4.3.24

See attached document.

The policies on affordable housing fall well short of addressing the failings in the current Local Plan which have consistently missed the targets set for the last five years. More ambitious targets for the percentage of affordable homes need to be set and rigorously enforced, using existing planning powers.
If the County Council fail to fully recognise the challenge which delivering affordable housing presents then it is severe danger of repeating the mistakes of the last plan which over a five year period only delivered 277 affordable housing units in total against an annual plan target of 123 units. Developers have frequently been successful in side-stepping the system with the result that on average private developer schemes have only achieved a level of 7% affordable homes. There are numerous examples of where the policy has been flouted. A developer in Rhos claimed that his target market of upper middle class retired with £250k to spend on an apartment required a higher quality of finish which would reduce his profit and therefore instead of 3 affordable units only 1 was provided. Another developer building 9, £300k homes, had to make a financial contribution of just £20k insufficient to finance a single affordable home.
The LDP Review also recognises the issues raised by "viability" assessments:
"To address this, the policy will need to be reviewed through further viability testing, whilst the call for sites will include more rigorous assessment of viability at an early stage to reduce the possibility of planning obligations being reduced due to high land values or abnormal costs".
There is no evidence from the published strategy and its associated documents that a more rigorous assessment has actually taken place. The plan therefore runs the risk of repeating the mistakes of the previous LDP leaving the system wide open to abuse by developers flaunting their obligations to provide adequate affordable housing.

Only this April the National Assembly produced a research note in its Planning Series on Section 106 agreements. Advice in paragraph of the note recommends:
"LDPs and/or Supplementary Planning Guidance should set out the circumstances where LPAs will use planning conditions or S106 agreements to ensure that the affordable housing provided is occupied in perpetuity by people falling within particular categories of need. Onsite provision of affordable housing is preferred, but in exceptional circumstances the provision can be offsite. In some cases a financial contribution in lieu of on-site provision (a commuted sum) is preferred".
The use of section 106 powers are particularity important in the successful delivery of affordable housing policies in any plan as recognised in Circular 13/97. It is therefore extremely disappointed to note a very defeatist stance taken within the plan in paragraph 4.3.24. This paragraph implies that proper control over the delivery of affordable housing via the planning system is "outside the sphere of influence" of the Council and that its powers as LPA are "limited ".
If the County Council fail to fully recognise the challenge which delivering affordable housing presents then it is severe danger of repeating the mistakes of the last plan which over a five year period only delivered 277 affordable housing units in total against an annual plan target of 123 units. Developers have frequently been successful in side-stepping the system with the result that on average private developer schemes have only achieved a level of 7% affordable homes. There are numerous examples of where the policy has been flouted. A developer in Rhos claimed that his target market of upper middle class retired with 250k to spend on an apartment required a higher quality of finish which would reduce his profit and therefore instead of 3 affordable units only 1 was provided. Another developer building 9, 300k homes, had to make a financial contribution of just 20k insufficient to finance a single affordable home.
Assuming the County Council are serious about making a real difference to the levels of affordable housing it should apply a minimum percentage of 30% right across the County. With most experts predicting a progressively tighter housing market with increasing rents making it even more difficult for local people to secure suitable homes it is regrettable that the County Council has not taken the opportunity to increase targets for the provision of affordable homes. In fact the target of 120 per annum is less than that set within the original plan and well below that required to make meaningful impact on this growing crisis. A crisis manifested by a waiting list for social housing of 891 households and where 270 under 24 year olds classified as homeless. The PS highlights the risk of further outward migration of the county's young people. With such limited housing choices more and more may join what is fast becoming a "housing led" migration epidemic.