Basingstoke and Deane Local Plan Update 2021 to 2040 Draft for Regulation 18 Consultation January 2024
HSG2 Affordable Housing
Object
Paragraph 4.16 of the Regulation 18 Local Plan states that the Council is making provision for a “sufficient” number of affordable homes to meet the needs identified through the Council’s Housing Market Assessment.
The Council’s Affordable Housing Needs Update (June 2023) states that the affordable housing need for the Borough is currently 169dpa - just under 20% of the total number of homes identified using the standard method (850dpa). Between 2026 and 2031, when the Council proposes to adopt a lower requirement of 660dpa, this will be approximately 26% of the housing target.
However, the Housing and Homelessness Strategy (2023-2027) which is referenced in the Council’s latest Authority Monitoring Report (December 2023) identifies a much higher target of 300 net affordable homes a year. If this figure were to be maintained through to 2031, this would require just over 45% of all new homes to be affordable. Whilst in absolute terms, the Council delivered against its target, this is below the 40% requirement of Policy HSG2 and the percentage which will be required between 2026 and 2031.
The affordable housing need figure is based on the assumption that approximately 55% of the 5,836 households in the Borough which are currently in unsuitable housing or without their own home, are able to afford both entry-level private rent and entry-level owner-occupation housing, which reduces the current need to 2,610 households. This assumes that 3,226 households are in a position to leave the affordable housing sector and find suitable accommodation in the private sector. This is of course an unsatisfactory position as the private rental sector of course does not have the same levels of tenancy security as affordable housing.
However, this may not be the case in reality. Firstly, there is the question as to whether there is the housing stock available in the private sector to accommodate these households, particularly when the Council is currently unable to demonstrate a five-year housing land supply and is intending to lower the housing target for the first five years after adoption of the Local Plan. Secondly, there is not necessarily a direct correlation between 35% of gross income being spent on housing costs and households no longer being eligible for affordable housing (a household spending less than 35% of gross income on housing may still qualify for affordable housing) and whether, in the case of home ownership, households have the funds to afford an initial deposit.
The report also states that there is a committed supply of 2,609 affordable homes. It is unclear where this figure has come from or to what period of time it relates. The latest Authority Monitoring Report (2023) shows that the Council has a supply of 3,817 homes in the next five years. It is not clear how many of these are expected to be affordable. However, given that in the monitoring year 2022/23 the Council delivered 274 affordable homes against an overall housing target of 850 dwellings (just over 32%), it would follow that approximately 1,221 dwellings might be affordable (although this figure may well be less). This is of course well below the 2,609 figure referenced in the Affordable Housing Needs Update (June 2023). Allocations in the emerging Local Plan cannot be considered to constitute a committed supply and it is recommended that this point is clarified by the Council.
Policy HSG2 requires at least 40% affordable homes are provided on sites of 10 or more dwellings, or on all sites delivering new dwellings in the North Wessex Downs National Landscape. Whilst this appears to exceed the need identified in the Affordable Housing Needs Update, it is not clear whether the proposed site allocations can meet the 40% requirement from a viability perspective. It does not appear that the Council has undertaken a viability assessment which determines whether the strategic sites will be able to deliver 40% affordable housing in accordance with policy. This is required in order to ensure that the policy is effective and justified. It is also the case that sites below 10 homes, wherever they are in the district, would not deliver any affordable housing.
Further, with the spatial strategy relying on delivery late into the Plan period, it is likely that the number of affordable homes being delivered will decrease between now and the time when the strategic sites are being delivered. This does little to assist the nearly 6,000 households currently in unsuitable homes or without a home.
The need for deliver more affordable housing provides a clear basis for increasing the housing requirement in the Plan above that identified as the starting point using the standard method.
The delaying of much-needed affordable housing is not considered to be an effective strategy. Nor is it positively prepared or justified. As such, the proposed affordable housing strategy is not considered to be sound.