% in West Central
       Berkshire (a population increase of 92,400), compared to 12% growth in the South
       East over the period. The Berkshire housing markets experience net in-migration
       from London and internationally but net out-migration to all other parts of the UK.
       At present the population of both market areas has a slightly younger bias when
       compared to the South East and England as a whole. Average household size in the
       West Central Berkshire is 2.46 people per household space. This is above the
       average for the South East (2.39) and England (2.37). The total number of
       households in the West Central Berkshire area increased by 13% between 1991 and
       2001 (an additional 26,600 households). The East Berkshire market area
       experienced more limited household growth over the period of around 8%, less
       than the rate of growth observed in the South East (11%) and England (9%).
       Although there is likely to be significant growth in single person households
       (including elderly households) in the future, couple households (with and without
       children) will remain the largest group in all authorities in 2026.

4.22   Ethnic composition of the population shows higher levels of ethnic communities
       than in SE or England. In common with other centres in Berkshire, Reading has
       experienced a substantial influx of migrants from Eastern Europe, particularly
       Polish migrants. This is undoubtedly affecting the private rented housing market.

4.23   Economic Growth. For the period 1995-2004, growth in the number of jobs in
       each of the market areas has surpassed comparative growth in England; West
       Central Berkshire area experienced 24% employment growth, Berkshire County 22%
       employment growth, and both East Berkshire and the South East 19% employment
       growth. The economies of West Central and East Berkshire have undergone
       considerable change over the past 10 years. Change has been driven by growth
       within the service sectors such as Banking, Finance and Insurance activities and
       Other Services. Demand for market housing within both market areas will therefore
       have been driven by those employed in high paid and high value sectors who will
       tend to have higher incomes and who are able to exercise greater choice within
       the market. Up until 2007, both the East Berkshire and West Central Berkshire
       economies were operating at the levels associated with full employment.

16                                                AFFORDABLE HOUSING BACKGROUND PAPER
4.24        Tenure, Housing Stock and Recent Completions. Owner-occupation in West
            Central Berkshire (75%), is marginally higher than the level for the South East
            (74%). Levels of social renting are relatively low but the distribution of social
            renting tends to be concentrated in particular locations. West Central Berkshire
            area has a lower proportion of social rented housing (13%) than in East Berkshire
            (16%). West Central Berkshire has a relatively low proportion of flats, maisonettes
            and apartments (15%) and a high proportion of detached housing (32%) compared
            to East Berkshire and the South East. 60% of the stock in the West Central
            Berkshire is detached or semi-detached, slightly higher than the average for the
            South East. The Buy to Let market has emerged as a phenomenon since 2001 and
            recent development (in the towns at least) has been dominated by flats and
            apartments. Since 2001 within Berkshire, over 50% of new private development in
            has been delivered as flats. 15

4.25        House Prices: Overall, the average house price in Berkshire (£247,000) is higher
            than the average for the South East (£229,000) or England (£195,000) (2006 prices).
            Furthermore, house prices within Berkshire have doubled in the last 10 years, with
            the fastest rises in East Berkshire. In all areas, semi-detached house prices have
            increased at a higher rate than overall average house prices over the period 1995
            to 2006, which can indicate pressure on the larger stock of dwellings.

4.26        Affordability: Affordability is poor and has worsened since 2002. The relationship
            between house prices and incomes within Berkshire is such that a proportion of
            households are unable currently to buy or rent housing within the market areas.
            There are over 21,000 households registered as seeking housing with the local
            authorities in Berkshire. In March 2006, over 600 homeless households were living
            in temporary accommodation, an unequivocal indicator of housing need.

4.27        The assessment of housing need in five of the Berkshire authorities was undertaken
            in line with the DCLG draft guidance.

15
     NHBC completions data by type and size obtained by DTZ

17                                                            AFFORDABLE HOUSING BACKGROUND PAPER
4.28   The assessment estimates that there is a need for between 3,000 and 4,200
       additional affordable homes across Berkshire per annum. Given the scale of
       housing need identified, there is therefore a need to prioritise in terms of future
       affordable housing provision. The level of need in Berkshire exceeds the total
       annual housing allocations (market and affordable) for Berkshire as proposed in the
       Regional Spatial Strategy. Thus, with the current levels of funding and at current
       levels of housing development, it is unlikely that there will be sufficient provision
       of affordable housing to both meet current and newly arising need. There is a
       need for all types of affordable housing but the analysis shows that between 15-
       20% of newly forming households will not be able to afford any of the intermediate
       tenures such as shared ownership of intermediate rent. The core requirement to
       address the housing need within Berkshire is for social rented accommodation and
       it is likely that the authorities will need to prioritise the provision of this type of
       housing.

4.29   Within Reading the analysis of affordable housing needs also found that there was
       a substantial unmet need for large family houses. This is backed up by the severe
       pressures being experienced by Housing colleagues in providing such
       accommodation.

4.30   Housing Mix. Under consideration of Housing Mix the study noted that there are
       relatively severe levels of overcrowding evident across Berkshire but in Reading
       and Slough in particular in the private and social rented sectors. There is evidence
       of pressure on large affordable dwellings in some authority areas with larger
       households in need having to wait longer to be re-housed and this may point to the
       need secure a higher number of larger affordable homes in some authorities than
       has been delivered in recent years

4.31   The summary and recommendations put forward a number of salient points. While
       housing markets within Berkshire work well for the majority, there are a number of
       challenges for the Berkshire authorities and their delivery partners:

18                                                   AFFORDABLE HOUSING BACKGROUND PAPER
•       The Challenge of Addressing Housing Need within Berkshire. The scale of
                housing need outstrips what can realistically be met;

        •       The Challenge of Delivering Mixed Communities. – The housing market
                within Berkshire is polarised;

        •       The Challenge of Delivering New Housing in the Future. New affordable
                housing and the opportunity to create mixed income communities is highly
                dependent on the delivery of new market housing within Berkshire.

4.32   Seven recommendations were put forward.

            •    Recommendation 1 deals with the range of factors that need to be
                 considered in providing for the high level of need for affordable housing;

            •    Recommendation 2 is concerned with prioritising in terms of the type of
                 affordable housing secured with the core requirement being for social
                 rented accommodation;

            •    Recommendation 3 is that authorities could improve the data held on
                 housing registers so that authorities can assess the extent to which
                 households are able and willing to access intermediate housing products.
                 This recommendation also indicates that an overall target of 35% is an
                 achievable target for affordable housing provision in line with the figure in
                 the emerging RSS. It indicates that authorities will need to consider higher
                 targets for larger sites and their thresholds if such a target is to be
                 achieved;

            •    Recommendation 4 There is a relatively strong case for supporting the
                 development of a greater proportion of certain types and sizes of homes in
                 different authority areas, including a higher proportion of larger new homes
                 in Slough and Reading.

            •    Recommendation 5 Authorities should allocate a variety of different types
                 and sizes of housing land to assist in encouraging a range of tenures and
                 housing types.

            •    Recommendation 6 is concerned with how authorities such as Reading
                 might facilitate the provision of more houses to meet the priority need for
                 such accommodation in the affordable housing sector;

            •    Recommendation 7 is that all authorities need to plan for an aging
                 population and that Slough and Reading need to plan for the needs faced by
                 ethnic minorities in their areas. It goes on to make comments on the
                 delivery of housing to meet the requirements set out in the emerging South
                 East Plan.

4.33   The Berkshire Housing Market Assessment provides a wealth of evidence on the
       housing markets in Berkshire. It emphasises the need for a high level of provision
       overall to meet economic objectives. It notes that recent trends are providing
       considerable numbers of flats that may be unbalancing the market and failing to

19                                                    AFFORDABLE HOUSING BACKGROUND PAPER
meet needs. It reinforces existing evidence of the high level of need for
        affordable housing that exists, emphasising the importance of determining
        priorities within the wide range of needs that are evident. The assessment does
        not appear to have made findings or reached conclusions that suggest that any part
        of the Core Strategy needs to be changed. It does, however, provide evidence and
        recommendations that will be picked up in future housing strategies and that will
        inform future DPD’s and the preparation of SPD‘s particularly on affordable housing
        and planning obligations.

4.34    The Berkshire Strategic Housing Market Assessment is also backed up by “A
        Technical Report for Reading Borough Council, Housing Need Assessment, April
        2007. 16 This report provides a more detailed analysis of need in Reading Borough
        arising from the methodology used by the study. The Figure below copies Figure
        3.12 from the study which provides the Estimated of Total Requirement for
        Affordable Housing in reading and for West Central Berkshire and Berkshire as a
        whole.

Figure 3.12: Estimated of Total Requirement for Affordable Housing

Total
4.35    The study goes on to look at tenure. It points to the fact that although products
        such as shared ownership and intermediate rent will help provide affordable
        housing for sections of those households that cannot afford open market housing, it
        still leaves many still unable to afford housing. Paragraph 3.65 states,

           “The key conclusion here is that even with the cheapest intermediate product
           (and the highest level of subsidy) at least 19% of new households within Reading
           are unlikely to be able to meet their needs in the market and, by implication,
           are likely to require social rented accommodation.”

4.36    Housing Waiting Lists and Registers currently point to the following finer grained
        needs:

         • disabled persons units +other specialist properties such as properties with a
           bedroom and bathroom downstairs for those families coping with a disabled
           adult in the house;
16
  http://ww2.reading.gov.uk/documents/Housing_and_Benefits/housing%20development/040407%20-
%20Reading%20HNA%20v1.0.pdf

20                                                            AFFORDABLE HOUSING BACKGROUND PAPER
• Big 4 bed & above houses;

       • Disabled adapted housing especially to meet needs of disabled children;

       • 1 bed flats in blocks of not more than 6 for vulnerable singles.

       • Pepper potted small flats on s 106 sites

       • Accommodation for Learning Disability clients and physically disabled people.

       • Bungalows with flexible use e.g. flat for carers;

       • Extra Care Provision for more vulnerable elderly.

4.37   Other needs and priorities will from time to time be detailed and changed through
       the Council’s Housing Strategy.

4.38   Current Housing waiting lists show a total of 5993 on the list at 1st April 2010. Of
       these, 3030 were considered to be in a reasonable preference category.

4.39   The above evidence demonstrates a very high level of need for affordable housing
       in the Borough. Planning has a crucial role in assisting in meeting those needs
       through the provision of a proportion of affordable housing as part of all new
       developments.

5.     POLICY DISCUSSION

5.1    The need for affordable housing is one of the most important issues facing
       Reading. The success of the sub region as an economic driver has added to
       demand for housing overall. House prices are well above the national average.
       Average house prices make it increasingly difficult for those on low incomes to find
       accommodation they can afford. The concept of “affordability” is essential when
       looking at housing needs. That is what households can afford to pay for their
       housing, and whether this is sufficient to meet their needs. Access to reasonably
       priced homes is essential for the local economy, so that there is a ready supply of
       locally based workers to meet job vacancies. Key workers, who are essential to
       support the local economy and society, such as teachers and nurses, must have
       affordable housing in order to live locally. Having a workforce living locally also
       reduces the environmental and economic costs incurred in travelling to and from
       work.

       Affordable Housing Targets

5.2    The Council’s Housing Strategy, 2009 -2014, discusses a target of 40% of all housing
       being in the form of affordable housing. It points to the target in the Adopted
       Core Strategy (paragraphs 6.26 and 6.27) that 50% of housing on sites of over 15
       dwellings will be affordable.

21                                                  AFFORDABLE HOUSING BACKGROUND PAPER
Affordable Housing Thresholds

5.3     Over a number of years, Reading Borough Council has operated a threshold of 15
        dwellings above which affordable housing has been expected as part of residential
        development schemes. In preparing its SPG on Planning Obligations during 2003/4,
        the Council considered and resolved to make allowance for the reduction of this
        threshold figure in line with draft Changes to PPG3 that were published by the
        government during 2003. However, the draft changes enabling lower thresholds
        to be used did not materialise in the final changes to PPG3. That proposal was
        then carried over into the new PPS3 published, at the end of 2006, just as the
        draft Core Strategy was being submitted.

5.3     Statistics for small site completions, defined as sites of less than 1ha with less than
        10 net dwellings is monitored annually. For the Core Strategy, the Inspector
        accepted that an average of 141 dwellings are completed on windfall sites of less
        than 10 dwellings per year (although the figures below suggest a higher level of
        completions on such sites). Analysis has been undertaken on completions on sites
        of 10-14 dwellings and the table below sets out evidence of housing provided on
        sites of less than 15 dwellings in the bands referred to in the draft policy.

                                            Dwellings          Dwellings      Dwellings
                        Net Dwelling       completed in      completed in completed in
          Year
                        Completions      developments of     developments developments
                                            10-14 units       of 5 - 9 units of 1 - 4 units
           00/01            371                  27
           01/02            747                  91
           02/03            574                  24
           03/04            761                 130
           04/05            1177                116
           05/06             656                 98                40             118
           06/07             637                 74                51             75
           07/08             837                 54                31             137
           08/09             782                 91                79             137
           09/10             693                140                58             124
           10/11
           Totals           7235               845                259            591
      Yearly Average         723                84                 52            118
         % of Total                            11.6               7.2%           16.3
        Affordable
          Housing
      Potential with                         25 (30%)           10 (20%)       12 (10%)
       30%, 20% and
            10%

        Note: Staged applications and adjoining sites have been counted as separate
        developments where they have been assigned a separate application number.
        Source: Planning Commitments for Housing, Reading, Berkshire Joint Strategic
        Planning Unit, 2000-2010

22                                                      AFFORDABLE HOUSING BACKGROUND PAPER
5.4   As indicated, this produces an average of 84 dwellings per year on sites of 10-14
      dwellings and an average of 254 dwellings on sites of less than 15 dwellings. It is
      clear that a sizeable proportion (35.1%) of the Borough’s housing land supply
      derives from sites of below the threshold of 15 dwellings and that appropriate
      contributions from sites of this size of site could, potentially, make a significant
      contribution towards affordable housing completions in the Borough.

5.5   As indicated by the analysis in the final row, this policy has the potential to
      produce an average of up to 47 affordable dwellings per annum which will provide
      more than an additional 30% to the average provision of affordable housing
      achieved through planning on sites of 15 or more dwellings. The pursuit of such a
      level of affordable housing will be very worthwhile.

5.6   As indicated, small sites of 1-4 dwellings have scope to make a contribution
      towards affordable housing provision either on site or more likely, offsite as the
      market improves. Offsite contribution will provide valuable income that can be
      put to the construction of affordable housing, perhaps much needed larger family
      homes, elsewhere in the Borough. A very rough estimate of completions over last 5
      years shows an average of 110 completions in the 1- 4 category, approximately half
      of which are new build developments. On 50 new build houses, if the charge was
      £7,000 a unit as the 10% contribution to providing a unit, it would provide around
      £350,000 a year? Appropriate contributions from conversions and COU in the 1-4
      dwelling category will add to this figure.

      Viability

5.7   Work was undertaken in house during 2009 by the Council’s Valuation Section to
      consider the viability of various levels of target provision for a range of sites of less
      than 15 dwellings. Viability was tested in market conditions prevailing at the time
      during 2009, when the market was quite near the bottom of the downswing in the
      economy, and for the market conditions that existed at September 2007 when the
      market was approaching, but not at, its highest. The market peaked in the early
      part of 2008, at about the time that the Northern Rock Building Society was
      brought into national ownership. The assumption was that the market would
      return to conditions similar to those that existed at September 2007 during the
      plan period. That work determined that the target provision set out in the draft
      policy would be viable, certainly with modest levels of grant, at September 2007
      conditions, although it was accepted that they were challenging in the 2009
      market conditions.

5.7   Various changes in planning policy, law and the housing market since the original
      Draft SDPD was published in February 2010 has required a review of existing Draft
      Policy DM 6 on Affordable housing. In particular there was a need to reassess
      whether the justification for the target provision set out in the policy remains
      viable.

5.8   The High Court (Blyth Valley Borough Council vs. Persimmon Homes (North East)
      Limited) has ruled that policies seeking the provision of affordable housing must be
      accompanied by evidence that demonstrates that the targets contained within the

23                                                   AFFORDABLE HOUSING BACKGROUND PAPER
policy are viable (i.e. have a reasonable prospect of being delivered by
       development in the Borough and not likely to deter such development). Having
       undertaken the analysis and review discussed below, the conclusion is that the
       policy and its targets can continue to be justified in terms of viability on the basis
       that the housing market is improving and will improve, although there may be
       some bumps along the way, that grant may be available for small sites in the
       future, within the plan period, and the wording is very clear that the policy allows
       applicants to submit viability information to demonstrate why targets can not be
       achieved.

5.9    The target proportions for provision were tested at the end of 2009/beginning
       2010, before the first Pre-Submission Draft SDPD was published, in terms of
       viability based on Autumn 2009 prices when the market was probably at its lowest
       and compared with September 2007 prices. Historically we know that markets are
       cyclical, the housing market rises, then falls but usually returns to rising prices. At
       the time of publishing the SDPD in February 2010, it was considered that the
       housing market was likely to return to September 2007 house prices in a relatively
       short space of time. There were clear signs that the economy was starting a
       recovery. A series of viability assessments on hypothetical sites were undertaken
       to test different sizes and types of developments.           Viability was tested for
       situations where affordable housing grant was available and where grant was not
       available.

5.10   The conclusion of the viability assessments was that most developments, especially
       the larger schemes, would be of marginal viability in providing the target provision
       in the 2009 house price scenario, both when grant is available but more so where
       no grant is available. However, in nearly all cases the proposals would be viable at
       2007 prices with or without grant. It was therefore considered that the policy was
       broadly in line with current practise and likely to be found sound based on the
       assumption that the property market would recover to prices comparable with
       2007 price levels within the plan period.

       Current Situation (June 2011)

5.11   The current economic situation and the new public sector settlement have
       changed the outlook in several ways. House price growth, levels of mortgage
       offers and new build outputs are all rather flat and demonstrating only limited
       signs of recovery. In fact, as can be seen above, the evidence on house prices
       shows a gradual fall and then a gradual rise so far during 2011. This reflects
       continuing uncertainty in the market as a result of uncertainty in the economy,
       public sector cutbacks, fears of interest rate rises, international financial
       uncertainty, continuing restraints in mortgage lending, etc. This suggests that low
       viability will remain a concern for most schemes of less than 15 dwellings. House
       prices are now not seen as likely to return to 2007 levels for some time. Prices
       since the end of 2010 have reflected this uncertainty but remain relatively higher
       than 2009 levels as can be seen above. Borrowing and other funding costs are
       expected to remain much higher than in 2007. Expected profit levels/rates of
       return are likely to remain at higher levels reflecting higher perceived risks and
       consequently more onerous lending criteria. These factors mean that viability is
       likely to remain lower than September 2007 levels on sites of less than 15 dwellings

24                                                   AFFORDABLE HOUSING BACKGROUND PAPER
for some time yet. The recovery may be slower than was anticipated during the
       early part of 2010. Nevertheless, the medium to longer term outlook is for the
       economy to recover and for house prices to rise and viability to improve.

5.11   Further work has been undertaken to test viability, including independent
       verification of the work undertaken in house. This has included consideration of
       the emerging regime arising from government policy on affordable housing and
       changes in HCA grant allocations. It is clear from the public sector settlement
       outlined in October 2010, that there will be less public subsidy of affordable
       housing and thus more emphasis on developer provision to meet identified needs.
       The government has introduced the affordable rent product and added this to its
       typology of affordable housing to which PPS3 applies. The council and various
       housing associations have been assessing the new product/model against identified
       need, current priorities, costs and viability. Under this model, DCLG through the
       HCA are promoting a form of rental affordable housing at levels of up to 80%
       market rents. This will allow providers to achieve high levels of provision without
       public subsidy and is intended to produce more affordable housing at lower costs.
       While, where provided on site, such housing will provide for an element of housing
       need for those on moderate incomes which do not allow them to buy on the open
       market, it is not going to produce housing for those most in need or the priority
       need identified in the Strategic Housing Market Assessment.

5.13   Officers have given some further thought to how the policy will be operated and
       how any provision/contributions are determined in the current circumstances.

5.14   One issue is that the preparation and assessment of viability studies is relatively
       expensive, certainly in relation to the amounts of provision and contributions we
       are talking about for the smaller sites. In addition, a part of the housing provision
       from smaller sites is in the form of conversions and changes of use, where viability
       is likely to be much less certain than for new build situations. We need to find
       ways of determining an acceptable level of provision/contributions without every
       application having to be subject to an individual viability assessment. That might
       take the form of an SPD that is updated annually or just an informal position
       statement that sets out what officers will accept at particular points in time in
       view of market conditions and the availability/ non availability of grant. A
       reference to some such mechanism has been added to the text.

6      PREFERRED APPROACH AND REJECTED ALTERNATIVES

       Preferred Approach

6.1    Various alternative approaches to implementing the provisions in PPS3 and Policy
       CS16 of the Core Strategy were considered as follows:

              ƒ   No SDPD Policy for AH provision on sites below 15 dwellings;
              ƒ   A policy providing complementary guidance to Policy CS 16 but retaining
                  the threshold of above 15 dwellings;
              ƒ   Having a lower threshold of 1-14 units;
              ƒ   Having a lower threshold of 10-14 units or 5-14 units

25                                                 AFFORDABLE HOUSING BACKGROUND PAPER
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