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ED032 SC Statement Policy H5 - Session 4 PDF
ED032 SC Statement Policy H5 - Session 4 PDF
ED032 SC Statement Policy H5 - Session 4 PDF
Affordable Housing -
Local Needs Housing and
Rural Exception Sites
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Contents
Contents ..................................................................................................................... 2
1.0 Introduction ....................................................................................................... 3
2.0 Revisions to Policy H5 ...................................................................................... 3
3.0 Renamed Policy H5 and Updates to Supporting Text ....................................... 4
4.0 Underlying Evidence ......................................................................................... 5
5.0 Amendments to Proposals Map ........................................................................ 6
6.0 New Policy on 100% Affordable Housing Sites................................................. 6
Appendix 1: LDP Policy Amendments ........................................................................ 8
Appendix 2: Proposed New LDP Appendix 7 – Eligibility Criteria and Restrictions for
Local Needs Housing ............................................................................................... 14
Appendix 3: Supplementary Evidence of Local Need ............................................... 17
Appendix 5: Amendments to LDP Proposals Map illustrating Allocated Sites in
Policy H5 21
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Statement of Swansea Council arising from
LDP Examination Hearing Session 4:
Affordable Housing -
Local Needs Housing and
Rural Exception Sites
1.0 Introduction
1.1 This Statement has been produced by Swansea Council (hereafter ‘the
Council’) in order to respond substantively to the following Action Points arising
from Hearing Sessions 3 and 4 of the Swansea Local Development Plan (LDP)
Examination:
1.2 This statement should be read in conjunction with other Council statements
submitted to the Examination, namely:
2.2 The proposed amendments to Policy H5 are set out in Appendix 1 of this
statement. The nature of the amendments can be summarised as:
2.3 Further details of the above changes are set out in the sections below.
3.1 The proposed amendments to Policy H5 and supporting text are presented at
Appendix 1 and are summarised below:
4.1 The Council recognises that the evidence that supports and justifies Policy H5
needs to be clearly expressed in respect of:
identifying the local need for the plan period (for both affordable housing
for local needs and market housing for local need)
clarifying how each site will meet the need
evidencing how each site meets the local, social or economic need
evidencing affordability
4.2 In order to further supplement the evidence set out in the Local Housing Market
Assessment (LHMA)1, and the demographic profiling data of the relevant wards
(as set out in the Appendix to the Council’s statement for Hearing Session 4),
the Council has commissioned Opinion Research Services (ORS) to provide
further evidence to respond the points raised in AP3.4 and AP4.10. The
resulting supplementary evidence paper is attached at Appendix 3.
4.3 The supplementary evidence from ORS provides confirmation and clear
evidence that Policy H5 (as proposed for amendment) will meet the both the
identified need for affordable housing for local needs, and the need for local
needs housing allocations within the Gower, Gower Fringe and West SHPZs.
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EB003 Local Housing Market Assessment 2013 EB004 Local Housing Market Assessment (Update) 2015
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restrictions are likely to have some impact of the overall house prices achieved
on the minority element, however it is not appropriate for the policy to seek to
place a specific restriction on sale prices in this regard. It must be recognised
that the enabling element of the policy must ultimately be capable of providing a
financial viable development that will secure the delivery of the affordable
homes.
4.5 Further additional evidence is provided by the recently adopted Gower AONB
Management Plan2 2017, which identifies the lack of affordable housing on
Gower as an issue for local people and affects their ability to continue to reside
within the area. The Management Plan was informed by comprehensive
discussions by the Gower AONB Partnership held throughout 2015 on the issue
of affordable housing, and by subsequent stakeholder and public consultation
on the draft Management Plan. The resulting Management Plan highlights
particular issues with maintaining communities with a balanced age group, and
also issues with a large proportion of homes being used a second homes.
Theme 14 of the Management Plan Strategy (pg 84) therefore specifically
relates to to affordable housing and is supported by Management Plan Policy
HC1 “Promote the provision of affordable housing for local people”, and
Objective 38 “ensure that LDP policy addresses the affordable housing needs
of local communities”.
4.6 Amendments to Policy H5 are set out in Appendix 1, which show that the
refined policy and supporting text accurately reflects the evidence base.
5.1 The amendments to the policy include amending the settlement boundaries to
show the allocated sites as being within the boundaries. Maps illustrating the
proposed boundary amendments for each allocated site are set out at Appendix
5, together with maps illustrating the original deposit settlement boundaries.
6.1 The element of the policy relating to development proposals for “100%
affordable housing” is proposed to be removed from Policy H5 and re-provided
in a new separate policy which is presented at Appendix 1. The new policy is
presented in a revised form to ensure that both the policy and terminology used
within it are fully aligned with National Planning Policy. In particular:
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https://www.swansea.gov.uk/gowermanagement
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housing provided under this policy is both sustainable and meets the
identified need.
Amendment to clearly distinguish between the requirements of sites
allocated under Policy H5, and non-allocated sites which will be
considered under the new policy in accordance with National Planning
Policy guidance.
Amendments to clearly refer to the fact that housing provided under this
policy will be for Affordable Housing for Local Needs and will be subject to
the Council’s own eligibility criteria which are set out in Appendix 6 of the
Plan, and are distinct from those which will be applied under Policy H5
relating to local needs occupancy criteria and set out in a separate new
Appendix.
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Appendix 1: LDP Policy Amendments
2.5.27 The Policy sets out criteria to ensure that where land is identified for
Affordable Housing for Local Needs outside of settlement boundaries, it is
of an appropriate nature and its location is in accordance with the Plan’s
strategy of creating sustainable communities.
2.5.28 National Planning Policy and Guidance allows for the identification of
local needs housing exception sites, which are distinct from
standard market housing allocations to allow for the provision of
both affordable and market housing for local needs. In this context,
Policy H5 allocates six sites to deliver both local needs housing and
affordable housing for local needs, specifically in order to meet the
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identified need in the Gower, Gower Fringe and West Strategic
Housing Policy Zones. rural exception sites to deliver Affordable
Housing for Local Needs. These are sites, where as an exception to the
restrictions on development in the countryside, may be permitted. The
Policy therefore allocates land which has been identified as being suitable
for Affordable Housing for Local Needs. However, the sites identified are,
for the most part, large in relation to the rural settlements/settings in which
they are located. It is not therefore considered to be in accordance with
the objective of creating sustainable communities to allocate the entire site
for affordable housing. In addition, the number of rural exception sites
delivered over previous Plan periods has been low as the reduction in
Social Housing Grant has reduced the viability of delivering affordable
housing without an enabling element of market development.
2.5.29 The sites identified in the Policy are, for the most part, large in
relation to the rural settlements/settings in which they are located. It
would not be in accordance with the objective of creating cohesive,
sustainable communities to allocate the entire site for affordable
housing. The Policy therefore provides a pragmatic and balanced
approach, which addresses the identified local needs and ensures
that the opportunities to deliver affordable housing are maximised in
accordance with the affordable housing strategy set out in Policy H
2.
2.5.31 The remainder of the site however may provide local need housing
offer alternative housing products to meet local social and economic
housing needs. This includes in particular, housing which addresses the
needs of older persons in the area to help facilitate downsizing. The mix of
tenure to be delivered on these sites must be negotiated with the Council’s
Housing Enabling Officer. There is little evidence of need for social rented
properties within the Gower and Gower Fringe SHPZ. Where such tenures
are provided it would be highly likely that the occupants would only be
found through cascading the search process to tenants from outside the
Gower and Gower Fringe Zones. This would not meet the specific local
needs identified in the LHMA. This element of the policy seeks to
address identified issues and deficiencies in the local housing
market that affect the ability of specific local groups to meet their
accommodation needs within the local area. These groups include
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first time buyers, local persons creating new households, carers,
older people, and those requiring care.
2.2.32 It is important to note that the specific allocations have not been
identified in order to meet a market need. The principle of market housing
development has not been accepted on these sites. For this reason all
such sites allocated under this Policy will remain outside of the respective
settlement boundaries in order that they can only be brought forward as
exception sites.
2.5.32 For the purpose of this policy, the defined locality is informed by
the evidence of social and economic need in a specific set of
electoral wards, which includes the Council's administrative wards
of: Bishopston, Fairwood, Gower, Mayals, Newton, Oystermouth,
Pennard, Penclawdd and West Cross. The geographical area of the
defined locality is illustrated in Appendix 7, which also sets out the
defined eligibility criteria for assessing whether a prospective
occupier would satisfy the test of local need. All wards within the
defined locality fall within the Gower, Gower Fringe and West SHPZs.
Within these wards evidence shows that the local housing market
experiences a range particular pressures that limit the options
available for local households to access private housing and can
lead to households moving outside of the defined locality. These
pressures include: high levels of second home ownership; a
dominance of larger properties in the existing housing stock; a lack
of smaller one or two bedroom properties; high levels of migrant
households from outside of the county that increases levels of
competition of existing stock. This is further compounded by the
evidence of the demographic profile of these wards within the
locality, which shows that there are significant levels of older
persons in larger properties, and lower levels of younger people and
young families in these areas.
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2.5.34 In order to ensure that local needs housing provided on the
allocated sites meet the objectives of the Policy, the occupation of
dwellings provided will be controlled through the use of local
occupancy restrictions. Such restrictions will require that initial and
subsequent occupants of the properties fall within the definition of
“persons with a local connection”. An exception to this requirement
may be permitted if a property has been advertised for sale, for at
least 16 weeks, and no person with a local connection can be
identified as a prospective purchaser. Restrictions will also be
imposed to ensure that the dwellings provided are only occupied as
“only or principal homes” Appendix 7 provides further details of the
definitions and mechanisms necessary to enforce the
implementation of the policy.
2.2.36 The mix of house sizes and tenure types to be delivered on the
sites allocated in Policy H5 must be negotiated with both the
Council’s Planning and Housing departments, having regard to the
most up to date needs evidence at the time of the application. If a
majority of affordable housing cannot be delivered for financial
viability reasons, there will be no relaxation of the minimum
provision target as viability of proposals will change over the Plan
period.
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B. Proposed New Policy based on extracted text from former Policy H5
2.5.37 National Planning Policy and Guidance allows for the identification of
affordable housing exception sites to deliver Affordable Housing for Local
Needs. These are sites where, as an exception to the restrictions set out in
national policy on development in the countryside, residential development
for affordable housing for local needs may be permitted.
2.5.39 The Policy sets out criteria to ensure that where affordable housing
exception sites are identified that they are of an appropriate nature and in a
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location which is in accordance with the Plan’s strategy of creating
sustainable communities.
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Appendix 2: Proposed New LDP Appendix 7 – Eligibility Criteria and
Restrictions for Local Needs Housing
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Definitions:
'Person with a Local Connection' means an individual who before taking up
occupation of the dwelling satisfies one of the following conditions:
Either:
(a) The person has been in continuous employment in the Locality defined for at
least the last 9 months and for a minimum of 16 hours per week immediately
prior to occupation; or
(b) The person needs to live in the Locality defined because they need substantial
care from a relative who lives in the Locality defined, or because they need to
provide substantial care to a relative who lives in the Locality defined.
Substantial care means that identified as required by a medical doctor or
relevant statutory support agency; or
(c) The person has been continuously resident in the Locality defined for three
years immediately prior to the occupation of the dwelling and is in need of
another dwelling resulting from changes to their household
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Boundary of Local Needs Housing Locality
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Appendix 3: Supplementary Evidence of Local Need
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Opinion Research Services | Swansea Local Housing Market Assessment: Summary of local needs housing February 2018
» Bishopston
» Fairwood
» Gower
» Mayals
» Newton
» Oystermouth
» Penclawdd
» Pennard
» West Cross
2. These wards broadly align with the Gower, Gower Fringe and West SHPZs.
3. Collectively, these wards have considerably higher house prices than the Swansea average (£270,800
compared to £161,800 in 2016-17 based on HM Land Registry data). At the time of the 2011 Census, there
were only 1,081 affordable homes in these wards, a much lower proportion than the Swansea average (7.4%
compared to 19.5%).
4. The LHMA 2013 analysis identified an overall affordable housing need for 1,700 affordable homes to be
provided in the Gower, Gower Fringe and West SHPZs over the period 2011-2025 based on meeting the
identified needs within the local area (Table 2 of the Affordable Housing Topic Paper, August 2013). This
included a substantial need for intermediate affordable housing due to the relatively high costs associated
with market housing in these areas.
5. Given the scale of the identified need, it will clearly be important to maximise the delivery of affordable
housing in these areas.
6. More generally, there will be a considerable number of local people in these areas seeking to form independent
households or move to housing more suitable for their needs. The 2011 Census identified that in 2010-11,
there were 1,548 households who moved within these wards (staying within the same ward) and
1
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Opinion Research Services | Swansea Local Housing Market Assessment: Summary of local needs housing February 2018
a further 487 households who moved from these wards to elsewhere in Swansea. Whilst some of these
households moving to other wards will have chosen to do so, others will have been forced to move either
due to affordability constraints or due to lack of suitable housing options.
7. On the basis of these trends continuing, it is likely that there will be over 23,000 household moves within these
wards over the 15-year LDP Plan period and around 7,300 households will move to other parts of Swansea.
8. Many of these households will move to existing market housing; however, the housing market in these areas
experiences particular pressures which limits the options available for local households.
9. The proportion of dwellings without a usually resident household is particularly high (10.5% of the stock
compared to 5.0% across Swansea). This is as a consequence of significant levels of second home ownership
in some of these wards, especially Gower ward (where 25.7% of dwellings aren’t main homes) and
Oystermouth ward (where the proportion is 15.0%).
10. These are also the wards which tend to attract migrant households from outside Swansea. The 2011 Census
identified that over a third of households moving to these wards (35.4%) are migrating from elsewhere in the
UK or overseas compared to around a quarter (26.3%) of moves across all Swansea. The proportion of
households migrating from elsewhere was particularly high in Oystermouth (48.4%), Mayals (43.5%) and
Newton (41.0%).
11. Local households face significant competition for housing in these wards.
12. Further to these pressures, it is important to recognise that the existing stock in these areas is dominated by
larger properties, with almost half (45.6%) being detached and around a third (32.9%) having four or more
bedrooms. These proportions are almost double the Swansea averages (23.2% detached and 18.2% with 4+
bedrooms). In contrast, there are very few smaller properties with only around a quarter (26.5%) with one or
two bedrooms compared to over a third of properties across Swansea (36.4%).
13. As a consequence, there are limited opportunities for newly forming households in these areas. The lack of
smaller properties coupled with the higher cost of housing in these areas mean that many have to either
move to other parts of Swansea or remain living as concealed households not able to live independently.
14. The mix of existing housing means that there are also limited opportunities for older households seeking to
downsize to more suitable housing. In the absence of suitable housing being available, these households will
often choose to stay in their existing family housing.
15. Whilst local needs market housing will never provide sufficient housing for all local households seeking to
form their own home or move to a more suitable home, the provision of such housing will help ensure that
households are able to stay in their local areas. Furthermore, providing an appropriate mix of housing on
these sites, which diversifies the stock and increases the range of housing options within the ward, will help
ensure that households can find suitable housing within their local area.
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Opinion Research Services | Swansea Local Housing Market Assessment: Summary of local needs housing February 2018
Household
spaces with no % moves from
Average house Affordable usual outside Up to 2
2011 ward price housing residents Swansea Detached 4+ bedrooms bedrooms
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Appendix 5: Amendments to LDP Proposals Map illustrating Allocated Sites in Policy H5
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