CHAPTER 3: HOUSING

3.1 Introduction

3.1.1 Provision of housing to meet the needs of the people of Broxbourne remains one of the primary objectives of the Local Plan. The overall housing requirement is set through regional planning guidance and the Adopted Hertfordshire County Structure Plan Review 1991-2011. It remains for the Borough Council to make adequate allocations of land to ensure that the Borough’s contribution to county wide needs is attained.

3.1.2 In terms of the allocation of land for housing, the Council's objectives are to:
(I) Ensure that land is made available for at least 5,400 dwellings during the Plan Period 1991-2011.
(II) Ensure that at least 50% of new housing development takes place on previously developed land rising to 60% over the lifetime of this Plan.
(III) Phase developments to ensure, as far as possible, continuity of provision throughout the Plan Period.
(IV) Minimise the need for the release of land for housing from the Metropolitan Green Belt.
(V) Provide for land for housing in a manner and in locations which generate a mix of house types in terms of size and tenure, in a sustainable relationship to other uses and public transport.
(VI) Ensure that new housing developments make a significant contribution to the provision of affordable and special needs housing.
(VII) Ensure that each development contributes directly or through financial support to the provision of infrastructure in the Borough to meet the needs of the occupants of the new development.
(VIII) Require a high standard of design and layout to create attractive living environments.

3.1.3 Apart from a need to ensure that the right range and types of dwellings are provided to match, as near as possible, the housing needs of the Borough's population, there is recognition that house prices are higher in Broxbourne than in many parts of the country. Indeed, the average price of a house in Hertfordshire precludes those on low wages and key workers from obtaining adequate accommodation. This is not a problem unique to the Borough and PPG3 and Circular 6/98 provide guidance on the desirability of providing for this need through ensuring that an element of new housing on larger sites is made available and retained for affordable housing. The most recent (July 2002) Housing Needs Survey undertaken in the Borough suggests that mechanisms currently in place are not keeping pace with the problem. The Council’s response to this major problem is set out in policies H13, H14 and H15 and in section 3.8 of this Chapter.

3.1.4 The County Structure Plan highlights continuing trends for an increase in the total number of households coupled with a long-term decline in average household sizes. It attributes this to the growth in single person households created by the young moving out of family homes, divorce, increase in a general desire to live alone and the longevity of life for many citizens. All these factors impact both on the number of dwellings required and on the type of dwelling. During the second half of the 1990’s Broxbourne saw a high proportion of large (four and five bed-roomed) houses completed (50% of total completions between 1995 and 2000) primarily in West Cheshunt. There has been some reduction in this trend over the last two years but in order to comply with the objectives of government guidance, the Adopted Structure Plan and sustainability policies within this Plan, the Borough Council will seek to ensure that a much greater proportion of smaller dwellings is constructed within Broxbourne in coming years on land which is, as far as possible, located within the urban area.

3.1.5 The Structure Plan places a housing land requirement upon the Borough Council sufficient to enable the provision of an additional 5,400 dwellings between 1991 and 2011. The Council carries out annual monitoring exercises to determine the rate of house building in the Borough. Table 1 shows completions in the years from 1991 to the end of March 2005.

3.1.6 Over the first 15 years of the current plan period (March 1991- 2002), there has been a net gain to the housing stock of 4,848 dwellings, making up 89% of the Borough's housing requirement.

Table 1: Residential development 4/1991 – 4/2005

Source: Borough of Broxbourne, P2/NHBC Returns

3.2 Housing Requirements

3.2.1 National policy and guidance requires that the Borough Council will make provision for land for housing in accordance with the level of need set out for the Borough Council in the Hertfordshire County Structure Plan Provision of this amount of housing must be at a rate sustainable for the entire plan period. Accordingly, release must be in a controlled but flexible manner, influenced by monitoring of construction rates, house types and provision of necessary infrastructure and facilities.

3.2.2 The allocated sites in this Plan provide sufficient land to more than satisfy the current Structure Plan requirement. The Council will undertake continual monitoring of its residential land supply, actual development rates and the level of windfall sites given approval each year. It will also monitor progress on allocated housing sites. The Council will support windfall sites which provide affordable housing, or which make a significant contribution to either regeneration in the urban area or to meeting the objectives identified in the Council's Community Plan.

3.2.3 In line with PPG3, and in recognition of the fact that there is a limited supply of urban land within the Borough suitable for housing, the Council will seek the maximum practical contribution to the housing stock from urban sites. The Council will support higher density development particularly where adequate provision exists, or can be made available to provide access by means other than the private car.

3.3 Sources of Housing Land Supply

3.3.1 The 1994 Local Plan estimated that additional provision for small sites (5 or less dwellings) and from other "windfall" sites (i.e. sites for more than 5 dwellings but not allocated within the Plan) would account for an average of 15 dwellings per annum. In the event, that Plan did not anticipate some of the major windfall sites which came forward. Based on the findings of the most recent (January 2002) Urban Capacity Study the Borough Council considers it reasonable to raise this figure to 40 dwellings per annum for the period 2001-2011. This level reflects the fact that most of the larger scale sites which have the potential for redevelopment for housing (having regard to the need to comply with other policies in this Plan) have now been identified and allocated and that many of the unidentified sites which are currently coming forward are small in scale.

3.3.2 During the last plan period, several of the windfall housing sites which came forward represented redevelopment of old industrial premises. The Council has now carried out a very careful assessment of its industrial and commercial stock and has included within the housing allocations set out in this chapter any such land which it considers may be redeveloped for housing without adversely affecting the economic base of the Borough.

Urban Capacity

3.3.3 In accordance with PPG3 Housing published in March 2000, the Council undertook prior to publication of First Deposit a comprehensive survey of all urban land within Broxbourne (that is, all land excluded from the Metropolitan Green Belt) to ensure that the maximum contribution possible to the Borough’s housing needs was made from previously developed sites that are well located in terms of access to facilities. That survey was undertaken in autumn 2000 before detailed government guidance entitled “Urban Housing Capacity Studies: Towards Better Practice” was published in December 2000 and formed the basis for housing allocations in the First Deposit version of this Local Plan Review. Prior to publication of this Second Deposit version of the Local Plan Review, a further more detailed urban capacity study has been carried out. This study took into account the findings of an urban capacity study undertaken throughout 2001 by consultants acting for HCC in connection with the roll forward of the Structure Plan to cover the period through to 2016, as well as being informed by a further comprehensive in-house review based on site appraisals. The Council is satisfied that its study of the potential capacity of the urban area of Broxbourne closely follows government guidance.

3.3.4 The findings of the most recent urban capacity study suggested that in the region of an additional 2580 residential units could potentially be brought forward from sites within the urban area over the period to 2016. Given that the Adopted Structure Plan extends to 2011, however, this Local Plan Review can only be concerned with identifying sites to meet housing needs to 2011. Furthermore, it has not been possible to ascertain the likely availability of all of the sites identified in the Urban Capacity Study (in terms of the owner’s intentions, operational requirements etc) and not all identified land will necessarily be appropriate for housing development having regard to the sustainability and other land use objectives of this Plan. Hence, sites have only been considered as available for allocation if:-

• The site is at a sustainable location in respect of proximity to public transport and local facilities (such as shops, schools, bus routes and convenient pedestrian and cycle routes).
• The use is appropriate in the location having consideration for the immediate environment.
• The land is not required for other purposes.
• The land is likely to be available during the Plan Period.
• There are no known ownership constraints.
• There are no known infrastructure or other constraints to development which cannot be overcome during the Plan Period.

3.3.5 In order to achieve a managed release of allocated housing sites, as promoted in PPG3 Housing and examined in more detail in the DTLR paper issued in July 2001 entitled “Planning To Deliver – The Managed Release of Housing Sites: Towards Better Practice”, the Council is maintaining the phased approach to the release of housing sites. Allocated sites therefore continue to be divided into two categories, as listed under policies H3 and H4, depending upon the timescale within which it is considered that the site is likely to be available. Allocated sites are identified on the Proposals Map. Sites listed within policy H3 and H4 are anticipated as likely to come forward for development during the first period of the Plan with completion by the end of 2008. Sites listed under policy H4 will be held in reserve for housing completions commencing in 2008 and extending throughout the second period of the Plan.

Strategic Housing Sites

3.3.6 A number of sites allocated for housing arise from a re-designation of land from the 1994 Adopted Local Plan. Two of the sites listed in policy H3 are of particular significance.

3.3.7 NHS/MAFF Site.
The first is site H3(iii) which is the former NHS/MAFF land at Ware Rd, Hoddesdon (also known as The Hailey Site) which was designated in the 1994 Adopted Local Plan as an Area of Special Restraint reserved for the development of a hospital to serve The East Herts Health Authority area together with ancillary residential accommodation for hospital staff. However, at an early stage in the Plan review process, the Health Authority advised that it no longer intended to pursue a hospital development here. Part of this 9ha site constitutes previously developed land, having accommodated The Lea Valley horticultural experimentation station. Given that the site occupies a sustainable location, being adjacent to The Lea Valley Green Route (a public transport route), within easy walking distance of local shops, schools and recreation facilities and with Hoddesdon Town Centre just 2km away, the Council considers it suitable for primarily residential development together with a new medical surgery for The Primary Care Trust. The Council adopted a Development Brief for the Hailey Site on 16th April 2002 to guide development of the site which is envisaged as providing in the region of 300 dwellings, 30% of which should be affordable.

Canada Fields

3.3.8 The second site comprises approximately 11ha of land at Canada Fields was allocated in the 1994 Adopted Local Plan for employment purposes. However, it was apparent by an early stage in the Plan review process that the form of development previously envisaged was most unlikely to occur. Following advice in PPG3 Housing the Council therefore considered the re-designation of this important land resource for alternative purposes. The proximity of the land at Canada Fields to the existing retail and commercial development at Brookfield led the Council to reconsider its future in the light of the identified objectives for Greater Brookfield, set out in chapter 6 of this Plan. As a consequence, the designation of this land has been changed from employment to primarily residential use together with associated community facilities. The Council adopted a Development Brief for Canada Fields on 24th July 2001 to guide development of the site for in the region of 650 dwellings, and construction work has now commenced. Due to the urgent need to provide a significant amount of affordable housing to meet unmet need within the borough the Council resolved not to constrain the development of this site by the imposition of a phasing agreement, as originally envisaged.

3.3.9 Because of the very significant contribution to the Borough’s housing supply which is planned to come forward from The Hailey site and land at Canada Fields, these two sites have now been designated as “Strategic Housing Sites” in accordance with advice contained within the good practice guide “Planning to Deliver - The Managed Release of Housing Sites”. The Hailey Site reflects the Structure Plan requirement to concentrate new housing development as far as possible on previously developed land whilst development of land at Canada Fields for housing is considered to represent a more sustainable use than its previously allocated use for commercial and leisure development, and additionally having regard to the Council’s primary objectives of promoting Greater Brookfield as a single entity for mixed uses well served by public transport. This is explored more fully in chapter 6. Additionally, both strategic sites are well located in terms of transport networks making them suitable for development at densities towards the higher end of the range (30-50dph) advocated in PPG3, which in turn encourages the production of a significant amount of affordable housing.

3.3.10 Since publication of the First Deposit version of this Plan Review in April 2001, a clearly defined site within Hoddesdon Town Centre has been promoted for mixed retail, commercial and residential development. This is known as land at Fawkon Walk, Hoddesdon. On the basis of detailed consents now granted, this scheme is now expected to bring forward around 138 units of residential accommodation, a substantial proportion of which will be sheltered housing designed to meet the needs of the elderly. A further 47 units will be provided east of Taverners Way in the existing precinct .The sites allocated in policies H3, H4 and H5 are those allocated at First and Second Deposit stage which remain unimplemented or still to be completed. An additional long term site for development is at Cheshunt South Reservoir. The existing reservoir is to be decommissioned and in-filled by 2006. Following consideration at the local plan inquiry this site has been re-instated as an housing allocation.

3.3.11 In order to ensure that each of the sites listed in policies H3, H4 and H5 is used to its full potential, whilst making the maximum contribution to the dwelling types most in need in the Borough, an indication of anticipated dwelling numbers and types is given in each instance, together with an indication of the contribution which will be sought from each site to affordable housing.

Housing Provision 1991-2011

3.4 4848 dwellings have been completed since 1991 leaving 546 dwellings that to satisfy the current structure plan requirement to 2011. As at 31st March 2005, having regard to existing commitments and allocations, the supply of housing within the Borough totals 1,848 dwellings (table 2).

Table 2 : Housing Provision 1991-2011 (as at 31st March 2005)

3.5 Housing supply from “green field” sites

3.5.1 With the both windfall and allocated sites coming forward , the Council has been able to meet its housing allocation of 5,400 dwellings in this plan period without the need for alterations to the Green Belt boundary. It has not been considered necessary to allocate reserves of greenfield land or areas of special restraint. Revised housing allocations for this Borough for the period 2001-2021 are expected to finalised during 2007 in the East of England Plan. In response to the new regional plan, the Council has committed to undertake a review of urban and greenfield land and the timetable for this is set out in its Local Development Scheme.

3.5.2 This Plan includes a proposal at policy EMP11 for the replacement of the St Mary’s school in Cheshunt with a new school at a site at Bury Green Farm The County Council and Diocese of St Albans have submitted strong representations to the Borough Council in support of a housing development on the curtilage of the existing school buildings in order to help fund the new school. The Council have agreed an outline planning consent for the site for housing taking into account the previously developed nature, its sustainable location and the need to find an early viable re-use for this site. While the site is not formally allocated in this plan it will be treated as a windfall development when the existing school site is vacated. This site is currently in the Green Belt. If housing development comes forward, the Council will consider revisions of the Green Belt boundary in this area as part of a comprehensive review within the Local Development Framework. A revised development brief has been prepared for this site (May 2004) which has been prepared to guide future detailed applications.

West Cheshunt Area

3.5.3 Many individual sites as well as wider tracts of land in this area have continued to be promoted to the Council for consideration for release from the green belt and allocation for housing development by landowners, those representing them and by development companies despite the strong opposing stance shown by the Council in First Deposit. The Borough Council sees this as a product of residential development brought forward during the latter 1990’s in response to policy 54 of The Hertfordshire County Structure Plan Alterations 1991 and policy H1 of the Broxbourne Local Plan Review 1994.

3.5.4 The impact of the development which occurred in the 1990's as a consequence of the Structure Plan allocation upon the character of West Cheshunt is now evident. In the main the Borough Council is satisfied that the level of development accepted in the areas chosen, which contained the worst of the dereliction, has enabled the rural character to prevail. It was accepted at the last review that some areas of derelict glasshouses would not be redeveloped and it is interesting to note that in a number of instances natural regeneration has, in the main, obliterated the worst impact of dereliction. In some instances new woodland areas are appearing, containing the visual impact of both new and old development and enhancing the still predominant rural character. The three major areas developed through the last Local Plan period have retained, to a reasonable degree, visual and physical separation and most, although not all, of the dereliction has gone. Nevertheless the balance between the urbanised areas and the intervening rural swathes is delicate and in the light of advice in PPG3, the Council's own urban capacity study and compliance with adopted Structure Plan Review housing figures without the need for major green belt releases, the Council has come to the conclusion that further development in the West Cheshunt area is not justified as part of this Local Plan Review.

3.5.5 Pending a comprehensive borough wide review of housing needs and the Green Belt, the Council will resist any further development in the West Cheshunt area which would conflict with the purposes of including land in the Green Belt as set out in PPG2. During this period the Council will also resist any such ad hoc development proposals based upon the following factors:

• damage to the dominant rural character of the Rags Brook Valley;
• the Inspector’s comments following the last Local Plan Inquiry;
• the availability of local infrastructure;
• sustainable development principles;
• the threat of coalescence of communities;
• compatibility with existing residential development;
• location in relation to major leisure, retail and employment areas;
• public transport provision
• educational facilities

3.5.6 Whilst these comments are relevant in the context of this current review, the Council acknowledges that an early review after the East of England Plan has been finalised in 2007 will involve the Council in a comprehensive PPG3 search (see PPG3 p.graphs 30 and 31) and land west of Cheshunt will not be prejudiced as part of that search sequence. The Council will also consider additional policies or measures could assist in the restoration of derelict nursery sites. Accordingly, apart from two very small adjustments of the Green Belt boundary in St James Village, the Council proposes no alteration to the Green Belt boundaries in this area and no new development.

3.6 Affording protection to existing housing

3.6.1 It is important that the Plan continues to afford protection to established residential areas. This will be achieved by ensuring that amenity areas provided within residential areas are retained as open spaces for the benefit of all residents; seeking to prevent the displacement of parked cars onto streets/grassed verges by exercising control over the conversion of garages; and by preventing over-development by careful control of extensions and alterations to existing dwellings, including the withdrawal of “permitted development rights” on higher density developments.

3.6.2 Retention of all of its existing residential stock is a primary aim of the Borough Council. In order to protect and retain the existing level of residential accommodation in the Borough, proposals which would result in the net loss of useable residential accommodation will be resisted. Redevelopment of existing housing will be considered favourably where there is no net loss of housing, and the replacement development offers an appropriate type and mix for the area concerned, at a density compatible with the sustainability objectives of the Borough Council. Exceptionally, circumstances may arise where there could be an overall advantage, whether in terms of the amenity of existing residents, for employment reasons or because of other benefits to the Borough's population as a whole, which warrant some limited loss of existing housing.

3.6.3 The Council will encourage the refurbishment of existing poor or substandard residential accommodation where this can be brought up to standard economically and at a reasonable density which contributes to the Borough's overall housing requirement. Whilst compliance with the Council's standards and criteria for residential development, as set out in Supplementary Planning Guidance, will be the expectation when proposals for the redevelopment or refurbishment of existing residential property is under consideration, some relaxation of specific standards may be permitted when this would result in overall benefits to the locality.

3.7 Residential development policies

3.7.1 In order to achieve a high standard of design and a consistent approach to the provision of reasonable levels of privacy and amenity for individual occupiers, the Council will seek to ensure that all new build housing development and, as far as is practical, conversion of existing buildings from other uses, meet the minimum requirements set out in Supplementary Planning Guidance. There is also a need to ensure that adequate provision is made for access and parking. The advice in SPG will be applied flexibly in recognition that each property or site will display its own characteristics. However, the aim must always be to achieve a good standard of residential amenity for all new residential development without prejudicing the amenity enjoyed by occupiers of existing properties. There will therefore be a presumption against the grant of planning permission for proposals which fall significantly short of SPG standards.

3.7.2 Notwithstanding the above, there will be instances where certain types of specialist housing, by their very nature, may warrant a relaxation from some of the minimum requirements within SPG. Sheltered accommodation for the elderly is a case in point. Part II of policy H8 addresses such cases.

3.7.3 The conversion of existing larger residential properties into two or more dwellings can make a valuable contribution to increasing the Borough's housing stock. In principle, the Council will support the conversion of large dwellings into self contained flats where the development would be compatible with the character of the area concerned and the cumulative impact of conversions in a particular locality would not adversely affect its character. Extensions proposed in association with conversions will be assessed against policy H6 part (II) whilst the conversion itself will be assessed in accordance with H9. For the purpose of this policy, a large dwelling will be taken as meaning one having a net floor area in excess of 120 sq.m. "Net floor area" includes internal measurements of all rooms, corridors, hallways and landings but excludes external walls and internal partitions. Suitability of such premises for conversion will not depend upon the size alone but also upon the current layout and its adaptability to provide new homes generally to the standards set out in SPG.

3.7.4 In assessing floor space available for conversion, the Council would normally expect basement areas to be excluded as they rarely represent a good residential environment. In addition, where lofts already contain accommodation, this may be considered as part of the overall net floor area. However, conversion of both basements and lofts to provide fully independent new units will normally be resisted on the basis that such conversions are unlikely to achieve a reasonable standard of internal environment.

3.7.5 In assessing the ability of the urban area to accommodate additional housing development, the Council has considered carefully commercial properties, in particular those which it is thought probable might become available during the plan period for other purposes. These are included in the list of allocated housing sites at policies H4 and H5. However, the Council is aware that from time to time other commercial premises, and premises in other non-residential uses, become redundant with little likelihood of re-use for their original purpose. In these circumstances the Council will consider favourably conversion, or redevelopment if conversion proves impractical, to residential use provided that it can be satisfactorily demonstrated that permanent loss of the previous use would have no material adverse impact on employment prospects and/or local community facilities. Schemes for conversion should accord with SPG as referred to in policy H10.

Density of Residential Development

3.7.6 Land for new housing in the urban area is limited. To meet the sustainability aims of government, as expressed in PPG3 Housing published in March 2000, in the 1998 Adopted Structure Plan and in this Local Plan, it is important to maximise the potential for new housing from urban sites in order to minimise green field development throughout the period of this Plan and subsequently. One method for increasing the effective use of under-used urban land for housing is to increase densities. The practical effects of this will depend very much upon the location of the particular development, its relationship to adjoining areas, the general character of the area and the location of the site in relation to public transport, shopping, employment and leisure uses. High density by itself need not signify bad design but there is a need to recognise that such schemes require the application of good urban design principles if the amenity of all occupiers is to be protected whilst, at the same time, the needs of all types of households in the Borough are to be met.

3.7.7 It is not practical to impose set densities for areas of the Borough as flexibility often helps in achieving maximum potential. However, the Council recognises the assistance to potential developers and others of providing an indication of density expectations. The number of new dwellings anticipated as being achievable from the three lists of allocated housing sites are set out in policies H3, H4 and H5. For all other sites general density presumptions will be assessed against policy H11. The Council will apply the definition given in PPG3 Housing issued in March 2000 for calculating relevant densities. This definition is re-stated in SPG. Whilst the Council recognises that there can be benefits from building above the normal two storey height in residential developments, appropriate building heights will be determined on a site by site basis having regard to the characteristics of the surrounding area. The Council considers that it is unlikely to be appropriate within the Borough to provide residential development in buildings of greater than three and a half storeys in height.

3.7.8 In addition to controls over density, the Council is also concerned to ensure that a range of houses sizes and types is provided to meet the needs of the Borough’s existing population.

3.8 Affordable Housing

3.8.1 Affordable Housing is defined as any housing for sale or rent or other form of tenure which is intended to be accessible to people whose incomes are insufficient to enable them to afford to obtain adequate housing locally on the open market.

3.8.2 The Borough of Broxbourne is an area of relatively high private sector house prices. The high cost of renting and home ownership create problems for local people wishing to remain in the Borough and for some employers wishing to attract key workers. Key workers including nurses, police officers, teachers and other public sector workers, are a specific group of housing need. The Council has recognised this need and has accepted a small percentage of housing will be for shared ownership to reflect that provision.

3.8.3 Planning Policy Guidance Note 3: 'Housing' and Circular 6/98: 'Planning and Affordable Housing' clearly state that a community's need for affordable housing is a material planning consideration in the formulation of development plan policies and in the determination of planning applications involving housing. The definition of affordable housing includes subsidised housing on private developments, and developments by Registered Social Landlords and local authorities. Broxbourne Council regularly undertakes housing needs surveys and produces a Statement of Need, to assist the preparation and justification of policies on affordable housing in the Local Plan, to underpin the Strategy Statement for the Housing Investment Programme and to form the basis for the Council's Affordable Housing Strategy. Statements of Need are produced on a regular basis by the Council, and together with the Affordable Housing Strategy, they should be referred to for up to date Information, since they provided a comprehensive analysis of the need for affordable housing in the Borough.

3.8.4 The Council's surveys demonstrate a high level of need for affordable housing which is predicted to continue. It is therefore essential to provide housing at less than normal market prices, and which people can afford. All reasonable opportunities to provide affordable housing will be pursued by the Council. As highlighted in the Statement of Need, the Borough's identified housing needs can best be satisfied by provision of social rented accommodation. Therefore the Council expects affordable housing primarily to be that which is available for rent through an approved registered social landlord or the Council itself.

3.8.5 The Council's Housing Needs Survey (July 2002) revealed that there is a requirement for 1950 units of affordable accommodation to be provided over the next 10 years. The Second Deposit Plan has identified sites for a total of approximately 1476 dwellings over the Plan period to 2011. Therefore even if all new housing in the Borough, built during the Plan period were to be affordable, there would still be a shortage of approximately 474 units. This clearly demonstrates the acute shortage of affordable housing which exists within the Borough and the importance of this issue to the Local Plan.

3.8.6 The principle of residential development on allocated housing sites was established through an urban capacity study and guidance set out in PPG3. In particular, regard was paid to the proximity of each site to local services and facilities and the accessibility of each site to public transport. These identified sites therefore comply with the criteria set out in Circular 6/98 as being suitable for an element of affordable housing. It is expected that affordable housing provision on these identified sites should be 40% of the dwellings provided, reflecting the mix set out in the Council's Affordable Housing Strategy and/or Statement of Need.

3.8.7 Since the identified need for affordable housing exceeds the total number of affordable homes likely to be achieved from public investment and the sites specified in this Plan, the Council considers that there are exceptional local conditions to justify adopting a lower size of site threshold for affordable housing provision. The Council will therefore seek provision of affordable housing from sites capable of accommodating fifteen dwellings or more or residential sites of 0.5 ha or more. On sites below the size threshold, the Council will encourage developers to consider affordable housing provision where it is feasible and appropriate. However a careful assessment will be made on proposals for housing development which fall just below the threshold (eg 12-14 dwellings) against the criteria in H13(III) and Policy H2.

3.8.8 Additionally, the Council will also seek the provision of affordable accommodation from unallocated sites (so called "windfalls") which come forward for housing after the Plan is adopted. Even though the supply of housing from windfall sites is expected to average around 40 dwellings per annum, and therefore its potential contribution to the overall supply is small, the acute level of housing need within the Borough justifies the consideration of windfall sites for affordable housing provision. Unidentified sites will be assessed in accordance with the criteria set out in Policy H16 for their suitability for affordable housing. Unidentified sites where the principle of residential development is acceptable, will by definition, comply with criteria (a) and (b) of part (II) of Policy H13. The Council will seek to ensure that provision of affordable housing on unidentified housing sites complying with the threshold and criteria set out in this policy is achieved at similar level of provision as for allocated sites, namely 40%. Provision of affordable housing on unidentified sites should reflect the mix set out in the Affordable Housing Strategy.

3.8.9 The supply of affordable housing through site assembly by the Council is increasingly constrained as the supply of Council owned land is reduced. Potential sites have been identified in a development programme with housing associations, but activity will be subject to the availability of sufficient resources being advanced to implement it.

3.8.10 PPG3 Housing encourages comprehensive redevelopment of land in order to secure the wider potential benefits of urban renaissance and avoid town cramming. With this in mind, the Council wishes to ensure that development proposals for residential development fully explore the potential to amalgamate sites to allow the most efficient use of land and facilitate the provision of affordable housing. In assessing the opportunities for amalgamation of sites which comply with the site criteria for affordable housing, the Council will also have regard to policies HD15 Comprehensive Approach to Urban Regeneration proposals and H11 Housing Densities in New Development on Unallocated Housing Sites.

3.8.11 In accordance with the broad definition of affordable housing expressed in Circular 6/98, the Council may accept a proportion of shared ownership property and low cost market housing, taking into account the current Affordable Housing Strategy, as fulfilling the affordable housing requirement, subject to negotiation on a site by site basis. Developers should be mindful of the Affordable Housing Strategy in relation to the allocation of Social Housing Grant. However, affordable housing which is not available for rent will not be acceptable if it exceeds the maximum levels set out in the Statement of Need and/or Affordable Housing Strategy. Even discounted open market housing is expensive in comparative terms and thus likely to be beyond the reach of most people in housing need. Accordingly, the Council's Statement of Need Clearly states that shared ownership has only a minor role to play in the provision of affordable housing within Broxbourne.

3.8.12 The intention of Policy H15 is to ensure that, as far as possible, affordable housing remains affordable and is occupied by local people in need. The Council recognises that Right to Buy and Right to Acquire provisions may supersede this policy.

3.8.13 The type and mix of units which will be sought for affordable housing will be as outlined in the relevant Statement of Need and/or Affordable Housing Strategy, which will be updated on a regular basis. Within the 1999 Statement of Need, the greatest demand is for larger family sized dwellings due to the number of families in temporary accommodation.

3.8.14 Registered social landlords will provide and manage affordable housing, but other agencies will be involved too, particularly in construction. The Council expects these agencies to tackle priority needs, whether defined Borough-wide or locally, and meet price and design guidelines. The Council will not accept a lowering of standards of construction to achieve satisfactory rent levels.

3.8.15 Weekly rent levels should be set at the lowest practical level below the benchmarks set by the Housing Corporation, and in any event should not exceed them. Annual rents for shared ownership properties should not exceed the benchmark set by the Housing Corporation.

3.8.16 The Council operates a cascade approach to occupancy of affordable housing units, whereby, housing is restricted to people currently living in the Borough who are in need and who immediately prior to an allocation were households:

(I) lacking their own housing; or
(II) living in housing which is inadequate or unsuitable; and who are unlikely to be able to meet their needs in the housing market without some assistance.

3.8.17 In order to assess the effectiveness of these policies in delivering affordable housing, the Council will undertake monitoring to measure the amount and type of affordable housing coming forward as part of residential developments on both allocated and windfall sites.

3.9 Other Special Needs Groups

3.9.1 In addition to the need for affordable housing, other people may need to be able to live as part of a mutually supportive group, to be near help when needed or to be given constant care and attention. Many people with special needs can and do live without difficulty in the community. The Town and Country Planning (Use Classes) Order 1987 defines a dwelling within Class C3 as a property used "by not more than six residents living together as a single household including a household where care is provided for residents", thus including some opportunities for care in the community. However, the Council recognises that there is a need for premises catering for larger groups of persons which will require planning permission. Accordingly, proposals for such uses will generally be supported provided that the use is compatible with the local environment in terms of the general level of activity at the premises, traffic generation and the need for extensions and/or additional buildings to enable the use to operate efficiently. In view of the probable increasing demand over the lifetime of this Plan for places in residential care homes due to the generally ageing population, it is equally important to afford protection to existing homes and to seek to prevent their change of use unless satisfactory alternative provision has been made for existing residents.

3.10 Hostel Accommodation

3.10.1 Hostels, whether for students, the homeless or other disadvantaged groups, often give rise to concerns on social issues and fears about the impact that such uses may have upon the amenity of their immediate environment. Nevertheless, there is a need for such provision and the Council will consider applications on the same basis as other special needs groups but with the additional expectation that all such applications will be accompanied by a full statement assessing the impact of the proposed use upon the area and measures to be taken to ensure that the amenity of existing residents is protected.