Housing Policy Technical Guidance SPD

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Comment

Housing Policy Technical Guidance SPD

Housing Policy Technical Guidance SPD

Representation ID: 16128

Received: 07/03/2023

Respondent: Cllr Silvia Collins

Representation Summary:

Rural villages need more bungalows to meet demand and enable downsizing. Policy also needs to incentivise delivery of new ones and disincentivise conversions of existing ones. Clearer definition of 'bungalow' required to prevent creative interpretations.

Policy H3 needs clarification.

Potential financial incentives for developers, to put in applications close to where there are existing extra care facilities, need to be removed.

Developers need more encouragement to invest in rural facilities.

The approach to viability mitigation for affordable housing (costed at sale) is especially good but must avoid potential to game the system e.g. by mitigating offsite, in cheaper locations.

HP03
A05

Full text:

Bungalows:
We need a clearer definition of what a bungalow is. Although bungalows are referred to in the glossary, this has been subject to creative interpretation by developers, in order to infer an application was meeting CBC's housing requirements for the older age groups. As an example, attached is a drawing of one dwelling which was described as a '3 bedroom bungalow' suitable for older residents.

More bungalows are needed in villages to allow elderly residents to downsize but remain in their established community. The document recognises the benefit of this and that this will free up larger properties for families etc but it is not strong enough on delivery. Bungalows are ‘encouraged’ but lumped in with other housing types considered suitable. They are unlikely to be the preferred option by developers because of the ground space they occupy. Thus, we are unlikely to see many come forward without specific policy requirements or incentives.

We should also consider how it might be possible to disincentivise investors buying up bungalows for conversion to houses. This has been very popular in the villages as the uplift property value can be considerable but it removes stock from the village. Even worse though is developers buying up bungalows in order to knock them down and develop their plots with multiple housing units.

I am supportive of the Council's approach to age inclusivity, when it comes to housing allocation for bungalows.

Policy H3:
It is not clear what type or size of extra care facility will be required for planning applications for more than 300 dwellings. I felt this was lacking some detail.

5.9.2: This introduces inequality to the system. Developers putting in planning applications close to where an existing extra care facility is, will have considerably less cost in provision onsite than those that have to commission a whole facility (which I assume will have a minimum size requirement to make it a viable operation (?))

5.15.4: It would be nice to be able to do more than ‘encourage’ developers to invest in rural facilities. Considering the growth Harlington is seeing, it is very disappointing that there will be no new facilities as part of this, yet the village only has a few shops.

6.15.1: I approve of this approach, to review viability mitigation at the time housing is sold. It needs to be robust so that all benefit from cost engineering is lost and gaming of the system will not pay off. It should be calculated in actual monetary terms for the site in question, so that developers are not incentivised to provide affordable housing elsewhere, where it can be achieved more cheaply.

Attachments:

Comment

Housing Policy Technical Guidance SPD

Housing Policy Technical Guidance SPD

Representation ID: 16326

Received: 07/03/2023

Respondent: Cllr Silvia Collins

Representation Summary:

Rural villages need more bungalows to meet demand and enable downsizing. Policy also needs to incentivise delivery of new ones and disincentivise conversions of existing ones. Clearer definition of 'bungalow' required to prevent creative interpretations.

Policy H3 needs clarification.

Potential financial incentives for developers, to put in applications close to where there are existing extra care facilities, need to be removed.

Developers need more encouragement to invest in rural facilities.

The approach to viability mitigation for affordable housing (costed at sale) is especially good but must avoid potential to game the system e.g. by mitigating offsite, in cheaper locations.

HP05
A05

Full text:

Bungalows:
We need a clearer definition of what a bungalow is. Although bungalows are referred to in the glossary, this has been subject to creative interpretation by developers, in order to infer an application was meeting CBC's housing requirements for the older age groups. As an example, attached is a drawing of one dwelling which was described as a '3 bedroom bungalow' suitable for older residents.

More bungalows are needed in villages to allow elderly residents to downsize but remain in their established community. The document recognises the benefit of this and that this will free up larger properties for families etc but it is not strong enough on delivery. Bungalows are ‘encouraged’ but lumped in with other housing types considered suitable. They are unlikely to be the preferred option by developers because of the ground space they occupy. Thus, we are unlikely to see many come forward without specific policy requirements or incentives.

We should also consider how it might be possible to disincentivise investors buying up bungalows for conversion to houses. This has been very popular in the villages as the uplift property value can be considerable but it removes stock from the village. Even worse though is developers buying up bungalows in order to knock them down and develop their plots with multiple housing units.

I am supportive of the Council's approach to age inclusivity, when it comes to housing allocation for bungalows.

Policy H3:
It is not clear what type or size of extra care facility will be required for planning applications for more than 300 dwellings. I felt this was lacking some detail.

5.9.2: This introduces inequality to the system. Developers putting in planning applications close to where an existing extra care facility is, will have considerably less cost in provision onsite than those that have to commission a whole facility (which I assume will have a minimum size requirement to make it a viable operation (?))

5.15.4: It would be nice to be able to do more than ‘encourage’ developers to invest in rural facilities. Considering the growth Harlington is seeing, it is very disappointing that there will be no new facilities as part of this, yet the village only has a few shops.

6.15.1: I approve of this approach, to review viability mitigation at the time housing is sold. It needs to be robust so that all benefit from cost engineering is lost and gaming of the system will not pay off. It should be calculated in actual monetary terms for the site in question, so that developers are not incentivised to provide affordable housing elsewhere, where it can be achieved more cheaply.

Attachments:

Comment

Housing Policy Technical Guidance SPD

Housing Policy Technical Guidance SPD

Representation ID: 16327

Received: 07/03/2023

Respondent: Cllr Silvia Collins

Representation Summary:

Rural villages need more bungalows to meet demand and enable downsizing. Policy also needs to incentivise delivery of new ones and disincentivise conversions of existing ones. Clearer definition of 'bungalow' required to prevent creative interpretations.

Policy H3 needs clarification.

Potential financial incentives for developers, to put in applications close to where there are existing extra care facilities, need to be removed.

Developers need more encouragement to invest in rural facilities.

The approach to viability mitigation for affordable housing (costed at sale) is especially good but must avoid potential to game the system e.g. by mitigating offsite, in cheaper locations.

HP06
A05

Full text:

Bungalows:
We need a clearer definition of what a bungalow is. Although bungalows are referred to in the glossary, this has been subject to creative interpretation by developers, in order to infer an application was meeting CBC's housing requirements for the older age groups. As an example, attached is a drawing of one dwelling which was described as a '3 bedroom bungalow' suitable for older residents.

More bungalows are needed in villages to allow elderly residents to downsize but remain in their established community. The document recognises the benefit of this and that this will free up larger properties for families etc but it is not strong enough on delivery. Bungalows are ‘encouraged’ but lumped in with other housing types considered suitable. They are unlikely to be the preferred option by developers because of the ground space they occupy. Thus, we are unlikely to see many come forward without specific policy requirements or incentives.

We should also consider how it might be possible to disincentivise investors buying up bungalows for conversion to houses. This has been very popular in the villages as the uplift property value can be considerable but it removes stock from the village. Even worse though is developers buying up bungalows in order to knock them down and develop their plots with multiple housing units.

I am supportive of the Council's approach to age inclusivity, when it comes to housing allocation for bungalows.

Policy H3:
It is not clear what type or size of extra care facility will be required for planning applications for more than 300 dwellings. I felt this was lacking some detail.

5.9.2: This introduces inequality to the system. Developers putting in planning applications close to where an existing extra care facility is, will have considerably less cost in provision onsite than those that have to commission a whole facility (which I assume will have a minimum size requirement to make it a viable operation (?))

5.15.4: It would be nice to be able to do more than ‘encourage’ developers to invest in rural facilities. Considering the growth Harlington is seeing, it is very disappointing that there will be no new facilities as part of this, yet the village only has a few shops.

6.15.1: I approve of this approach, to review viability mitigation at the time housing is sold. It needs to be robust so that all benefit from cost engineering is lost and gaming of the system will not pay off. It should be calculated in actual monetary terms for the site in question, so that developers are not incentivised to provide affordable housing elsewhere, where it can be achieved more cheaply.

Attachments:

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