The Council should consider omitting the tenure altogether.

The use of different affordable housing percentages for greenfield and brownfield sites in this policy is supported on the basis of this supporting regeneration of brownfield sites. The text in this policy does not however reflect that delivery of First Homes across the Borough may further dilute the delivery of affordable housing tenures that better meet local housing needs, and in sufficient quantities to hit the Council’s targets for meeting housing need. It is concerning that the Viability Assessment – Further Update Note (January 2023) does not contain any detailed analysis of the costs associated with delivering First Homes, nor the impact of varying discounts necessary to deliver different house sizes to meet the price cap within Chichester.

The local planning authorities of Bath and North East Somerset Council and Guildford Borough Council have identified the lack of affordability of First Homes within their communities and taken steps to prioritise other affordable housing tenures. In the case of B&NES due to the evidence demonstrating that First Homes is not affordable and would affect delivery of other affordable tenures, the Council has decided not to implement the national guidance and excluded the tenure from their policies and guidance.

In contrast, the emerging draft Guildford Local Plan Policy H8 incorporates flexibility to deliver alternative affordable home ownership tenures where delivery of First Homes would “lead to an adverse planning outcome”, making delivery of First Homes an expectation, but not a requirement.

The HEDNA (April 2022 Final Report) suggests that:

“the clear need for additional rented housing would arguably mean that providing the affordable home ownership would ‘prejudice the ability’ to meet the needs of the ‘specific group’ requiring rented accommodation”.

It also notes that delivery of First Homes may ‘squeeze out’ other forms of low cost home ownership housing such as shared ownership, and delivery will, in particular for 3-bedroom dwellings for which there is significant need within Chichester, require additional discounts to hit the national cap. These higher discounts prejudice the viability of development, and in particular the delivery of rented affordable housing.

The introduction of First Homes as expected by the national guidance may reduce the opportunities for mixed tenure developments to meet local housing needs, contrary to national policy. We ask that the Council review whether the omission of the tenure, as supported by Bath and North East Somerset Council, would operate more effectively in Chichester than the flexibility currently suggested in the policy text. If not, the flexibility as currently drafted will assist in delivering housing in response to local need, affordability, and viability.

Abri supports the further text supporting development identifying opportunities for delivering a proportion of affordable housing for older persons.