NPPF Changes Consultation 2015
Do you have any comments or suggestions about the proposal to amend the definition of affordable housing in national planning policy to include a range of low cost homes?
- Section 50 of the NPPF states that planning authorities should "plan for a mix of housing based on current and future demographic trends". However, this section of NPPF also allows developers to offer an "off-site provision or a financial contribution of broadly equivalent value" instead of the affordable housing required. The result is that affordable housing is in short supply, and when it is built it is likely to be concentrated around already deprived areas rather than in the mix that the NPPF demands.
- Broadening the definition of affordable housing will not rectify this fundamental problem. It will only provide the developer/house builder with more ways of avoiding the construction of the type of housing needed. Instead the government should tighten the conditions so that developers cannot avoid the provision of ‘affordable’ housing.
- The constant reference in the NPPF consultation regarding ‘affordable homes’ to ‘products’ illustrates the mind-set of the author and their Government sponsors. Everything is biased to a ‘market’ view of housing provision and the drive to encourage participation by the financial services sector whose appalling reputation for mis-selling novel financial products is self-evident.
- The average market price of a house in Guildford borough is approximately just under £500,000 (see South West Surrey Joint SHMA, G L Hearn, January 2015). A 20% discount as proposed for ‘starter homes’ results in a property sale price of approximately £400,000. Currently, this will not buy a three-bedroom semi-detached house in the borough. The estimated average market rent for a three-bedroom semi detached house in Guildford borough is approximately £1,350 pcm (see RightMove and Zoopla web sites). The ‘affordable home’ definition in Annex 2 of the NPPF proposes 80% of these rates as ‘affordable’.
- It has been suggested by many elsewhere that a family with two adult wage earners would need an annual joint income somewhere in the region of £75,000 to even attempt to consider the above options. Suggesting that they have the opportunity to invest in a ‘Help to Buy ISA’ will only benefit the financial services industry.
- We propose an increase in the discount rate for ‘starter homes’ to 30%.
Do you have any views on the implications of the proposed changes to the definition of affordable housing on people with protected characteristics as defined in the Equalities Act 2010? What evidence do you have on this?
- We would like to see social rented housing to be retained in perpetuity unless finance is available to cover the net loss and so add to the low rental housing pool. Extending the ‘right to buy’ to housing associations will increase the existing shortage of rented accommodation and is a retrograde step.
- In some towns, such as Guildford, student accommodation has not been made available on campus so housing at the lower end of the market is not available for first time buyers as it is being made available to students by local landlords. Information from the local authority implies at least 1,500 properties in the town being rented as student accommodation.
- We are concerned that the proposals will contravene the 2010 Equalities Act in terms of socio-economic discrimination against the poorer sectors of the community, including those who will be unable to afford market housing even with the 20% reduction.
- In most local authorities there is a long waiting list for social rented accommodation. We appreciate the government’s wish to encourage home ownership but it is essential to also provide accommodation for those unable to afford starter homes. In our opinion it is essential that Local Authorities have the power to require developers to make a contribution towards an element of social housing.
- We have reservations on the numbers of dwellings for first time buyers which can be built with a cap of £250,000 in Guildford; it would be difficult to purchase a dwelling for £250,000 even with the 20% reduction, except perhaps for a small one bedroom flat. The price difference between London at £450,000 and elsewhere of £250,000 is a crude cut-off and a sliding scale should be provided.
- We are also concerned at the cut off age of 40. Older families could be in greater need.