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Contents Page - Issue 14 - Affordable and Particular Needs Housing

1. Schedule 4

2. Representations

Homes for Scotland (CLDP 041e)
Susan Morris (CLDP146)

3. Supporting Documents

CD012 Planning Advice Note 2/2010 - Affordable Housing and
Housing Land Audits (August 2010) (Paragraphs 5 & 22)
CD016 Letter from Chief Planner 'Planning for Affordable Housing'
(15th March 2011)
CD022 Designing Places - A Policy Statement for Scotland (2001)
CD023 Designing Streets - A Policy Statement for Scotland (2010)
CD035 Proposed Supplementary Guidance 1 - Developer
Contributions (November 2013)
CD037 Proposed Supplementary Guidance 3 - Placemaking
(November 2013)
CD039 Proposed Supplementary Guidance 5 - Affordable Housing
(November 2013)
CD050 Clackmannanshire Council Housing Needs and Demand
Assessment 2011
CD051 Clackmannanshire Council Housing Needs and Demand
Assessment Summary 2011
CD052 Clackmannanshire Strategic Housing Investment Plan 2013-
2018
CD053 Clackmannanshire Housing Strategy 2012-2017
SD16 Homes for Scotland (CLDP 041e) - Cover Letter



















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Issue 14 Affordable and Particular Needs Housing
Development Plan
reference:
Forth Area Statement - Services,
(Page 22, Paragraph 7.07)
Chapter 5 - Creating Sustainable
Communities - Affordable and
Particular Needs Housing (Page 34,
Paragraphs 5.11 - 5.17)
Reporter:
Body or person(s) submitting a representation raising the issue
(including reference number):

Homes for Scotland (CLDP 041e)
Susan Morris (CLDP146)

Provision of the development
plan to which the issue relates:
Affordable and Particular Needs
Housing
Planning Authoritys summary of the representation(s):

Homes for Scotland (CLDP 041e) While the Housing Needs and Demand
Assessment (CD050 & CD051) clearly highlights a high need in
Clackmannanshire for social rented housing, it also sets out a need for low
cost home ownership and mid-market rent tenure affordable housing.
Developers must be able to provide these tenures as well, otherwise housing
delivery will be affected.

Due regard must be taken of the Chief Planners letter dated March 2011
(CD016) advising local authorities not to stifle housing supply with unrealistic
affordable housing requirements if there is no availability of Scottish
Government funding for the development.

It should also be made clear that if a developer is building social rent units to
transfer over to the Council it will be a lesser number of units at the equivalent
value to providing the serviced land for affordable housing, again as set out in
PAN 02/2010 (paragraph 22) (CD012).

Paragraph 5.14 is at odds with paragraph 5.12. It states the Council will
seek to achieve a range of tenures... but the Council in paragraph 5.12 refers
only to on-site provision of social rent.

Susan Morris (CLDP146) Feels generally the LDP does not adequately
address issues relating to accessibility to services and recreational facilities
for people with disabilities. Specifically, no detail is reflected in the LDP about
the housing needs of those with disabilities. Perhaps this is covered in the
Housing Needs and Demand Assessment (CD050 & CD051) but if so, no
specifics are mentioned.

There are comments that combine matters about elderly and disabled - as if
they have the same needs. It is further implied that only minor internal
modifications, rather than spatial changes, are needed for suitable housing
which is an odd assertion, and that building regulations will take care of most
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issues. Building regulations apply broadly and therefore only ever really set
out a generic, minimum standard which can apply in most situations - clearly
this won't deal with the specific housing needs of many with disabilities. The
LDP contains broad generalisations which do not address the needs of many
disabled citizens in the County. If such generalisations are allowed in the LDP,
it blocks the way to the more detailed consideration that would be helpful to
resolve current problems. Specifically, there needs to be recognition of the
needs of families with a disabled family member, particularly wheelchair users
whether parents or children.

At a time when the Council's grant funding for adapting existing houses is
being drastically reduced, it would be far more sensible to consider ahead the
need for alternative properties and locations for new build. This is not an issue
that the market will ever take care of and it therefore requires specific planning
intervention if these needs are to be met.

There is a lack of mix of house tenure, types and sizes and developments
should provide for a variety of housing need. It requires innovative working by
the Council. As a starting point an effective assessment of the housing needs
of those with disabilities would be a start.

In conclusion, it cannot be seen how the LDP effectively addresses housing
needs of those with disabilities and consideration of more specific action on
the issues is strongly urged.

Modifications sought by those submitting representations:

Homes for Scotland (CLDP 041e) Rewrite the LDP to make clear the
preference is for social rent but if there is no funding available from the
Scottish Government then developers are able to fulfil their requirement
through other tenures as set out in PAN 02/2010 (paragraph 5) (CD012), or in
a commuted sum. It should be clear that if a developer is building social rent
units to transfer over to the Council it will be a lesser number of units at the
'equivalent value' to providing the serviced land.

The Proposed LDP must secure a good housing mix in our communities and
allocate for a variety of house sizes. There are not enough social-rented
homes.

Susan Morris (CLDP146) The Proposed LDP must be more specific about
accessibility and the needs of disabled persons.

Summary of responses (including reasons) by Planning Authority:

Homes for Scotland (CLDP 041e) The Proposed LDP seeks to enable with
some degree of certainty, the delivery of affordable homes where they are
clearly needed and allocates land for housing making it clear where affordable
homes are required.

The LDP is supported by Supplementary Guidance 5 - Affordable Homes
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(CD039), which provides fuller detail on the context for the delivery of
affordable homes in Clackmannanshire. The Council maintains this approach
and guidance is consistent with national planning policy and guidance and
seeks a collaborative approach in enabling delivery. Through joint working
between housing and planning interests SG5 (CD039) is supported by the
Council's investment plan (SHIP) (CD052) which identifies specific sites to
provide for more affordable homes across the County.

Paragraphs 5.11-5.12 of the LDP stress that the Council's preference is for
social rented homes to be built on-site when dealing with larger sites. It does
not indicate that social rented is the only tenure to be provided, but rather
seeks a collaborative approach that aims to secure affordable homes
appropriate for any particular development.

SG5 (CD039) also describes the basis for any calculation on the level of
provision or alternative commuted sum to be agreed i.e. it is mentioned that
matters are to be the subject of a formal planning agreement where required.

It is therefore maintained that the Proposed LDP provides a degree of
certainty for the development industry from the earliest planning stages on
where negotiations are required for the supply of affordable homes.

It is agreed that the basis for any financial commitment in this regard must be
compatible with national policy and guidance. Homes for Scotland have
rightfully highlighted the need for any calculations on the level of financial
requirement to be consistent. This is agreed and the Council clearly states a
fair approach for such deliberations in Supplementary Guidance 5 'Affordable
Housing' (CD039) and Supplementary Guidance 1 'Developer Contributions'
(CD035) to enable efficient delivery. In particular, the Council's approach is
flexible enough to ensure that any financial commitment for affordable homes
sought is commensurate with local circumstances whilst meeting
requirements e.g. if there is an overall need for significant enhancement in
infrastructure arising from the proposed development and that is placed on the
developer such that it may adversely affect the economic viability of the
proposed development then a reduced level of affordable homes provision
might be agreeable (paragraph 8.1, SG5) (CD039), where the evidence
clearly shows and it can be agreed. For the avoidance of any doubt SG5,
Section 8 'Delivery examples' (page 7-8) (CD039) fully describes the way
delivery will be sought. No changes are therefore sought to the LDP.

Susan Morris (CLDP146) The Proposed LDP emphasises that development
proposals must formulate their design solutions based on the principles
contained in national planning policy statements 'Designing Places' (CD022)
and 'Designing Streets' (CD023). This includes creating new places that are
"adaptable" and provide quality access for all in the community. Proposed
Supplementary Guidance 3 'Placemaking' (CD037) refers to the need to fully
consider those with disability (page 21, paragraph 5.22). Page 15 gives the
third criterion in Key Quality of Successful Places: 'Easy to move around in',
and bullet eight asks "Have inclusive design principles been incorporated into
the new development in order to ensure access for all?".
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Policy SC12 'Development Proposals - Access and Transport Requirements'
(page 51) emphasises the application of the national statements and requires
"...excellent accessibility and mobility for all users, including walkers, cyclists,
and those with special needs and is safe and attractive.".

Paragraph 5.15, page 35 of the LDP mentions that new build schemes should
deploy scope through design of buildings and sites with a variety of sizes and
layout to cater for changing needs. The Council's Housing Needs and
Demand Assessment (2011) (CD050 & CD051) clearly identifies the nature of
special housing needs in the area and the Housing Strategy sets a framework
for joint working to deliver for assessed housing need, i.e. Planning and
Housing Services with prospective developers, working towards delivery of
special housing needs where required. Although particular housing needs are
not mentioned directly in any policy within the Proposed LDP, effective
delivery will be sought through joint working. Therefore, along with affordability
issues the need for different house types, tenures, and sizes will be guided by
the Council's Local Housing Strategy (CD053), its evidence base (the Housing
Needs and Demand Assessment, 2011) (CD050 & CD051), and related
delivery plans. The Proposed LDP Schedule of Sites includes for larger
housing sites that "Proposals (are) to include details of house numbers, sizes,
and any affordable housing provision". No changes are therefore sought to
the LDP.

Reporters conclusions:

Reporters recommendations: