Sevenoaks District Draft Local Plan Consultation July 2018

Document Section Draft Local Plan July 2018 Providing for Housing Choices Market and Affordable Housing Mix Policy 8 - Market and affordable housing mix [View all comments on this section]
Comment ID DLPP1087
Respondent Tetlow King Planning (Planning… [View all comments by this respondent]
Response Date 27 Sep 2018
Current Status Accepted

We represent Rentplus UK Ltd, an innovative company providing affordable rent to buy housing for

working people aspiring to home ownership with an accessible route to achieve their dream through the

rent - save - own model. This is achieved through a combination of a secure affordable rented period

(whichever is the lower of 80% of open market rent, including any service charge, or Local Housing

Allowance), giving time to save, and a 10% gifted deposit to enable tenants to buy their own home in 5,

10, 15 or 20 years.

We previously responded to the Issues and Options consultation in September 2017. In the time since

then the Government has published a revised NPPF, containing within it new policies relating to the

assessment of housing needs and the tenures of affordable housing that local planning authorities must

assess and seek to deliver. It is important for the Council to consider how its policies will be used in

determining planning applications in the long term, assessing the need and planning for the delivery of

the new, wider types of affordable housing to meet local housing needs.

As noted in our previous representation, rent to buy affordable housing seeks to meet the needs of

those households who cannot access home ownership without intervention. This model has now been

fully recognised and incorporated within the definition of affordable housing set out in the revised NPPF

under the new category of ‘other affordable routes to home ownership’:

"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 local market value) and rent to buy (which

includes a period of intermediate rent). Where public grant funding is provided, there

should be provisions for the homes to remain at an affordable price for future eligible

households, or for any receipts to be recycled for alternative affordable housing

provision, or refunded to Government or the relevant authority specified in the funding

agreement." (Our emphasis)

It is clear from the changes to the NPPF that the Council will need to reconsider the wording on

affordable housing throughout this draft Local Plan, most prominently in Section 5, and paragraphs

5.18 to 5.32 and Policies 9 and 10. For example, the new definition of affordable housing in Annex 2

of the revised NPPF states that affordable housing is "housing for sale or rent, for those whose needs

are not met by the market (including housing that provides a subsidised route to home ownership and/or

is for essential local workers)" – it is no longer tied to only social and affordable rented and intermediate


The Plan acknowledges the severe affordability pressures present in Sevenoaks, with a severe house

price to income ratio of 13 having a crippling effect on household formation. For the Plan to be effective

over the long term the Council would be well served by encouraging the delivery of a wider range of

housing – to support this the policies and supporting text should reflect the new Framework phrasing,

for example with the below minor amendments to paragraph 5.18:

"5.18 Affordable housing is provided to eligible households whose needs are not met by the

market and includes social rented housing, affordable rented housing and intermediate

affordable housing for rent or sale, including affordable routes to home ownership."

Delivery of affordable housing is critical to responding to local housing needs, particularly for those who

cannot afford to rent in the private rented sector. We note that paragraph 5.20 states:

"Building new affordable homes will help ensure that those requiring assistance receive it, and

the increase in the supply of affordable housing will help to slow down the rise in housing costs,

allowing those who aspire to own their own home the ability to get onto the housing ladder."

This alone will not be enough to support local people into homes that they can afford, particularly as

access to mortgages (for both open market and intermediate affordable tenures) relies upon each

household having saved for a mortgage deposit. Social and affordable rented housing needs to be

delivered alongside other forms of housing for those who could afford home ownership in the longer

term but are not able to access a mortgage deposit in the short term - to encourage and support more

people to stay within the District there needs to be more access to types of housing from which people

can afford to build up savings. As the Rentplus rent to buy model uses a combination of a secure

affordable rented period - the lower of 80% of open market rent, including any service charge, or Local

Housing Allowance - for a minimum period of five years, tenants have time to save towards the

mortgage deposit.

Rentplus always work in partnership with locally active housing associations to ensure that rent to buy

is affordable in each local authority area, while working with those local authorities to encourage

allocations from the housing register. This reduces the numbers of households waiting for appropriate

housing and frees up resources to target households with higher priority needs. Enclosed with this

representation is a document setting out broad findings from those schemes that have already been

completed and occupied, highlighting the success of this tenure in meeting local authority and partner

RP aims in meeting local housing needs.

As an example, the first Rentplus scheme delivered with Tamar Housing received bids from 200

households in the first 24 hours and was subsequently 41% filled by households in Band C of the local

choice based lettings scheme. Of the total, 30% of tenants moved from social rented housing, while a

further 35% were previously living in overcrowded households. These developments not only free up

existing affordable housing for others in need on the housing register, but also enables RPs to diversify

their stock and deliver more affordable housing of all tenures.

Paragraph 5.23 will need to be updated to reflect the new affordable housing definitions, but also the

Strategic Housing Market Assessment as this cannot be used to understand need for the wide range of

affordable housing types now recognised by the Government; this will inevitably impact on the

recommended split also set out in that supporting text.

For a change in delivery of affordable housing to take place, encouraging a much greater supply, policy

needs to be robust in seeking the most ambitious level of affordable housing, from as wide an array of

developments as possible. Policy 9 should be amended to refer to the wider range of affordable housing

tenures as defined by the revised NPPF, replacing "including social rented..." with "including housing

for sale or rent, including housing that provides a subsidised route to home ownership". The

preferred tenure split should change, following a review of local housing need that takes into account

the revised NPPF definition and the expectation that 10% of major developments be delivered as an

affordable home ownership property.

To assist with that review of housing need, we recommend the Council and its advisors review the

methodology produced by Lichfields (enclosed with this representation). We ask that the Council

engage directly with local providers of affordable housing, including Rentplus, to discuss the most useful

policy approaches to encouraging this delivery and in reducing the barriers to development coming

forward more quickly to meet needs.

Policy 10 should also be reviewed in light of the new policy of entry-level exception sites introduced in

the revised NPPF (2018) which encourages delivery of schemes on the edge of existing settlements

with homes suitable for first-time buyers and those looking to rent their first home.

The Council should also look to review the definitions set out within the Glossary, looking to set a local

definition of affordable housing that reflects the national definitions.