Consultation Response: Affordable Housing

I responded to the council’s consultation on their updated Affordable Housing policy. Here’s my response.

It’s quite a technical response, so here is a summary:

The introduction to the draft Affordable Housing SPD reveals a shocking decline in the amount of affordable housing delivered in Norwich since the publication of the National Planning Policy Framework (NPPF) in 2012.  Whilst the City Council should be applauded for building new council housing itself, the obligation of developers to contribute is being eroded by insufficiently robust policy at both a national and local level.  

At present, the draft document includes some welcome changes from the 2015 version (such as the requirement for purpose-built student accommodation to provide an affordable housing contribution), but also includes content that is contrary to national planning practice guidance (NPPG) and other content that is simply not detailed enough to have any meaning when it comes to its application.

Whilst the ability of this document to defend the council’s affordable housing policy is limited due to the limitations in the government’s underlying national policy, there are several opportunities to strengthen it which are not included within this draft, and which are summarised below.

  • The definition of affordable housing does not state how it would remain affordable once sold on to another buyer. 
  • The document does not provide a process to ensure a mix of affordable tenures, or a method of making sure that the development is as attractive as possible to Registered Providers (Housing Associations).
  • The document states that the weight given to a Viability Assessment is a matter for the decision maker but fails to specify under what circumstances a Viability Assessment may or may not be given weight.
  • There are a number of references to “land-owners” profit which are contrary to the NPPG, as these should instead be referring to the developer’s profit, since the land-owners profit should already be factored into the price of the land. 
  • There is no guidance on who is responsible for developing the plan-making stage viability assessments.
  • There is no real acknowledgement that the acceptable level of profit for both land-owner and developer should be based on risk, not arbitrary percentages.  
  • The document also does not state whether or not the viability assessment should take into account the risk of planning refusal.