Draft Strategic Planning Policy Statement. Consultation Response

Transcription

1 Draft Strategic Planning Policy Statement Consultation Response April 2014

2 Outline of Response 1 This paper contains the response of the Northern Ireland Federation of Housing Associations (NIFHA) to the draft Strategic Planning Policy Statement for Northern Ireland (SPPS). The focus of the paper is on housing issues. At the end of the paper we summarise key recommendations. 2 Annex 1 sets out a suggested revision of the main section of the SPPS on housing. Annex 2 contains comments on the strategic environmental assessment, the equalities assessment and the regulatory impact assessment. 3 NIFHA represents 26 registered housing associations in Northern Ireland. Collectively our members provide 44,000 homes comprising general needs, specialist and supported accommodation, as well as shared ownership. 4 Housing associations are charitable social businesses. Our movement is investing increasing private finance to deliver public benefit in meeting housing need, supporting tenants and transforming communities. 5 Further information on NIFHA and housing associations is available at NIFHA's Main Concerns 6 NIFHA has three main concerns about the SPPS: (a) One of the primary roles of the SPPS is to set objectives for future development plans. As local authorities explore their new plan making powers it is important for the SPPS to provide guidance about what local plans are expected to achieve. The SPPS should make it absolutely clear that development plans must plan to accommodate housing need in full, for both market and affordable homes, for all 2

3 types, sizes and mixes of housing unless that would lead to unsustainable development. At present, this fundamental requirement is not clear. Our first recommendation is that the SPPS should be clear that meeting housing need in full, for both market and affordable homes, is a clear, key and central policy requirement at the heart of plan making and development management decisions; (b) The SPPS does not give enough weight to the importance of the development of new market and affordable homes, including the role of new homes in supporting economic development, creating and securing community cohesion and providing a sense of place. Housing is central to the quality of life for people in Northern Ireland. The planning system has a critical part to play in making sure that all forms of new housing are of the right standard, in the right place and delivered at the right time. Plan making and development management should explicitly recognise the importance of the links between housing and employment. Our second recommendation supports the first, and is that the role of new housing in sustainable development and in supporting the economy is fully and properly recognised; (c) The SPPS gives no adequate guidance on affordable housing (including social rented housing). The SPPS should set out clearly the policy tools that it expects local planning authorities to use in plan making to secure affordable housing, and should confirm that a failure to meet identified housing need on appropriate sites is a reason for refusal. NIFHA understand that a policy paper will soon be published on "developer contributions" towards affordable housing. Regardless of the approach proposed in any future policy paper the SPPS must still address the broader planning issues associated with meeting the need for affordable housing. NIFHA notes that the future integration of any developer contribution policy into the SPPS will need to 3

4 be dealt with very carefully to avoid undermining the consultation process on the SPPS as a whole. Our third recommendation is that the policy approach to affordable housing must be far more explicit. Affordable housing is integral to mixed and balanced communities. Plan making should provide for affordable housing where needed. Development management should secure it and should refuse permission to schemes that do not, without good reason, make proper provision. Housing 7 Planning for housing is the core function of plans. The identification of housing need, by type, tenure, size and location is the primary role of the plan making authority. A failure to plan housing properly leads to inadequate housing conditions, house price inflation, poorer communities and places and stifled local economies. Quality housing is at the core of sustainable development. At the moment the SPPS does not recognise the importance of housing, and does not make clear the responsibility on local planning authorities of planning properly for housing. 8 Planning for housing must be built on an understanding of housing markets, and the need for market and affordable homes, as well as the need for supported and specialist accommodation. The SPPS identifies the potential evidence sources but does not indicate the importance of clear and robust local evidence to being able to plan properly for communities. At the moment there is too much reliance on the outdated Regional Development Strategy housing figures, the foundation data for which is almost a decade old, and there is no indication of how that will be (as it should be) updated. Similarly there is a passing reference to traditional Housing Needs Assessments. The Housing Executive analyses of need have underpinned planning requirements in the past in a clear and consistent manner. What is required in the future is either a similar assessment from the 4

5 Housing Executive or clear, local, robust evidence (prepared on a consistent basis for each planning authority) on the need for all housing, of all types, across all tenures and of all sizes. The SPPS should make it clear that plans without adequate evidence will be found unsound. 9 Where housing need is identified the SPPS should be unequivocal in saying that the need should be met in full, as soon as practicable. The SPPS should give advice in relation to affordable housing to emphasise the range of tools that are available. Sites should be zoned for affordable housing or to support a percentage of affordable housing. Policies should be promoted that require affordable housing on all suitable sites. In exceptional cases where affordable housing need cannot be met on site, the SPPS should be clear that off site provision and/or commuted sums may be acceptable where it is clear that that will lead to better provision of affordable housing in the area. 10 The SPPS should make it clear that the plan making and development management processes have a clear role in ensuring the quality of all housing, and of affordable housing in particular. It should be clear, in the SPPS, that housing should be designed so that variances between different tenures are minimal. Proper planning policies and design standards will, effectively, set the standards and types of affordable housing that will be required. 11 Unhappily, at the moment, the SPPS does not make these points sufficiently clear. NIFHA strongly recommends that the importance of meeting housing demand, of all types, is identified as part of the Core Principles, and that the subject planning policy section is expanded to give full and proper guidance to local planning authorities, to land-owners and developers and to the communities who will rely on new housing. 12 NIFHA has amended the proposed paragraphs in the SPPS on "Housing in Settlements". This is attached as Annex 1. As you will note we have provided definitions for affordable housing 5

6 and social housing. It is important that everyone is clear about the different roles of each form of affordable housing. Structure of the SPPS and PPSs 13 The SPPS is clear, well structured and thoughtful. It provides a good framework within which decisions on local development plans and on development management will take place. It captures the main policy issues in a succinct manner. If amended as proposed it will provide a clear basis for future planning decisions. 14 NIFHA notes the intention to retain the majority of PPSs until local plan strategies and local policies plans are adopted. NIFHA believes that this is counter-productive, and risks confusing the clarity of policy otherwise offered by the SPPS. It raises a real risk that existing PPSs will "linger on" for a long time, and that we end up with a patchwork of policy - in some areas planning policy will be set by the SPPS and the adopted development plan, and the PPSs will be irrelevant; in others the PPSs will remain in force. That confusion is a recipe for future litigation. The SPPS already summarises the PPSs and, provided that the SPPS is revised to emphasise the importance of meeting housing need in full, it would be far better for the PPSs to be removed immediately. 15 The immediate repeal of the PPSs would also send out the right message about the need for local authorities and planners to take responsibility about planning, making their own decisions informed by the principles in the SPPS, rather than reverting to the comfort of policy designed for a different centralised planning system. 6

7 The Purpose of Planning 16 This section of our response comments on sections 1, 2 and 3 of the SPPS. These sections should be the heartbeat of planning in Northern Ireland for the future. They should offer an exciting vision. They should set out a clarion call about what is expected of the planning system. Unfortunately, both sections 1 and 2 open with a lack of ambition - "to secure the orderly and consistent development of land". It would be far stronger to emphasise the importance of sustainable development, and the contribution that that can make to improving social, environmental and economic wellbeing. In fairness, sustainable development is mentioned in paragraph 1.1, but should be the focus rather than being diluted by the introductory remarks. 17 Section 1 continues and sets out an important benchmark for all planning decisions, both within development plans and development management. Development should not be resisted unless it would cause "demonstrable harm to interests of acknowledged importance". NIFHA strongly supports this approach. The language throughout the SPPS could, more fully, embrace this concept. At the moment the approach reads defensively. If the principle is applied properly, it would emphasise that the planning system should, at all times, be proactive, positive and transparent. 18 NIFHA applauds the approach and structures set out in section 3. It is helpful to set out the core planning principles that the planning system is meant to deliver. However, NIFHA has real reservations about a number of the core planning principles. The eight principles that are mentioned are a mix of social objectives and process issues. The focus should properly be on the outcomes that planning can help to deliver in the built environment so that those are embedded in plan making and development management decisions. Planning should further sustainable development, improve health and wellbeing, create and enhance shared space and support good design and positive place-making (all referred to in 7

8 paragraph 3.2). As discussed later it should, as part of those principles, strongly promote high quality housing development to meet the demands of society. 19 However, the core planning principles are confused by the references to delivering spatial planning, observing a plan lead system, enhancing stakeholder engagement and local democracy (again referred to in paragraph 3.2). These are all laudable parts of the process that will be adopted in implementing the planning system. They are not, however, core objectives of the planning system. It would be better to remove the process points from the section, perhaps including them within section 2 which could then deal with the architecture of the planning system. 20 NIFHA believes that the paragraphs elaborating on "furthering sustainable development" need significant expansion. Regulation 42/187 of the United Nation Assembly places real weight on "meeting the needs of the present". This is then balanced against the need to ensure that we do not compromise the ability of future generations to meet their own needs. It does, however, require a genuine understanding of society's present needs and an acceptance that those needs should be met unless they would cause harm. 21 In the context of housing, a far stronger emphasis should therefore be placed on planning to meet the need for all types, mixes, sizes and tenures of both market and affordable housing, as well as the needs of those requiring more specialist forms of accommodation. Paragraph 3.4 goes part of the way towards this, but is couched in limited terms. It refers only to "facilitating delivery of social and affordable homes". It should, instead, note that one of the key drivers of sustainable development is to meet the demand for all housing needs, and other economic and social needs, qualifying that only when there would be long term adverse effects. 8

9 22 One of the core objectives of the planning system should be to ensure that the economy of Northern Ireland is strong and sustainable. This is briefly referred to in the reference to a "sustainable economy", but is not given anywhere need enough of a priority. Similarly, the role of housing in supporting a vibrant economy is not addressed. This could either be covered as part of an expanded section on "furthering sustainable development" or as a separate core planning principle. Whatever approach is adopted there needs to be clear recognition of the relationship between new and affordable homes and a successful economy. 23 As more detailed points on the core planning principles: (a) At the moment there is an imbalance between the relative brevity of the section on sustainable development and the lengthier sections on managing noise and air quality. The former should be expanded and the latter edited; (b) Paragraphs 3.36 and 3.37 sets out some important issues in relation to place making. There is a danger that, because of the format, it will be read as a check list. The principles in paragraph 3.37 are said to relate to the "countryside" but, in fact, are of wider importance. It might be worth amalgamating the paragraphs. Local Development Plans 24 NIFHA has three structural concerns about the approach set out in section 4 of the SPPS on local development plans. These are: (a) We understand the desire for early adoption of a local development plan document. As a consequence the SPPS proposes that the plan is prepared on a staged basis - a planned strategy and then a local policies plan. NIFHA is concerned that it will lead to a very significant delay before full up-to-date local development plans are in place. It 9

10 would be far better to encourage local authorities to prepare a full plan, and only to leave issues for a follow up document if that is demonstrably necessary. (b) The local development plan system will stand or fall on whether plans are sound. The SPPS should set out, clearly and comprehensively, the tests that the PAC should take into account when assessing soundness. These tests will then drive the behaviour of local authorities in plan making. NIFHA believe that the key questions are: (i) Is the plan based on sound and up-to-date evidence? (ii) Does it meet all identified needs, except where there are clear reasons why it cannot do so - has it been prepared positively? (iii) Are the proposals in the plan deliverable? (c) It would help to expand on the advice of objectors to a local development plan. At the moment paragraph 4.21 deals with this very briefly, and simply suggests that objectors need to "demonstrate how their proposed solutions so as to make the plan more robust". The plan making process is meant to encourage engagement. If objectors will only succeed if they can demonstrate that the plan will be "more robust", then that sets a high standard, and effectively a presumption in favour of the proposals promoted by the local planning authority. NIFHA believe that the test should be more open - would the proposal, if accepted, better deliver the sustainable development of the area? 10

11 Development Management 25 NIFHA has limited comments on section 5. It sets out, clearly and concisely, the approach that should be adopted to planning applications. It could be improved by: (a) At the outset, making it clear (as mentioned earlier) that development should be permitted unless harm would be caused to interests of acknowledged importance. At the moment this is rather hidden under the heading "Reasons for Refusal" it is too important a principle to be lost in that way. In relation to affordable housing it should be clear in the SPPS that, where there is a need, affordable housing should be an integral part of all schemes and that a failure to provide affordable housing without good reason would normally justify refusal; (b) It is odd to open the description of "appeals" with a reference to judicial review. There should be an assumption of competence and proper interpretation of policy and recourse to the courts should not be needed. Judicial review is not something that properly merits a place in a policy document; (c) The section on developer contributions will need to be expanded once policy has been issued on affordable housing. It will have to make it clear that the delivery of affordable housing is an important component of both housing and mixed use development and that the absence of planned affordable housing would be harm to an interest of acknowledged importance. There will need to be a very clear emphasis on: (i) Ensuring that affordable housing is, normally, provided on site and in full; (ii) If there is any waiver of an affordable housing requirement, making sure that that only occurs in exceptional circumstances and is properly evidenced; 11

12 (iii) If, exceptionally, affordable housing is provided off site, or commuted, ensuring that there is a clear and public justification for that approach. Subject Planning Policies 26 We do not wish to comment at length on the other subject planning policies which, admirably, cover the main issues. NIFHA assumes that, as part of the response to consultation, each of the subject planning policy sections would be reviewed and edited. When that exercise is undertaken it would be helpful for the length and content of each section to be compared. There are significant variations in the length of the sections, not entirely justified by the importance of the topic. There are stylistic differences between the different subject planning policies and there will be a need to ensure consistency. 27 Simply as reminders for the future editing process: (a) NIFHA welcomes the reference in paragraph 6.62 to the need to meet social and affordable housing requirements. This will have to be updated when the affordable housing policy emerges; (b) Paragraph 6.72 should be expanded to make it clear that, in many cases, successful economic development, and vibrant city centres, is dependent on sensibly planned housing, including affordable housing. Recognition should also be given to the importance of housing development as part of the economy; (c) The language in paragraph 6.84 may need to be qualified. Land should be reserved for economic development where there is a genuine need for that land to be used. Too often, in the past at least, historic designations have thwarted otherwise sensible development proposals; 12

13 (d) The transport policies should be given more focus. Significant amounts of money, and time, are spent assessing the transport implications of proposals. At the local development plan stage, allocations should be allowed to proceed unless there is evidence that the transport impacts would be unacceptable. In development management decisions, permission should only be refused if the transport effects are, for example, "severe". It is important to have clear thresholds. Implementation and transitional arrangements 28 NIFHA is deeply concerned that the PPSs will be retained until the local policies plans are adopted. They will linger on for many years. Since the SPPS already summarises the PPSs it would be far better for the PPSs to be withdrawn. Retention would lead to anomalies as plans are adopted, leading to a position where some local authority areas are governed by the SPPS and development plans while adjacent authorities, because there are delays in adoption, would still be looking at the full suite of PPSs. That would cause public confusion. 29 If retained there will, almost inevitably, be a debate about the respective weight to attach to the SPPS and to the PPSs. It will doubtless be suggested by some that the more detailed provisions in the PPS should be given greater weight if they are allowed to continue in existence. That risks becoming a lawyers charter. 30 Perhaps more importantly, the continuation of the PPSs will encourage over reliance on policy, some of which is now historic. The SPPS marks a change in approach. It sets out principles, and then leaves decision making to planners. That is empowering. It is liberating. Maintaining the PPSs, by contrast, would be stifling. 13

14 Additional Recommendations Recommendation One The first five paragraphs of the foreword and section 1 should be combined to set out a clear and exciting vision about what the planning system should deliver for Northern Ireland. The focus should be on: Planning for and enabling high quality sustainable development Operating on the basis that development should be encouraged unless there would be harm to interests of acknowledged importance Recommendation Two Section 2 should be changed so that it sets the stage. It should describe the status of the SPPS and the structure of the future planning system. Paragraph 1.4 would sit more comfortably in this section rather than in the section on the purpose of planning. Recommendation Three Section 3 should set out core planning principles. These should be focussed on the outcomes that planning is meant to achieve, rather than the process by which they are delivered. NIFHA's view is that the objectives should be Furthering sustainable development, with the principle being elaborated upon to make it clear that that means meeting society's need for housing and other development where that can be achieved in a sustainable way Improving health and well being Creating and enhancing shared space 14

15 Supporting good design, place making and stewardship Recommendation Four The objectives in paragraph 3.2 on delivering spatial planning, observing a plan led system, encouraging engagement enhancing local democracy are all important but relate more to the way in which the planning system is operated rather than being the outcomes of the planning. It would be better to treat these as good practice points rather than core planning principles. 15

16 Annex 1 Proposed amended version of Housing in Settlements section of draft SPPS Housing The planning system, in co-ordination with the broader public sector, private sector and key housing agencies, has a pivotal role in the delivery of good quality housing in appropriate locations. Housing makes a vital contribution to each of the key policy objectives of promoting sustainable development, economic well-being and social progress 2. New housing development can also stimulate urban and rural renewal The policy objectives for housing are to; deliver housing growth in response to changing housing needs; ensure that the needs for all types, tenures, mixes and size of units of housing are met in full, including the need for affordable housing 3 plan housing growth to achieve more sustainable patterns of residential development; promote more housing within existing urban areas; encourage an increase in the density of urban housing appropriate to the scale and design of the cities and towns of Northern Ireland; encourage the development of balanced local communities maintain a supply of deliverable sites throughout the plan period set clear targets for the delivery of housing so that monitoring can easily take place and any shortfalls in provision can be addressed. Local Development Plans The LDP process is the main vehicle for assessing future housing needs and land requirements and managing housing growth to achieve sustainable patterns of residential development, as well as fulfilling other objectives. In this regard, the SPPS sets out guidance for plan preparation under 4 inter-related elements, as follows: 1 The limitation in this section on housing being "in settlements" be reviewed. The importance of housing means that the policy should be set out in one place rather than being addressed, with different emphasis, in settlements and in the countryside. 2 The relationship with the RDS should be clarified. Does the SPPS set planning policy or does the RDS? At the moment the RDS sets out housing numbers. Is this up to date? What is the process for updating? How should the numbers be reflected in Area Plans? 3 There needs to be a policy objective in relation to affordable housing 16

17 identifying the need for housing of all types, tenures, mixes and sizes allocating housing land, maintaining a supply of deliverable sites through the plan period and measures to be contained in LDPs; implementing, monitoring and reviewing LDPs. The Process for identifying the need for housing There needs to be clear and up to date evidence on which decisions about housing should be based. Plans that are not supported by clear evidence are unlikely to be sound. Housing allocations in LDPs should be informed by: Application of RDS Housing Growth Indicators (HGIs) as a starting point for allocating housing distribution across the plan area. Local evidence should be prepared that reviews and updates these figures to make sure that there is a robust evidence base identifying the full levels of demand for all forms of housing in the area; Use of 4 the RDS housing evaluation framework(38) which takes account of the varying capacities of settlements; Allowance for existing housing commitments Councils should take account of dwellings already constructed, approvals not yet commenced and residential development proposals likely to be approved. Urban capacity studies Councils should assess the potential for future housing growth within the urban footprint(39) and the capacity for different types and densities of housing. The urban capacity study should take account of housing development opportunities arising from previously developed land(40), infill sites, conversion of existing buildings, and possible changes of land use. Consideration needs to be given to the type of housing and density appropriate to each site in order to assess the number of housing units likely to be generated. Urban capacity studies should also include an allowance for windfall (41) housing arising from previously developed land within the urban footprint over the course of the plan period where there is clear evidence that the rate of housing delivery on windfall sites will continue. The deliverability of all major proposed sites should be tested. The urban capacity study should be published as a technical supplement to the draft plan. Housing Needs Assessment - to provide an evidence base for the allocation of land to cater for special housing needs such as affordable housing, social housing, supported housing and travellers accommodation. The HNA will be part of the evidence base on which LDPs will identify the need for a mix and balance of housing tenures and types. 4 "use of" suggests some flexibility -- are the RDS figures to be delivered or not? 17

18 5 LDP. Transport Assessments where appropriate transport assessments should be carried out when considering certain sites for residential use to achieve increased integration with public transport and other alternatives to the private car Allocating Sites and Measures to be contained in Development Plans LDPs should 6 ; set out the overall housing needs that they intend meeting over the plan period for all forms of housing need. A failure to do so, without clear and robust justification, is likely to lead to a plan being unsound 7 set out the overall housing provision for each settlement over the plan period; set development limits for all identified settlements; zone sites for housing in larger settlements to meet the full range of identified need, including the need for affordable and specialist housing indicate in small settlements areas where it is anticipated that most new housing will be located through the use of Housing Policy Areas (HPAs); provide for a managed release of housing land, in line with the RDS plan, monitor and manage approach; identify sites or areas within settlements where the site (or part thereof) is required to meet one or more category of need and clearly state the proportion required; identify settlements where the HNA has found there to be an affordability pressure, zone land or include policy, as appropriate, to reflect the local need resulting from the demand for second homes; where justified, specify those sites or areas where the development of certain house types or a mix of house types will be required set density levels for housing sites appropriate to the location of the site and the character of the surrounding area; identify areas within town centres where existing residential development will be protected; set requirements for the housing elements of sites identified for a mix of land-uses; include, where appropriate, specific policies to protect the distinctive nature and character of settlements; identify opportunity sites and specify the level of housing that is either required or is acceptable and any design requirements that should be applied; 5 Two references to windfalls will encourage too much reliance on them. 6 This is a key paragraph and the way in which it has been reduced to bullet points diminishes it. It is noted that in relation to decision taking each of the key points in paragraph is expanded upon -- which makes for a sharp contrast. 7 There needs to be a measure against which the plan is assessed, and against which delivery can be measured 18

19 set out any additional plan policies or proposals (including key site requirements) to deliver quality residential environments. For example, plans may set out the main infrastructure requirements that developers will be expected to meet for zoned residential sites, local design requirements, and requirements for local neighbourhood facilities; identify sites requiring a development brief to be drawn up; include as supplementary planning guidance Concept Master Plans for major developments site; and contain specific policy for safeguarding the character of established residential areas contain policies that provide a policy framework for other sites to come forward and to be tested as to whether permission would cause harm to interests of acknowledged importance. Affordable Housing and Specialist Housing Affordable housing, and supported and specialist housing, are important components of housing need, and plans should accommodate those need. Plans are unlikely to be sound unless they do so A Everyone deserves the right to a decent, safe and affordable home. Society has a particular obligation in enabling people with specific needs to secure appropriate accommodation. A high proportion of housing association homes are supported and specialist accommodation, including for the frail elderly, people with dementia, people with disabilities and homeless people. However delivering the necessary new supported and specialist homes is increasingly difficult, sometimes as a result of local opposition to many proposed developments. Yet without a significant increase in such provision, it will be impossible to meet the needs of society, especially for our ageing population, and to fulfil the vision of Transforming Your Care. This requires helping fulfil peoples aspirations to live as independently as possible and for longer in the community with high quality care and support. It is vital therefore that local authorities identify and plan to meet the need for all types of supported and specialist accommodation B The delivery of affordable housing, and specialist and supported housing, is an interest of acknowledged importance. Where there is a need affordable housing is an integral part of development and development and where development fails to make appropriate provision, in accordance with the principles in the SPPS or in the local development plan, permission should be refused C DOE and DSD are currently working on a new operational planning policy on developer contributions that will set out one way in which affordable housing provision may be secured. The policy will be consulted on in due course. 19

20 Implementation, Monitoring and Review Councils should undertake regular monitoring. Tracking residential development through monitoring provides for example, valuable information on annual building rates, housing output relative to planned densities, and gives an indication of the validity of estimated windfall predictions. This information will allow a clear view of the overall progress in meeting the housing objectives of the plan and identifying issues likely to require intervention. For example, a need to release second phase sites where a sufficient land supply 8 is not being maintained, or the need to release a site providing for a particular housing need. It will also be necessary to monitor and assess housing development in the rural area in order to ensure that total housing growth can be assessed against the plan s housing allocation. Decision-taking The decision-taking process has a particularly important role to play in supporting Government improve community cohesion facilitate urban and rural renaissance, and deliver sustainable patterns of residential development In decision-taking councils should adhere to the following planning principles; encouraging housing development where it would not cause harm to interests of acknowledged importance increasing housing density without town cramming; securing good design; promoting sustainable forms of development; and facilitating mixed and balanced communities. Encouraging Housing Development 6.125A High quality new housing development brings many benefits, social, economic and environmental. It should be encouraged in appropriate locations even if the site is not identified for development if the proposal would be sustainable. Authorities should not refuse schemes if there is no harm to interests of acknowledged importance. 8 Clear guidance on what is meant by a "sufficient land supply" is important. Is there a reason for control of this nature? 20

21 Increasing Housing Density without Town Cramming Higher density residential development should be promoted in town and city centres and other locations which benefit from good accessibility to public transport facilities. It may also be appropriate for major housing or mixed-use development proposals. Within established residential areas it is imperative to ensure that the proposed density of new housing development, together with its form, scale, massing and layout will respect local character and environmental quality as well as safeguarding the amenity of existing residents. In residential areas of distinctive townscape character an increase in density should only be allowed in exceptional circumstances. Securing Good Design Good design should be the aim of everyone involved in housing development and will be encouraged everywhere through the development management process. All new housing developments should demonstrate a high quality of design, layout and landscaping. Promoting Sustainable Forms of Development Whilst the LDPs process will be the main mechanism for steering residential development to sustainable locations, the development management system also has a role to play in dealing with individual planning applications. In this regard a design concept should be sought from and agreed with the developer incorporating sustainable elements such as good linkage of housing with schools, community facilities and public transport; provision for cycling; adequate provision of open space and landscaping integrated with broader green and blue infrastructure systems; energy efficient design of housing units and use of sustainable drainage systems, where appropriate Within town centres, planning permission should be granted for residential use above shops and other business premises, where appropriate, as this can promote sustainability through utilising underused space, maintaining the fabric of buildings and contributing to the vitality and viability of town centres. Facilitating Balanced Communities Achieving balanced communities and strengthening community cohesion is one of the major themes of planning and other policy. The provision of good quality housing offering a variety of house types, sizes and tenures to meet different needs and development that provides opportunities for the community to share in local employment, shopping, leisure and social facilities is fundamental to the building of more balanced communities. The development management process has an important role in delivery in this context. Affordable housing (including social housing) is part of the way in which communities can be enhanced, and decision making should encourage affordable housing to be an integral part of the overall development. 21

22 Glossary Affordable housing: comprises all forms of affordable housing (including the social rented sector, housing benefit funded private rented and low cost owner occupation market) which can be rented or purchased utilising 30% or less of gross household income. Affordable housing provision should include mechanisms for it to remain at an affordable rent or price for future eligible households or for any subsidy (public or private) to be recycled for alternative affordable housing provision. Social housing: housing for rent normally provided by registered social landlords. Such housing will normally be allocated by reference to an approved waiting list or housing selection scheme. Social housing may also be owned by other persons under equivalent rental arrangements where agreed with the Department for Social Development. 22

23 Annex 2 Commentary on the information supporting the Draft Strategic Planning Policy Statement Strategic Environmental Assessment Scoping Report 1. The scoping report sets the framework for the draft SEA. It gives very limited attention to the need for affordable housing (including social housing). 2. The scoping report properly looks at the broad strategic environmental consequences of the draft SPPS. It does not, however, adequately look at the differences between the environmental consequences of the draft SPPS compared with the existing range of policy advice. 3. As noted in our representations, the draft SPPS does not contain adequate policy on affordable housing (including social housing) and is markedly weaker than the existing PPS policy advice, particularly PPS Unless changes are made to the draft SPPS, there will be a significant effect on the delivery of affordable housing. That will have an environmental consequence that needs to be fully assessed. Strategic Environmental Assessment Environmental Report (SEA) 5. The SEA reflects the shortcomings in the scoping report. It does not address the absence, in the SPPS, of a clear policy requirement to meet housing need, including the need for affordable housing. 6. The SEA does not address, in any way, the effect of the draft SPPS on meeting the need for affordable housing. Indeed, the only references to "affordable" housing are in the sections summarising existing policy; there is no mention of the environmental consequences of affordable housing in the text describing the effects of the draft SPPS itself. 23

24 7. As in the scoping report, there is no assessment of the omission of affordable housing policies from the draft SPPS. The environmental consequences of that omission are not assessed. Equality of Opportunity Screening Analysis 8. The Section 75 Northern Ireland Act 1998 analysis highlights the section in the draft SPPS on "creating and enhancing shared space". It also notes the SPPS references to "good relations" policies. Although it is not, formally, part of the section 75 requirements, it would be helpful if the analysis could note the brevity with which these issues are dealt with in the SPPS, compared with the guidance in existing policy. There is, at least, a risk that that will lead to the issues being treated as being of less weight. 9. More importantly, the section 75 analysis does not address the effect of omission from the draft SPPS of policies on affordable housing (including social housing). That has the potential to reduce, potentially significantly, the provision of affordable housing within Northern Ireland. If levels of affordable housing provision are reduced then that is likely to have equalities implications. NIFHA Recommendation: NIFHA understands that the intention is to publish affordable housing policy which will then be amalgamated into the final draft SPPS. If an appropriate set of policies are introduced then that will address the issues noted above. However, if appropriate policies are not introduced into the SPPS then the SEA and equalities assessments will have to, as a matter law, make reference to the significant adverse impacts of that omission, in terms of both environmental and equality consequences. 24