Affordable Housing SPD – The CovSoc response

In November the City Council launched a consultation on three news Supplementary Planning Documents (known colloqually as SPDs). Although the consultation period has now ended, you can still see the draft documents on the Planning Consultation pages of the Council website.

This is the Society’s response to the draft Affordable Housing SPD.

The Coventry Society welcomes the document’s:

  • emphasis on ensuring that there is a mix, and choice, of tenures across the city rather than particular types of tenancy being concentrated in certain areas, and that the different types of tenancy should be integrated into new developments.
  • links with the aspirations and objectives of the Council’s Housing and Homeless Strategy 2014 and the Strategic Housing Market Assessment 2015 (but note comment on the latter below).
  • concern with meeting residents’ need and with build quality, including energy efficiency, environmental friendliness and internal living space requirements.
  • recognition of advanced methods of construction.
  • acknowledgement of non-traditional forms of provision such as co-living, self-build and community-led housing (but note comment below).

We do, however, have a number of reservations and criticisms of the document and its shortcomings, particularly in the light of the alarming statistic that in four years only half the target number of affordable homes in the plan have ‘benefited from planning permission, were being constructed or had been delivered’. This is a shocking situation, which we are not at all convinced will be remedied by the measures outlined in the document, given its generally complacent, unimaginative, ‘business as usual’, ‘more of the same’ approach.

We are concerned that the viability argument – often highly questionable or entirely spurious – will continue to lead to the City Council being outmanoeuvred in its negotiations with developers. The example of City Centre South, with, thus far, its total absence of affordable housing, vividly illustrates the point. We would like to see this ‘get-out’ tightened up considerably and subject to much greater transparency.

We are aware that there has been considerable recent public debate about the validity of the SHMA. The Society shares some of the doubts that have been raised about it, including the significance of social, economic and demographic changes such as:

  • the failure of the exceptionally large population growth, which was assumed when the plan was drawn up, to materialise;
  • a growth in the student population and the concomitant expansion of bespoke student accommodation with its associated effects on land cost and availability, pressure on local services and amenities, etc;
  • a growth in Coventry’s migrant populations, with their specific needs;
  • a growing realisation of the ramifications of an ageing population, whose needs should be reflected in the delivery of new housing, a point emphasised in the recent white paper People at the Heart of Care: adult social care reform, itself arguably underplaying the consequences of an ageing population on housing delivery (see for example https://housingevidence.ac.uk/housing-and-the-social-care-white-paper-a-credibility-gap/.
  • The effects of the Covid-19 pandemic, including the growth of ‘working at home’.

We are surprised that, despite recognising that non-traditional forms of provision such as co-living, self-build and community-led housing have a part to play, co-living has been so thoroughly dismissed in the document, for reasons that we find flimsy and unconvincing.

Given the continued sluggish delivery of affordable housing we are also surprised that the City Council proposes to continue with the same restricted list of rather samey Registered Providers.

Our overall verdict on the guidance is that it presents laudable aims and objectives but leaves us with serious doubts that its implementation will give the desired results. If that proves to be the case it will have failed the people of Coventry.

In view of these reservations, we suggest that

  • The emerging and changing needs (and numbers) of Coventry’s population are monitored closely and reflected in flexible and regularly reviewed planning guidance.
  • The provision of affordable housing is opened up to a much wider set of providers, to encourage innovation, competition and an increase in the number of delivery channels. New providers should be encouraged, not just because of the additional homes they will provide but because their schemes will be exemplars and challengers to the existing players. This should include community organisations and charities, in partnership with registered providers where appropriate. Starley Housing Co-operative, which partners with Greensquare Accord, is a good example of what can be achieved. So is Earlsdon Park Village, which is also an exemplar of how housing and social care can be brought together.
  • These new challenger providers should include the City Council itself. Throughout the UK, local authorities in a similar position to Coventry’s – a shortfall in the delivery of housing, in particular affordable housing, by traditional developers – have found ways to enter the field themselves. See for example
    https://www.theguardian.com/cities/2019/oct/28/meet-the-councils-quietly-building-a-housing-revolution
    and
    https://www.rtpi.org.uk/research/2017/june/local-authority-direct-provision-of-housing-i/
  • The viability regime for developers is toughened up. It is clear that developers are too quick to reach for this escape route in the cause of profit maximisation and scheme simplification. It is too easy for developers to negotiate their way out of their social obligations with the help of high-powered consultants. The replacement options – section 106 agreements, the provision of affordable housing on another site, the payment of a commuted sum – are often inadequate.
  • Non-traditional forms of provision are actively encouraged, including by the creation of a support and advice function within the City Council.

Coventry Society 18/1/22

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