PLANNING AND COMPULSORY PURCHASE ACT 2004 · 2017. 11. 7. · PLANNING AND COMPULSORY PURCHASE ACT 2004 The Town and Country Planning (Local Development) (England) Regulations 2004

PLANNING AND COMPULSORY PURCHASE ACT 2004

The Town and Country Planning (Local Development) (England) Regulations 2004

Submission Core Strategy Development Plan Document

Hearing Statement of Stafford Borough Council For Session 6 – Core Policies 2, 3 & 10

Affordable Housing (C/HSS6/AH)

Date : 19/05/2006

Hearing Statement of Stafford Borough Council For Session 6 - Affordable Housing

Contents Page

Section Title Page

1.0 Introduction 1

2.0 Hearing Statement of Stafford Borough Council for Session 6 – Affordable Housing

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Hearing Statement of Stafford Borough Council For Session 6 - Affordable Housing

1.0 Introduction 1.1 The key objective for planning policies in the Core Strategy Development Plan

Document is to deliver the strategic approach for spatial planning across the Borough Council area. The Core Strategy Development Plan Document will be the principal planning document in the Stafford Borough Local Development Framework and will form part of the new Development Plan for Stafford Borough alongside the Regional Spatial Strategy for the West Midlands (RSS). The Core Strategy will aim to cover the same time period as the Regional Spatial Strategy.1

1.2 The purpose of this Hearing Statement is to prepare for the independent

Examination into the Submission Core Strategy Development Plan Document in accordance with Section 20 of the Planning and Compulsory Purchase Act 2004 and requirements set out in the Town and Country Planning (Local Development) (England) Regulations 2004. This Hearing Statement presents the Council’s response to the agenda for Session 6 - Affordable Housing of the Core Strategy Development Plan Document Independent Examination.

1 2001-2021

Stafford Borough Council - Local Development Framework Examination - Core Strategy Development Plan Document

Hearing Statement for Session 6 - Affordable Housing

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STAFFORD BOROUGH COUNCIL - CORE STRATEGY DPD EXAMINATION

AGENDA FOR SESSION 6 - AFFORDABLE HOUSING

1 Affordable Housing within the Core Strategy

• Should the DPD give a fuller coverage of affordable housing requirements? • If so, in what form should this be done?

2 The rate of provision of affordable housing

• Should this DPD include a target for provision? • If so, what should it be?

3 Locational Consideration

• Should this DPD set out an area based approach to provision? • If so, what should it be?



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RELEVANT SECTIONS OF THE SUBMISSION CORE STRATEGY DEVELOPMENT PLAN DOCUMENT Core Policy 2: Sustainable Rural Living

The purpose of this policy is to ensure that new development maintains and improves the character and quality of life in the rural area and its settlements.

SUBMISSION POLICY The essential character and economic and social fabric of rural areas and settlements shall be maintained or improved to meet local needs by: a) encouraging development at an appropriate scale and location which assists in

supporting existing businesses or diversifying the local economy, to help to underpin or improve services, community facilities and local employment;

b) the provision of housing to meet the needs of existing rural communities including affordable homes and housing for key workers;

c) ensuring that development protects, conserves and enhances the rural setting whilst not having undesirable impacts on local infrastructure, facilities and transportation networks;

d) conserving and enhancing the natural, built, historic and water environments; e) maximising the use of previously developed land in preference to greenfield sites; and f) ensuring that new development provides adequate foul drainage services to prevent pollution to controlled waters.
Core Policy 2 is linked to Spatial Objective 2 & 11 Indicator
Affordable housing completions - Number of affordable houses completed outside Stafford and Stone per year Target: 10 affordable houses completed (measured from 2007) Percentage of new housing development on previously developed land in rural areas Target: 70% by 2011 80% by 2021 (measured from 2007)

Milestones 2011, 2016 & 2021 Implementation Development industry Landowners Registered Social Landlords Timescale for Delivery 2001 - 2021



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Core Policy 3: Sustainable Urban Living The purpose of this policy is to encourage partnership working to deliver quality development schemes in the urban areas of Stafford and Stone.

SUBMISSION POLICY Sustainable urban living will be achieved by encouraging and implementing initiatives which will enhance the image, improve opportunities for physical activity, create vitality and improve safety, comfort and environmental quality. This approach will be developed through partnerships with other agencies and the development industry, for schemes and proposals which: a) Maintain and enhance the viability and sustainability of urban areas whilst facilitating

new built development, economic investment and diversification; b) enhance the image, attractiveness and accessibility of the town and district centres

within the urban areas, boost vitality and encourage new investment; c) aim to reclaim and reuse derelict, contaminated, degraded, vacant or underused land

and buildings for new development in preference to taking greenfield land; d) seek to improve the availability, accessibility, quality and diversity of the housing stock,

including the provision of affordable housing; e) protect, conserve and enhance the character and quality of the Borough’s townscapes

and public realm; f) protect and enhance environmental quality through the creation, retention, improvement

and extension of areas of wildlife value, woodlands, open spaces, access to watercourses and historic assets where relevant;

g) provide high quality designed developments which will protect water quality, improve the quality of life and enhance the built environment; and

h) promote more sustainable transport choices and reduce the need to travel.

Core Policy 3 is linked to Spatial Objective 10 & 11 Indicator

Percentage of completed retail, office and leisure development in town centres Target: 60 – 80% completed in town centres (measured from 2007)

Affordable housing completions - Percentage of new housing development classified as affordable housing Target: 25% classified as affordable housing (measured from 2007)

Milestones 2011, 2016 & 2021



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Implementation Development industry Landowners Registered Social Landlords Stafford Borough Council – Economic Development Timescale for Delivery 2001 - 2021 Core Policy 10: Residential Development Provision The purpose of this policy is to meet the residential requirements for the Borough as set out in the Regional Spatial Strategy.

SUBMISSION POLICY Provision will be made for not more than the housing requirements for Stafford Borough identified in the West Midlands Regional Spatial Strategy, as set out in Table 2 below. In allocating sites for housing and considering applications for residential development, where appropriate the Council will have regard to the provisions of Planning Policy Guidance 3: Housing or its successor documents and the following:

(a) The capability of being served by public transport; (b) The availability of pedestrian and cycle links, being suitable for people with

mobility aids; (c) Access to the strategic highway network and proximity to employment locations; (d) The capacity of existing health, education services and provision of additional (or

improvements to existing) community facilities arising from increased demand; (e) The availability of utility services; (f) The ability to reuse previously developed land and buildings; (g) Viability, feasibility for implementation and capability for development; (h) Achieving acceptable densities; (i) Provision for housing mix and tenure including affordable housing and specialist

needs; and (j) The capacity of the strategic highway network.

Developments should be consistent with the creation of attractive and safe living environments, be in keeping with their surroundings and must not take valuable open space. Providing a range of housing types and tenures is an essential part of establishing choice for the whole community.



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Core Policy 10 is linked to Spatial Objective 5 & 6 Indicator Housing trajectory showing:

(i) net additional dwellings over the previous five year period or since the start of the relevant development plan document period, whichever is the longer;

(ii) net additional dwellings for the current year;

(iii) projected net additional dwellings up to the end of the relevant development

plan document period or over a ten year period from its adoption, whichever is the longer;

(iv) the annual net additional dwelling requirement; and (v) annual average number of net additional dwellings needed to meet overall

housing requirements, having regard to previous years’ performances.

Target: To be reported by the housing trajectory (measured from 2007) Percentage of new and converted dwellings on previously developed land. Target: 75 – 85% (measured from 2007) Percentage of new dwellings completed at:

(i) less than 30 dwellings per hectare; Target: 15% (measured from 2007)

(ii) between 30 and 50 dwellings per hectare; and Target: 70% (measured from 2007)

(iii) Above 50 dwellings per hectare. Target: 15% (measured from 2007)

Affordable housing completions Target: 35 affordable homes to be completed per year (measured from 2007)

Milestones 2011, 2016 & 2021

Table 2 – Annual average rates of housing provision for Stafford Borough based on Regional Spatial Strategy requirements and the Ministerial letter dated 15 June 2004.

Annual average rate of housing provision 2001 – 2007

375


323


206



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Implementation Table 3 - Current completions and commitments of residential land

Completions – 1 April 2001 to 31 March 2005

2,168 dwellings

Commitments at 2004, including planning permission and sites subject to consent following the signing of Section 106 agreements

1,574 dwellings

Development industry Landowners Registered Social Landlords Timescale for Delivery 2001 – 2021



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COUNCIL RESPONSE 2.1 The Council has considered each of the key questions raised in the agenda for

Session 6 in turn, as set out below:

Affordable housing within the Core Strategy

• Should the DPD give a fuller coverage of affordable housing requirements? 2.2 Prior to addressing the above question, the Council consider that it may be of

assistance to the Examination for this paper to reproduce (for ease of reference)

those six separate sources in which guidance on the definition/provision of

affordable housing is currently to be found:

National Policy (i) PPG3 Planning Policy Guidance 3: “Housing” (PPG3) sets out the Government’s guidance

on housing provision. Local Planning Authorities are advised to encourage the

development of a mix of housing types in their area including affordable housing to

meet local needs. These are material considerations when formulating planning

policy and determining planning applications.

(ii) Circular 6/98 Circular 6/98: “Planning and Affordable Housing” provides more detail including:

housing needs surveys, identifying suitable sites and securing affordable housing by

involving Registered Social Landlords (RSLs) and using conditions and obligations.

In particular, this sets out the following thresholds for sites on which Planning

Authorities are able to negotiate for the provision of affordable housing (to meet

proven local need):

- In settlements of more than 3,000 people, the thresholds applied are sites of

25 or more dwellings or a site area in excess of 1 hectare.

- In settlements of fewer than 3,000 people, the Planning Authority has the

discretion to adopt appropriate thresholds which are based on assessments

of local need (ie ‘Housing Needs Surveys’) and the availability of land for such

use.



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Regional Policy (iii) Regional Spatial Strategy In June 2004 Regional Planning Guidance for the West Midlands (RPG11) was

adopted and published. Following commencement of Part 1 of the Planning and

Compulsory Purchase Act 2004 Regional Planning Guidance has now become part

of the statutory development plan and is known as the Regional Spatial Strategy

(RSS). The RSS provides the regional spatial framework within which Local

Development Documents of the Stafford Borough Local Development Framework

(LDF) will be prepared. The RSS forms part of the statutory development plan

alongside the Development Plan Documents of the LDF.

The RSS incorporates the following policy, CF5, within the “Communities for the

future” chapter in respect of affordable housing:

CF5 A. Local Authorities, developers and social housing providers should co-

operate to create more balanced and mixed communities through the

provision of a range of house types and tenures within new housing

developments and sites across all parts of the region.

B. Local Authorities should keep under review the need for affordable

housing in their area, based on local housing needs assessments,

using a broadly consistent approach the production of which will be

co-ordinated by the Regional Planning Body. Both social and low cost

market housing should contribute to meeting the need for affordable

housing. Opportunities should be sought within the existing housing

stock where this would help the creation of mixed communities, as

well as through new-build…

D. Local Planning Authorities in their development plan should:

(i) indicate how many affordable homes need to be provided

throughout their plan area;



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(ii) in rural areas specify the balance of affordable housing to be

achieved between market towns and villages where there is a

need to retain or strengthen services; and

(iii) consider the need to prevent the unjustified use of affordable

housing provision for general market housing purposes.

E. Local Authorities should also consider whether there is a need for

affordable housing to be sought on sites below the thresholds set out

in national guidance in areas where low income households have

particular difficulty in affording local general market house prices.

Where local authorities can demonstrate that local circumstances,

particularly the likely viability of developments, justify adopting a lower

threshold, they should bring forward proposals through the

development plan process. This applies especially …….. in some

rural areas where appropriate thresholds should be set for settlements

of 3,000 or less.

Strategic Policy (iv) Staffordshire and Stoke on Trent Structure Plan 1996-2011 The Staffordshire and Stoke on Trent Structure Plan 1996-2011 provides a broad

planning framework for Stafford Borough over the period 1996-2011 through a

comprehensive, sustainable strategy relating to land use, transportation and the

environment. The following planning policies from the Structure Plan relate to

affordable housing:

H8 Affordable Housing

H10 Affordable Housing in Rural Areas

It should be noted that following commencement of the Planning and Compulsory

Purchase Act 2004 the new development plan will be made up of the Regional

Spatial Strategy and Development Plan Documents within the Local Development

Framework. As part of the existing development plan the Staffordshire and Stoke on

Trent Structure Plan 1996-2011 will only be saved for three years until 2007.



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Local Policy (v) The Stafford Borough Local Plan 2001 Currently the Stafford Borough Local Plan 2001, covering the period 1986 to 2001,

and the Staffordshire and Stoke on Trent Structure Plan 1996-2011 make up the

adopted development plan for the area. Following commencement of Part 2 of the

Planning and Compulsory Purchase Act 2004 the Local Plan element of the

development plan will be replaced by Development Plan Documents within the Local

Development Framework along with the Regional Spatial Strategy.

The following planning policies from the adopted Stafford Borough Local Plan 2001

relate to affordable housing:

HOU17 Provision for Affordable Housing

HOU18 Subsidised Affordable Housing

HOU19 Affordable Housing on Exception Sites

(vi) Housing Needs Survey The Housing Needs Survey for the Borough defined affordable housing as follows:

“Affordable housing is that provided with subsidy, both for rent and low cost market

housing, for people who are unable to resolve their housing requirements, in the

general housing market because of the relationship between local housing costs and

incomes.”

However, following the undertaking of an up-date in 2004 of the 2002 study the

definition of affordable housing has been amended to be:

“Affordable housing is that provided with subsidy, both for rent and low cost market

housing, for people who are unable to resolve their housing requirements, in the

general housing market because of the relationship between local housing costs and

incomes.”

The up-date recommended that a quarter of affordable housing provided on new

sites should be subsidised low cost market housing, but acknowledges that the

changed relationship (between the original study in 2002 and the up-date in 2004)



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between incomes and prices will mean that the number of people who can access

housing in the private sector without subsidy will have reduced significantly.

2.3 Whilst paragraph 2.2 above has set out the existing situation insofar as policy and

guidance on the provision of affordable housing is concerned, this matter is also

addressed in the consultation version of Planning Policy Statement 3 (PPS3) -

Housing.

2.4 The final version of PPS3, together with accompanying guidance (currently being

drafted), will replace PPG3 (as referred to previously) and Circular 6/98: Planning

and Affordable Housing (also referred to previously). Consequently, the content of

this draft PPS3 (insofar as affordable housing is concerned) is material to any

consideration of the issues currently concerning the provision of affordable housing.

2.5 Draft PPS3 defines affordable housing as follows:

“… Non-market housing, provided to those whose needs are not met by the market

for example homeless persons and key workers. It can include social-rented housing and intermediate housing. Affordable housing should:

- meet the needs of eligible households, including availability at low enough

cost for them to afford, determined with regard to local incomes and local house prices; and

- include provision for the home to remain at an affordable price for future

eligible households, or if a home ceases to be affordable, any subsidy should generally be recycled for additional affordable provision….”

and defines social-rented and intermediate housing accordingly: “…..Social-rented housing Rented housing owned by local authorities and registered social landlords for which

guideline target rents are determined through the national rent regime, set out in the ‘Guide to Social Rent Reforms’ published in March 2001.

Also rented housing owned by other persons and provided under equivalent rental

arrangements to the above, as agreed with the local authority or funded with grant from the Housing Corporation, as provided for in the Housing Act 2004.

Intermediate housing Housing at prices or rents above those of social-rent but below market prices or

rents. This can include shared equity products (for example HomeBuy) and intermediate rent (ie rents above social-rented level but below market rents). Intermediate housing differs from low cost market housing (which Government does not consider to be affordable housing - see definition of affordable housing above)….”



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Having identified the above forms of affordable housing, the draft PPS proffers the

following guidance concerning its provision:

• Sub-regional housing market assessments should help determine whether

affordable housing is needed and guide the level, size, type and location of

affordable housing provision (either through new provision or as replacement

provision).

• In determining the overall target for affordable housing provision, local

planning authorities should have regard to:

- sub-regional housing market assessments

- Regional Spatial Strategy (RSS)

- Regional Housing Strategy

- Regional Homelessness Strategy (if in existence)

- Local Housing Strategy

- Community Strategy

• Affordable housing targets should take account of the anticipated levels of

finance available for affordable housing, including public subsidy (based on

priorities set out in the Regional Housing Strategy and discussions with the

Housing Corporation) and the level of developer contribution that can

realistically be sought on relevant sites.

• Separate Targets should be set for social-rented and intermediate (where

appropriate) housing.

• Local planning authorities should aim to ensure that the provision of

affordable housing meets the needs of both current and future occupiers.

• Local planning authorities should set a minimum site-size threshold - which

can be expressed either as numbers of homes or in terms of site area - above

which the provision of affordable housing will be sought, with the indicative

national minimum being identified as 15 dwellings.



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• A lower threshold or series of thresholds may be set where such can be

justified.

• Minimum site - size threshold will be determined by:

- the level of affordable housing to be sought

- site viability

- the impact on the delivery of housing provision

- the objective of creating mixed and sustainable communities.

• Local planning authorities should balance the need for affordable housing

against the viability of sites by:

- having regard to the implications of competing land uses

- making informed assumptions about the levels of finance available for

affordable housing.

• Local planning authorities should aim to manage the risks in terms of delivery

to ensure that they achieve their identified affordable housing targets (in this

respect, the Draft makes reference to a “companion guide” to PPS3 - which is

currently being prepared - that will set out an approach that authorities may

use if the assumed level of finance available for affordable housing is not

forthcoming and provides examples of innovative ways of delivering such

where that is the case or in order to supplement the delivery of affordable

housing).

• There is a presumption that affordable housing should be provided on-site, so

that it contributes towards achieving the objective of creating mixed

communities and avoids creating concentrations of deprivation.

• Local planning authorities may, however, within their local development

documents (LDD’s) set out those circumstances in which provision would not

be required within an application site or in which a financial contribution would

be acceptable in-lieu of on-site provision - either form of alternative

provisions, however, must be of broadly equivalent value and should, again,

contribute towards the plan objectives for mixed communities.



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• The companion guide (as referred to previously) will provide advice on:

- setting affordable housing targets

- setting thresholds

- the use of planning conditions and planning obligations

- ensuring that affordable housing provided meets the needs of both

current and future occupiers.

2.6 Insofar as the consideration of the provision of affordable housing at the local level is

concerned, the following aspects of Draft PPS3 are particularly relevant:

• Lower thresholds to trigger the provision of affordable housing are being

considered for introduction nationally, with the possibility also that local

authorities could impose their own threshold or range of thresholds (based on

justification).

• Draft PPS3 advocates the identification of separate targets for social rented and

intermediate affordable housing.

• Local authorities would be encouraged (under the provision of Draft PPS3) to

undertake a more pro-active role in securing affordable housing.

• There would clearly be a presumption in favour of on-site provision of affordable

housing to accord with the objective to secure mixed communities.

• Affordable housing should remain as such in perpetuity.

2.7 The above then provides the background context (both existing and consultative) for

the consideration as to whether the submission Core Strategy DPD provides

sufficient coverage of affordable housing requirements, or whether that coverage

needs to be fuller.

2.8 This paper has also set out (under the heading of “Relevant Sections of the

Submission Core Strategy Development Plan Document”) the relevant abstracts

(from the submission Core Strategy) regarding the provision of affordable housing.

These provide the context for the more detailed policies concerning the provision of



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affordable housing which are contained within the Residential Development Control

Development Plan Document.

Residential Development Control DPD

2.9 This DPD - which is currently at the “Preferred Options” stage and out for

consultation until 15 May 2006 - includes the following two policies in respect of the

provision of affordable housing:

“…………

Policy 7: Affordable Housing Government guidance encourages local authorities to set targets for provision of affordable housing and to seek a reasonable mix of housing types, particularly on substantial developments. This is intended to encourage the development of mixed and balanced communities. Government guidance states that ‘affordable housing’ or ‘affordable homes’ includes both low cost market and subsidised housing that will be available to people who cannot afford to rent or buy houses generally available on the open market.



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PREFERRED POLICY OPTION The following approach will be taken in order to maximise the supply of affordable housing to meet identified needs; 1. Require all proposals involving residential development of 15 or more dwellings in

settlements of 3,000 population or more and 6 or more dwellings in other areas to provide a percentage of affordable housing, taking account of requirements and evidence in the Housing Needs Survey and in accordance with Planning Policy Guidance 3: Housing or its successor documents. Such provision must be made on site in the form of serviced land and/or dwellings. Only in the most exceptional circumstances will contributions in cash or kind in lieu of on-site provision be accepted.

2. Seek to negotiate the exact level and means of provision of affordable housing in all

such cases with reference to: (a) The nature of identified need; (b) The likely timing of the release and development of the site; and (c) Special considerations affecting the development of the site.

3. Not to grant planning permission until the developer has entered into satisfactory

arrangements to ensure that the affordable housing is: (a) Built within an agreed time scale; (b) Provided on terms which ensure its cost will be genuinely capable of meeting

identified need; (c) There are secure arrangements to ensure that the benefits of affordable housing

will be enjoyed by local people on low incomes in perpetuity; and (d) Managed and maintained on a long-term basis as affordable housing, normally

through the involvement of a Registered Social Landlord.

Policy 8: Affordable Housing on Rural Exception Sites

Small sites which would not normally be acceptable for housing development, may exceptionally be developed for affordable schemes to meet a proven local need for such housing in accordance with Government Guidance in Annex B of PPG3.

PREFERRED POLICY OPTION Exceptionally, affordable housing may be allowed within or on the edge of small ruralcommunities on land that would not normally be released for development, providedthat: a) the proposal is small scale and of a character suitable for the location; b) there are secure arrangements to ensure that the benefits of affordable housing will

be enjoyed by local people on low incomes in perpetuity; c) any application must be accompanied by a local needs survey which shows

conclusively that there is a genuine proven local need for the type, mix and scale ofthe proposed dwellings; and

d) the site should conform with all relevant development plan policies. Such affordable housing does not include general market housing or market housing for local needs only.

……..” 2.10 The Council does not consider that there is any necessity for the Core Strategy DPD

to provide a “fuller coverage” of affordable housing requirements. The purpose of the

Core Strategy is to provide the overall context for the preparation of more detailed

Development Plan Documents and by the inclusion of references to affordable

housing within these policies of the submission version it is considered that the Core

Strategy thereby fulfils this contextual role.

2.11 The Council coincides that its requirements in respect of the provision of affordable

housing are fully set out in the two dedicated policies concerning affordable housing

(viz Policies 7 and 8 as reproduced above) as contained in the Residential

Development Control DPD, and - given that these are policies specifically relating to

affordable housing - that these are the most appropriate policies in which to set out

the Council’s full requirements for affordable housing.

2.12 Furthermore, the Council considers that those two policies together fully set out its

requirements in respect of affordable housing, and that these requirements appear to

be consistent with the emerging guidance as contained in Draft PPS3 in that the

policies provide for - inter alia - a lower threshold (15 dwellings) in settlements of



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3,000 + population as a trigger for the provision of affordable, an even lower

threshold (6 or more dwellings) in other areas, the provision of affordable housing on-

site (unless exceptional circumstances dictate otherwise) and the need for the

affordable housing provided to remain as such in perpetuity.

The rate of provision of affordable housing • Should this DPD include a target for provision? 2.13 This Hearing Statement has set out the relevant policies from the Submission Core

Strategy DPD which relate to the provision of affordable housing together with the

respective targets (concerning the delivery of affordable housing) for each of those

policies. By way of summary, those targets seek -

o 10 affordable houses to be completed per year outside of Stafford and Stone

o within Stafford and Stone, 25% of new housing to be classified as affordable

housing

o within the Borough as a whole, 35 affordable homes to be completed per year

2.14 In the light of the above three figures, the Council would confirm that it does consider

that this Core Strategy should include a target(s) for the provision of affordable

housing.

2.15 Insofar as one of the targets referred to above is concerned, - ie that relating to the

provision of 35 such units per year - Tetlow King Planning for the West Midlands RSL

Planning Consortium submitted an objection to Core Policy 10 which expresses

concerns regarding that target figure (Representation No U4C, U9/CP10/0039/5204

refers). In its response to that representation, the Council has indicated that whilst it

considers the targets associated with Core Policy 10 to be realistic, it would not

oppose the target being expressed as a percentage rather than as a fixed figure.



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• If so, what should it be? 2.16 The Council re-states its considered view that the targets for the delivery of

affordable housing that relate to Core Policies 2(b), 3(d) and 10(i) respectively are

both realistic and appropriate. However the Council would not oppose the figure

being expressed in an alternative manner if required.

Locational considerations • Should this DPD set out an area based approach to provision? 2.17 The Council considers that by having dedicated references to affordable housing for

both rural (Core Policy 2) and urban (Core Policy 3) areas, the Submission Core

Strategy thereby effectively adopts an area based approach towards the provision of

affordable housing. The Council considers that it is appropriate to consider the

provision of affordable housing under the broad locational headings of rural and

urban since the Housing Needs Survey (2002) and the Housing Needs Survey

Update (2004) demonstrate significant need for affordable housing in all areas of the

Borough - thereby justifying the fact that the DPD does not adopt a very detailed

(area) based approach to provision.

• If so, what should it be? 2.18 The Council re-states its considered view that it is appropriate for the Core Strategy

to incorporate policy guidance for affordable housing at rural and urban level only,

and that those policies should not be more locationally specific given that there is a

demonstrable need for the provision of affordable housing across the Borough as a whole.

Any other matters 2.19 The provision of affordable housing is addressed within the Core Strategy in Spatial

Objectives 5 and 6 as well as Core Policies 2, 3 and 10.

2.20 A number of representations were received to these Spatial Objectives and Core

Policies through the consultation period of the Submission Core Strategy

Development Plan Document. In March 2006 Stafford Borough Council provided a

response to each of these representations. The following lists of representations set

out the responses which particularly relate to the issue of affordable housing:



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• McDyre & Co for J F Bostock Settlement –

U4B,U4C,U4D,U6,U9/CP2/0019/5064

• Paul Sharpe Associates for Fradley Estates – U4B,U6,U7,U9/CP2/0022/5087

• Creswell Parish Council – U7/CP2/0038/5171

• Tetlow King Planning for West Midlands RSL Planning Consortium –

U4C,U9/CP2/0039/5198

• Tetlow King Planning for West Midlands RSL Planning Consortium –

U4C,U9/CP3/0039/5199

2.21 The Council considers the policies referring to affordable housing as incorporated

within the Core Strategy to be appropriate in both content and application.



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