SECTION 1 – Context & Background

1.1

Please tick one of the following options:

This EIA is being carried out on:

☐New policy / strategy

☐New service

☐Review of policy / strategy

☐Review of service

☐Commissioning

☒Other project (please give details)Supplementary Planning Document for Affordable Housing

1.2

In summary, what is the background to this EIA? 

The Affordable Housing Supplementary Planning Document (SPD) adds further details to the Local Plan which was adopted on 6^th December 2017 and for which EIA was undertaken. SPDs do not introduce new policy, but provide further detail and guidance to enable the delivery of adopted policies.

Delivering sufficient affordable homes over the Plan period to 2031 is a key objective of the adopted Coventry Local Plan. The aim of this SPD is to facilitate the delivery of affordable homes as set out in the plan and in compliance with the most up to date national policy as set out in the National Planning Policy Framework.

The additional guidance provided within the SPD sets out the different types of affordable housing as defined by Government and provides the detail on how these should be delivered.  This includes setting out the process in agreeing affordable housing delivery, affordability types and tenures, dwelling design, management structures and Section 106 Agreements for securing delivery.

1.3

Who are the main stakeholders involved?  Who will be affected?

Developers who are required to deliver affordable housing, providers of affordable housing, and those members of the community who need to access affordable homes. The National Planning Policy Framework (NPPF) defines affordable housing as ‘housing for sale or rent, for those whose needs are not met by the market (including housing that provides a subsidised route to home ownersip and/ or is for essential local workers)’. Further detail on the definition can be found here https://www.gov.uk/government/publications/national-planning-policy-framework--2 : this includes detail on the different types of product including affordable housing for rent, starter homes, discounted market sales housing and other affordable routes to home ownership.

Coventry City Council Planning Policy Service

SECTION 2 – Consideration of Impact

The Local Plan was formulated using detailed evidence including a Strategic Housing Market Assessment. The Local Plan was independently examined by a Planning Inspector to ensure that its policies were robust and formulated using appropriate evidence before it could be sound and capable of adoption. Further detail on the Local Plan and the evidence base can be found here https://www.coventry.gov.uk/localplan

This SPD details how the policy will be delivered, setting out the process in agreeing affordable housing delivery, affordability types and tenures, dwelling design, management structures and Section 106 Agreements for securing delivery.

Protected

Characteristic

Impact type

P, N, PN, NI or ID

Nature of impact and any mitigations required

Age 0-18

P

Affordable housing is aimed at those whose needs are not met by the market. Whilst those aged 0-18 would generally not be directly able to access affordable products, many will live in households where their parents and carers will not be able to afford open market homes and thus they will indirectly benefit from the policy. 22.5% of children live in low income families which is above the regional and national average (20.2% and 17% respectively)[1]

Age 19-64

P

Affordable housing is aimed at those whose needs are not met by the market. The average gross disposable household income for Coventry is below the regional and national average (£15,353 per head per annum compared to £18,222 and £21,609 respectively in 2018), and the average house price was £185,000 (October 2019 to September 2020 figures). Currently the claimant count stands at 15,320 (ONS July 2021) compared to 8,000 in March 2020. As well as the affordable housing for rent product, the government is promoting a variety of routes to home ownership including starter homes and discounted market sales housing which are most likely to apply to this age group.

Age 65+

P

See above in terms of disposable household income and average house prices. Some affordable housing products (as defined by the Government in the National Planning Policy Framework) will be applicable depending upon the individual / household circumstances

Disability

ID

No direct impact although some affordable products will be applicable depending upon the individual / household circumstances

Gender reassignment

ID

No direct impact although some affordable products will be applicable depending upon the individual / household circumstances

Marriage and Civil Partnership

ID

No direct impact although some affordable products will be applicable depending upon the individual / household circumstances

Pregnancy and maternity

ID

No direct impact although some affordable products will be applicable depending upon the individual / household circumstances

Race (Including: colour, nationality, citizenship ethnic or national origins)

ID

No direct impact although Coventry has a diverse population and affordable products will be applicable depending upon the individual / household circumstances

Religion and belief

ID

No direct impact although some affordable products will be applicable depending upon the individual / household circumstances

Sex

ID

No direct impact although some affordable products will be applicable depending upon the individual / household circumstances

Sexual orientation

ID

No direct impact although some affordable products will be applicable depending upon the individual / household circumstances

2.3

Health inequalities (HI) are unjust differences in health and wellbeing between different groups of people which arise because of the conditions in which we are born, grow, live, work and age. These conditions influence our opportunities for good health, and result in stark differences in how long we live and how many years we live in good health.  

Many issues can have an impact: income, unemployment, work conditions, education and skills, our living situation, individual characteristics and experiences, such as age, gender, disability and ethnicity

A wide range of services can make a difference to reducing health inequalities. Whether you work with children and young people, design roads or infrastructure, support people into employment or deal with welfare benefits – policy decisions and strategies can help to reduce health inequalities

Please answer the questions below to help identify if the area of work will have any impact on health inequalities, positive or negative.

Question

Issues to consider

2.3a What HIs exist in relation to your work / plan / strategy

·   Explore existing data sources on the distribution of health across different population groups (examples of where to find data to be included in support materials)

·   Consider protected characteristics and different dimensions of HI such as socio-economic status or geographical deprivation

Response:

The Affordable Housing SPD supplements the policies of the adopted Local Plan which was subject to Health Impact Assessment. The Health and Wellbeing chapter of the plan, which includes Policy HW1, requires Health Impact Assessments for particular types and scale of development where there could be significant impacts. See https://www.coventry.gov.uk/localplan This was supplemented by a Health Impact Assessment SPD which provided further detail and guidance including that in relation to affordable housing. See https://www.coventry.gov.uk/downloads/file/28900/health_impact_assessment_spd

2.3b How might your work affect HI (positively or negatively).

How might your work address the needs of different groups that share protected characteristics

Consider and answer below:

·   Think about whether outcomes vary across groups and who benefits the most and least, for example, the outcome for a woman on a low income may be different to the outcome for a woman a high income

·   Consider what the unintended consequences of your work might be

Response:

a.      Potential outcomes including impact based on socio-economic status or geographical deprivation

The Health Impact Assessment SPD referred to above includes the following:

b.      Potential outcomes impact on specific socially excluded or vulnerable groups eg. people experiencing homelessness, prison leavers, young people leaving care, members of the armed forces community.

Ensuring access to a range of affordable housing products to meet a range of needs and circumstances is a key aim of the Local Plan housing policies and the SPD provides the further detail to ensure that policy can be delivered.

2.4

Next steps - What specific actions will you take to address the potential equality impacts and health inequalities identified above?

This was considered through the Local Plan (the ‘parent document’), this document provides the detail to ensure the Local Plan policies can be delivered effectively

2.5

How will you monitor and evaluate the effect of this work?

The Local Plan already includes monitoring indicators.

No

As the appropriate Head of Service for this area, I confirm that the potential equality impact is as follows:

No impact has been identified for one or more protected groups             ☐

Positive impact has been identified for one or more protected groups      ☐

Negative impact has been identified for one or more protected groups    ☐

Both positive and negative impact has been identified for one or more protected groups     ☐                                                                                          

Signed: Head of Service:

David Butler

Date:  02/09/2021

Name of Director:

Andrew Walster

Date sent to Director:

02/09/2021

Name of Lead Elected Member:

Councillor David Welsh

Date sent to Councillor:

06/09/2021