Southampton City Vision Local Plan Chapter 2 - Homes

Density Policy Options

Theme: Homes
Policy Name: Density
Policy Number: HO1(S)
Options Y/N: Y

Summary of responses (88 received)

There was a decidedly mixed opinion on this policy with some supporting a general increase in density to help meet housing needs, particularly where it would be in good proximity to public transport and major centres of employment. Some went further and suggested that the density levels proposed were still too low. There were also some who suggested that the density levels proposed for the 'rest of the city' could be too low in some circumstances and that there may be some sites which could support higher densities meaning a more flexible consideration of site-specific circumstances was needed. However, a notable number of responses did not support higher densities raising concerns about the impacts this would have on Southampton's character as well as increasing pressure on infrastructure and services. Some did not consider higher densities to be the right solution for housing citing the failures of various national high-density developments over the past few decades and that they would have a negative impact on quality of life. There was also a criticism of nationally imposed housing targets necessitating higher densities and suggestions the Council should ignore these targets. Another point of view was that density should be gently increased across the city to create a more uniform density for the city as a whole.

There were also mixed opinions on how higher densities should be achieved. Some supported the use of tall buildings and were even excited by the potential of new architecture to raise the profile of the city. However, others thought mid-rise development would be more appropriate for the city, to bridge the gap with existing residential areas. There were also some who did not want to see buildings go beyond 3 to 6 storeys or that the number of new tall buildings should be kept to an absolute minimum. Some suggested a cap on maximum heights that would be allowed in the city. What people were in agreement over is that high density developments, including tall buildings, need to be very well designed and of high quality.

There were also differences of opinion in how higher density development should meet the mix of housing needs in the city. Some favoured still delivering detached dwellings whilst others emphasised the need to deliver more affordable and more smaller scale dwellings, namely 1 or 2 bed units. There were those who did not support the creation of any new 1 storey, or even 2 storey, dwellings where these did not already exist. Whereas, some emphasised the need to still allow bungalows in some areas as a means of providing accommodation for older people that could also free up family dwellings as they downsize.

A critical issue for many was that new higher density developments should not have an adverse impact on existing open spaces. There was support for such developments also making sure to include new open spaces as well as providing sufficient levels of private amenity spaces such as balconies and roof gardens. There were also suggestions that the policy needs to better respond to environmental and heritage constraints and that new higher density developments should be delivered in a sustainable manner. Whilst there was support for allowing higher density development near public transport hubs and routes, some reiterated there would still be a need to provide parking for residents as car free developments were considered to be unfeasible and unattractive to future occupiers.

Some responses found the policy difficult to interpret and considered a more lay approach is needed to the text. Others also identified difficulties in conceptualising the proposed densities and suggested examples of similar densities from within Southampton or elsewhere should be included. There were suggestions that certain parts of the policy text should be amended to prevent potential loopholes where proposals could be watered down,or obligations avoided. It was also suggested that certain terms should be more clearly defined to prevent arguments with developers over how they should be interpreted.

Housing Mix Policy Options

Theme: Homes
Policy Name: Housing Mix
Policy Number: HO2(S)
Options Y/N: Y

Summary of responses (62 received)

On the whole, the majority of respondents were supportive of the policy approach, though many suggestions were made to amend specific elements of the policy to take account of different priorities to deliver better housing choice for all and the right mix of housing to meet the market/social demand for the communities in the city. A spectrum of views expressed where the balance for the percentage level of the family housing mix target should lie with new development according to housing need and delivery constraints. This is further analysed through the comments received under the relevant policy options.

• Six strong themes came out of the responses which focused on:
• manage the conflict with family housing in communities affected by high concentrations of HMOs
• various views on how the format of private and communal garden spaces for housing should be designed, especially in the city centre where there is pressure on parks,including anti-social issues, to compensate for higher density developments with limited residential garden space,
• the definition of family housing should recognise the need to deliver for different sizesand types of families, recognising the need to provide more 1 and 2 bedroom apartments suitable for couples and single persons within the housing mix
• flexibility needed to develop sites with no family housing in places not suitable for families to live,
• the policy does not directly address the housing needs of certain groups including homeless, older, disabled persons, key workers (e.g. NHS staff), social housing and self and custom build houses, and better recognition of the emergence of new housing models such as build-to-rent (BTR) and co-living, and
• tackle affordability and availability pressures of housing for all types of households and making sure that family housing targets are properly delivered.

There was a mixed response to Options 1a) and b). Housebuilders were generally concerned that without a strategy/site identification their large sites would be burdened by accommodating plots for self and custom homes, whilst other respondents were concerned that sites should be identified to support self-builders and cooperative style housing coming forward.

There was a mixed response to Options 2a), b) and c) in terms of what the overall family housing mix percentage should be for new developments. Whilst respondents sought greater flexibility of the target to recognise that the circumstances of individual sites coming forward, especially in the City Centre, are not suitable family housing, others were critical that family housing targets should be applied more rigidly to support family housing being built or the targets are not generous enough. Whilst others expressed caution that building more family homes will conversely support the growth of the HMO and short-term landlord market in communities. Respondents were critical of the policy robustness in basing family housing need on the out-of-date SHMA published in 2014. Others were critical that the housing needs of certain groups including homeless, older, disabled persons, key workers (e.g. NHS staff), and those in need of social housing should be better recognised by the policy in the overall housing mix of new development alongside the emergence of new housing models such as BTR and co-living. There were suggestions by retirement housing providers to create a standalone policy outside the housing mix to deliver and identify need for sites to develop older persons housing. Some suggested that BTR and co-living housing should be included under definition of affordable housing in the Local Plan glossary. Others suggested the Council should explore the model of purpose-built housing providing a range of accommodation for different users to live within the scheme alongside older persons and students to create self-supporting communities.

Respondents were generally more supportive of Option 3b) to build in flexibility and exemptions to allow the net loss of family homes to enable sites to come forward with other benefits and recognise the benefits of delivering retirement homes and PSBA in releasing family housing stock used by these groups. That said, representation was made that providing retirement housing is not the only solution for older persons, with suggestions the loss of bungalows outside the City Centre should be resisted to safeguard this housing stock for the needs of older persons. Within communities with high concentrations of HMOs, concerns were raised that the mix and balance of communities could be further upset by losing family homes when landlords decide to convert their HMO stock into flats/studios, whilst more controls should be applied to control the proliferation of short terms let such the Airbnb market. Conversely, further concerns were raised about allowing more family housing near areas of high concentrations of HMOs given the anti-social conflict for families living alongside transient households.

There was a mixed response to Options 4a) and b) in the public perception and within housing builders/market of what a ‘family home’ should constitute to meet the needs and preference of users. Respondents felt that strictly defining a ‘family home’ as a 3-bedroomhome doesn’t fit the need and demand for all types of families in the city and suggested that 2 bedrooms should also form part of the definition. There was a mixed response to the appropriateness of the amenity space standards specified. In terms of living conditions, some considered the standards to be right, whilst others felt that their minimum size wasn’t high enough to tackle poor housing conditions. In general, housebuilders preferred Option 4b) for greater flexibility in the family home definition to allow housing development to be maximised on certain sites by relying on communal space where it is not possible to provide private space for families, especially in the City Centre and other areas suitable for higher density housing. Housing providers for retirement and supported accommodation for disabled persons considered that this housing should be exempt from the amenity space requirements identified in point 3 of the policy, however, schemes must provide high quality amenity space that meets the needs of residents, and supported by appropriate on-site management plan. Respondents felt the standards should further prescribe a higher minimum size and number of living facilities for family housing to tackle poor housing conditions. Conversely, it was suggested that it would be socially better to deliver a uniform type of housing to improve equality for all residents in the city. Although being outside the scope of planning system legislation, it was suggested that the policy could address the affordability of housing by specifying maximum housing and rents prices on reviewable basis.

Affordable Housing Policy Options

Theme: Homes
Policy Name: Affordable Housing
Policy Number: HO3(S)
Options Y/N: Y

Summary of responses (39 received)

In general, respondents were supportive of the policy approach. A range of views were expressed relating to the flexibility of applying the policy dependent on viability and market conditions, with many supporting the options to allow developments to be viability tested on site specific basis against affordable housing costs to ensure development comes forward where proven unviable otherwise. In criticising this approach, a number of respondents commented that this flexible policy approach fails to deliver needed affordable housing.

Outside the scope of the policy, others linked the importance of delivering good housing standards and energy efficiency alongside affordable housing to tackle social inequalities, suggested there is a need to build more flats to free up the availability of family housing from single occupancy and multiple occupancy households, and for the Council to have greater control over the affordability of homes in the housing market itself.

Respondents have raised criticism that no Local Plan Viability Assessment has been carried out at this stage of the plan making process and, therefore, the suggested affordable housings thresholds and tenure splits set out in the policy and preferred options have not been properly justified. Furthermore, the policy is not based on robust evidence of housing need for affordable homes given the out-of-date baseline data relied upon. Specialist housing providers for elderly persons have stated that their developments should be exempt from affordable housing provision.

Respondents considered there should be a review whether flexibility could be built into the policy to allow for different proportions of each tenure to be delivered in response to local need, affordability, and viability. Furthermore, the supporting text should more explicitly support the full range of housing and supported accommodation types to meet needs, including bungalows. It was suggested that section 2b of the policy should specify what constraints on the development of the site imposed by other planning objectives will be considered by the policy. As an alternative to the policy threshold, it was suggested to set a variable affordable housing target by defined location across the city supported by the Local Plan Viability Assessment as well as a minimum requirement, not subject to viability assessment, set with clear exclusion zones, potentially based on City Centre Quarters or specific allocations where the minimum requirement would not be applicable.

It has been questioned whether ‘First Homes’ will successfully address affordable housing need given that the discounted house prices still prove to be unaffordable for most and therefore does not deliver mixed and balanced communities, whilst ‘First Homes’ are not a mandatory requirement by the government so this should be an optional policy approach for local authorities. Furthermore, it is suggested that reductions in the level of ‘First Homes’ required in the policy, or across individual sites, would protect the overall level of affordable housing delivered on sites, which would otherwise be lost to market sale following the marketing period, further reducing the opportunities for sustainably located affordable housing within the city. Concerns are raised that ‘Build to Rent’ requirement to provide 35% affordable housing is non-compliant with the National Planning Practice Guidance, as this states that ‘20% is generally a suitable benchmark for the level of affordable private rent homes to be provided (and maintained in perpetuity) in any build to rent scheme’.

Conversion to Residential Use Policy Options

Theme: Homes
Policy Name: Conversion to Residential Use
Policy Number: HO4(S)
Options Y/N: Y

Summary of responses (23 received)

On the whole, the consultation responses supported the objectives of the policy in recognising the benefit of delivering a range of housing by repurposing under-utilised non- residential premises within sustainable transport locations, and the balancing act of sensitively locating residential uses in busy commercial areas. Caution was aired about ensuring safeguards can be put in place in locating residential uses near commercial uses, including the Port.

There are conflicting views in how much parking should be provided for future residents, with some supporting car-free development near transport hubs whilst others consider that provision of car parking is essential for work and life.

Views were expressed about permitted development rights undermining the planning system by relaxing the protection of shopping areas and creating poor quality housing. Furthermore, the Council should explore using Article 4 powers to limit the impact of permitted development rights.

It was suggested that the policy should focus on maintaining ground floor commercial uses and residential uses above as these uses have complimentary benefits for each other.

Statutory bodies have expressed the importance of linking up other relevant policy areas including flood risk and water supply/drainage in planning new conversions.

Housing Retention Policy Options

Theme: Homes
Policy Name: Housing Retention
Policy Number: HO5
Options Y/N: Y

Summary of responses (18 received)

Whilst the policy approach was supported, a number of issues and themes surrounding the loss of family and availability of local housing came out of the consultation. There was support for encouraging greater densities on sites where housing is to be replaced, with encouragement to extend buildings upwards to add more floors. Some of the concerns raised fall outside the scope of the policy such as preventing ownership of second homes and limiting the residential status of homeowners to the city, changing the planning rules for Airbnb and short term lettings, and limiting Houses in Multiple Occupation. Others questioned the mechanism for ensuring the delivery of replacement homes within a development, and allowing larger homes will proliferate more Houses in Multiple Occupation and flat shares.

Houses in Multiple Occupation (HMOs) Policy Options

Theme: Homes
Policy Name: Houses in Multiple Occupation (HMOs)
Policy Number: HO6
Options Y/N: Y

Summary of responses (34 received)

The main themes voiced in the consultation responses ranged from meeting housing need with issues surrounding lack of affordability and shortage of housing suitable for lower income persons leading to greater pressure for HMO housing in the city, redressing and restoring the erosion of unhealthy mix and balance of communities in the interests of improving the living conditions of longer term family households affected by high concentrations of transient people and more action needed to reverse the damage to neighbourhoods from the negative affect of long term high concentrations of HMOs, improving standard of housing and living conditions for existing and future HMOs, potential continuation of same community and housing imbalances allowing HMO stock to be converted by landlords to small flats as the HMO market changes, the effectiveness of using joined up enforcement powers from other Council teams to tackle common social and environmental issues associated with HMOs including changing rules for issuing HMO licenses to act with planning enforcement cases and tougher penalties for landlords, and fostering beter relationship between long term residents and short let landlords. It was recognised that HMOs offer important source and choice of short term housing for lower income persons including university students.

In terms of the evidence base informing the policy, there was concerns this must be representative of those who use HMOs. There was agreement with the Council that policy intervention was still necessary to control the negative impacts associated with the proliferation of HMOs over the city and especially those neighbourhoods where the healthy mix and balance has already been upset. To accurately establish the overall number of HMO and short terms lets, the Council must conduct an up-to-date assessment of the total number of HMOs in the City across the total housing stock to feed into the Local Plan before it is published.

The proposed methodology to control the future increase of large HMOs received comments with regards to effectiveness of geographic targeting at neighbourhood level and capability to prevent further erosion of unhealthy mixed and balance communities, especially associated with wider impacts from significantly increased adult population putting pressure on local services and infrastructure.

There was a mixed response to Options 1a) and b), with both support for putting the threshold policy into the Local Plan and others preferring to use the flexible SPD route in recognising its agility to take account changes in circumstances. Comments were received calling for the geographic targeting of the threshold for new HMOs to cover a wider neighbourhood area or up to ward level as the 40m radius was not effective to achieve the policy objective of maintaining a healthy mix and balance of households in neighbourhoods, especially those already affected by high concentrations of HMOs.

On the whole, introducing a new strategy to control overconcentration of larger HMOs was welcomed under Option 2, with others who thought the that policy would be a ‘back door’ to increasing concentrations of HMOs so they preferred that no more large HMOs were created or occupancy increase in existing large HMOs. Concerns were raised that the high percentage of the tipping point set for the secondary threshold would not achieve the policy objective of maintaining a healthy mix and balance of households in neighbourhoods due to the significant increase of the HMO concentration, especially those neighbourhoods already affected by high concentrations of HMOs. Suggestions were made to decrease the ‘tipping point’ threshold for new large HMOs to lessen the impact of increasing HMO concentrations, and to omit the use of the 60% upper limit for the secondary threshold to beter protect communities from increasing HMO concentrations in neighbourhoods already affected by high concentrations. Others have reserved their comments on the policy about the secondary threshold until they know more detail of its methodology.

There was a mixed response on Option 3 to geographically target the assessment of the secondary threshold for large HMOs. As an alternative to the current 40m radius approach at a local neighbourhood level, there is a preference that the policy should target the assessment at a broader geographic level such as Wards in order to limit wider concentration and prevent further dilution of the family housing stock across the city. Others have reserved their comments on the policy about the secondary threshold until they know more detail of its methodology.

There was a mixed response to the Option 4. Concerns were raised that extending HMOs will exacerbate the unhealthy imbalance in neighbourhoods with high concentrations of HMOs above the 10% threshold. Otherwise, the view is taken that a case-by-case assessment in isolation to the threshold policy will allow the impacts of HMO extensions to be considered in line with the Council’s adopted standards and policies.

A range of other policy text suggestions have been raised in the consultation responses. These mainly suggest the Council consider other HMO policy interventions which would go beyond the scope of planning legislation or land use maters. Other issues raised such as standards on minimum size of living spaces or communal facilities for HMO residents are already covered by the Council’s HMO licensing scheme. In response to further concerns about the implementation of the HMO policy, the wording does not explicitly state a ‘presumption in favour’ of permitting HMOs, however, the NPPF (2023) paragraph 11 setting out the higher level of national policy requires all planning applications decided by the Council to ‘apply a presumption in favour of sustainable development’, and this means for decision making ‘approving development proposals that accord with an up-to-date development plan without delay’.

Purpose Built Student Accommodation Policy Options

Theme: Homes
Policy Name: Purpose Built Student Accommodation
Policy Number: HO7
Options Y/N: Y

Summary of responses (32 received)

Most respondents supported student housing need within the city, however, there were mixed views over the appropriate location for future student housing sites. Representatives of the student housing providers and the University bodies were unsupportive of a City Centre focus as this would locate student housing further away from University campuses and, therefore, increase travel time for students, and students will lose the opportunity to live near existing ‘student villages’ in north of the city with access to a range of affordable options and accommodation. Respondents living in suburban areas near the university campuses raised concerns that allowing more student housing to locate outside the City Centre will lead to further community imbalances and negative amenity impacts within nearby suburban neighbourhoods. Others considered that locating student housing in the City Centre will create its own community imbalances whilst this makes housing unaffordable for non-student residents due to an overconcentration of sites.

Student housing providers are concerned that there is an insufficient evidence base to include and clarify the quantum of existing and required student accommodation over the plan period and, therefore, the policy will fail the test of soundness without an objectively assessed needs for student housing. So that student housing market providers are clear where they can invest, it was suggested that supply and demand of student accommodation is addressed in the City Vision with allocation of student housing sites alongside the supply and demand for general market housing.

The University of Southampton considers that the assessment of student housing need should change to take into account how academic floorspace is specifically used or created as student population is not directly linked. An established evidence baseline can demonstrate whether the floorspace proposed is for accommodating existing or additional student numbers and the University are able to therefore provide accommodation as appropriate and required to do so. The University expressed interest in exploring options for student housing being part of mixed-use developments and where there may be appropriate future synergies across Southampton. Furthermore, it was suggested that the policy reiterates the need to support necessary facilities near to student accommodation, such as small convenience stores and health and wellbeing facilities.

Respondents were mainly supportive of the policy approach to encourage student housing to be short-term tourist accommodation during holiday periods, this being subject to placing no specific burdens on building design. Student housing providers were unsupportive of the policy approach to make student housing adaptive for future residential use given the conflicting design approach in layout and residential standards including amenity space requirements, whilst they consider there is a significant need for student housing well beyond the plan period so it is unlikely the accommodation will not be required for students and made available for general housing. Conversely, the benefit of student housing is to free up housing stock by reduction in need for student Houses in Multiple Occupation in suburban areas. Concerns were also raised that the non-specific reference to a ‘high-quality living environment’ in the policy is too vague to be effective. As an alternative to specifying precisely the size of rooms/communal areas, it was suggested using the phrase “appropriately-sized rooms” as it allows the decision-maker to draw on precedent developments with a view to understanding what the market expectation is for room sizes.

In a wider context of the student housing market, respondents commented on the importance of building more student housing to make up the shortfall of accommodation to free up family housing in suburban areas being used as student house shares, however, further student housing built will remain empty as the accommodation is unaffordable so students will tend to live in cheaper house shares. Criticism was raised of low standards created due to over-reliance on offshore real estate providers rather than university led and maintained student housing which can be subsidised for students. Other suggestions made such as controlling rent costs for students fall outside the scope of the planning system.

Other concerns associated with student housing were raised around negative impacts to amenity, safety and character for local communities. These include poorly designed utilitarian buildings, parking pressure for nearby residential streets due to a lack of off-road parking for students, and poor management of noise disturbance and anti-social behaviour issues including late-night when students return home from nights out through residential areas. It was suggested that permissions for student housing should specify a minimum number of management and security staff to minimise anti-social behaviour issues

Gypsy and Traveller Accommodation and Accommodation for Travelling Showpeople Policy Options

Theme: Homes
Policy Name: Gypsy and Traveller Accommodation and Accommodation for Travelling Showpeople
Policy Number: HO8
Options Y/N: Y

Summary of responses (10 received)

There was general support for the policy approach, with other comments suggesting that transient facilities should be further considered to better manage the potential for unauthorised encampments, including using permanent sites as a transit site to direct groups in need of medical treatment.

Summary of responses (88 received)

Theme: Homes
Policy Name: Houseboats and Moorings
Policy Number: HO9
Options Y/N: N

There were no objections to the policy, but some felt the need for more detail around issues of foul water and waste and design and structure of houseboats. Overall, the policy was considered a positive and could add to regeneration of parts of the city.