Affordable Housing Supplementary Planning Document

Chapter 2: Policy Context

2.1 The Coventry Local Plan 2017 was prepared under previous iterations of the National Planning Policy Framework, but the provisions relating to affordable housing remain relevant in the context of the adopted Local Plan 2017.

2.2  The local planning policy position is established in Section 4 of the Coventry Local Plan 2017. Specifically, Policy H6 asserts the affordable housing delivery considerations and requirements for residential developments in the city.

National Planning Policy Framework

2.3 The National Planning Policy Framework 2021 (known hereafter as the ‘NPPF’) provides the overarching national planning policy basis for England and includes provisions for how Local Planning Authorities should achieve affordable residential development. Paragraphs 61-64 establish this;

  • Ensure local policy reflects the housing needs of different groups within the community, including affordable housing requirements;
  • Identify the affordable housing type needed and delivered on-site, with off-site provision, or financial contribution, if appropriate justification can be demonstrated;
  • Emphasise the need to deliver affordable housing, in most circumstances, on major development sites;
  • Promote the redevelopment and re-use of brownfield land through reducing affordable housing contribution by a commensurate amount where vacant buildings are re-used.

2.4 Furthermore, the NPPF provides a definition of affordable housing at Annex 2. For the purposes of this SPD and to ensure consistency between it and national policy, the definition of affordable housing will be as follows as it is established at Annex 2;

Affordable housing: housing for sale or rent, for those whose needs are not met by the market (including housing that provides a subsided route to home ownership and/or is for essential workers); and which complies with one or more of the following definitions:

 a) Affordable housing for rent: meets all of the following conditions: (a) the rent is set in accordance with the Government’s rent policy for Social Rent or Affordable Rent, or is at least 20% below local market rents (including service charges where applicable); (b) the landlord is a registered provider, except where it is included as part of a Build to Rent scheme (in which case the landlord need not be a registered provider); and (c) it includes provisions to remain at an affordable price for future eligible households, or for the subsidy to be recycled for an alternative affordable housing provision. For Build to Rent schemes affordable housing for rent is expected to be the normal form of affordable housing provision (and, in this context, is known as Affordable Private Rent).

b) Starter homes: is as specified in Sections 2 and 3 of the Housing and Planning Act 2016 and any secondary legislation made under these sections. The definition of a starter home should reflect the meaning set out in statute and any such secondary legislation at the time of the plan-preparation of decision-making. Where secondary legislation has the effect of limiting a household’s eligibility to purchase a starter home to those with a particular maximum level of household income, those restrictions should be used.

c) Discounted market sales housing: is that sold at a discount rate of at least 20% below local market value. Eligibility is determined in regard to local incomes and local house prices. Provisions should be in place to ensure housing remains at a discount for future eligible households.

d) Other affordable routes to home ownership: is housing provided for sale that provides a route to ownership for those who could not achieve home ownership through the market. It includes shared ownership, relevant equity loans, other low cost homes for sale (at a price equivalent to at least 20% below market value) and rent to buy (which includes a period of intermediate rent). Where public grant funding is provided, there should be provisions for homes to remain at an affordable price for future eligible households, or for any receipts to be recycled for an alternative affordable housing provision, or refunded to Government or the relevant authority specified in the funding agreement.”

Non-statutory Regional Policy

2.5 The West Midlands Combined Authority (the ‘WMCA’) provides additional definitions in regard to affordable housing. Although the Combined Authority does not have statutory planning powers, it plays a significant role in realising funding streams for affordable housing delivery as well as releasing previously undeliverable sites for development.

2.6 The Combined Authority’s definition of affordable housing goes beyond the statutory definition as referenced in the NPPF by stating that to be truly affordable, residents should not pay more than 35% of their income towards their monthly rent or mortgage. This establishes a greater discount of 15% when made against the definition referenced in the NPPF 2019, which asserts that a 20% discount from the prevailing rate as an affordable rate.

2.7 Whilst this definition cannot be granted any planning weight and is not a material planning consideration, as a full member of the Combined Authority, Coventry City Council encourage applicants to consider provision against this definition. Particularly where the WMCA has facilitated delivery of affordable housing through funding and land-release strategies.

Local Planning Policy

2.8 The Coventry Local Plan 2017 provides the strategic housing requirement for the city over the Plan period from 2011 to 2031. This includes the need to deliver affordable housing alongside market development, to foster sustainable communities and that those residents which are eligible, can access good and truly affordable housing. This is in line with the Council’s Housing and Homeless Strategy 2014.

Screenshot 2021-11-11 133759

2.9 Set within the context of the objective housing need of the city in the region of 42,000 homes between 2011 and 2031, the Plan recognises a need to deliver some 12,000 affordable homes over this period. That equates to the delivery of around 600 affordable homes per annum. It should be noted that a proportion of this need will be delivered across the Warwickshire Housing Market Area through cross-boundary delivery and as such, the pro-rata affordable yearly quantum, which takes into account the established city capacity and cross-boundary apportionment, equates to 348 dwellings per year.

2.10 At the time of the Plan’s adoption in 2017, it was established that during the first 4 years of the Plan period (2011 to April 1st 2015), approximately 1,150 affordable homes benefited from planning permission, were being constructed or had been delivered.

2.11 These identified numbers, taken alongside the strategic allocations, which will deliver a further 3,300 affordable homes, a shortfall of 1,150 affordable homes was identified.

2.12 The accompanying text to the affordable housing policy of the Plan identifies that this shortfall will be resolved through achieving affordable housing delivery from a variety of sources. This includes the Private Rented Sector, windfall sites, redevelopment of existing housing stock, Registered Provider (“RP”) site delivery and re-use of empty homes.

2.13 It should be noted that a core element of this strategic policy is its spatial element. This is to ensure that different areas of the city can experience the maximum benefit of the policy and to ensure those residents in need of affordable accommodation, wherever their location in Coventry, can be housed in affordable homes. It is considered that this spatial approach will also ensure the development of cohesive and socially representative communities in all parts of the city.

2.14 Delivery of affordable housing will be actively monitored by the Council and represented through the publication of yearly Authority Monitoring Reports. This ongoing monitoring will identify levels of affordable housing delivery against the requirement established in the adopted Coventry Local Plan 2017, which is in the region of 348 dwellings per annum.

2.15 This SPD will help to facilitate enhanced delivery of affordable housing in the City, thereby contributing towards meeting the identified needs of the Local Plan 2017.