We strongly support the need for more affordable housing in the district and applaud the stance of this SPD. We have the following comments:
3. Affordable Housing Policies
3.1 Threshold for providing affordable housing
We feel there is an opportunity for the council to use a staggered approach to thresholds for providing affordable housing and target percentage of affordable dwellings in order to maximise the number of affordable homes delivered. Further for sites that fall just below the existing threshold this technique is more compelling than a land capacity study.
For urban areas:
No. of Homes at New
Development
0-4
5-9
10-14
15+
% of Affordable
Homes Required nil
15%
25%
35%
For both rural and urban areas we feel the percentage of affordable dwellings delivered should be 35% inline with the Draft Regional Spatial Strategy (RSS).
Net Increase
We feel the threshold should be measured against the gross number of dwellings not the net increase. This is inline with other Homes West councils.
3.4 Rural Exception Sites
We believe that consultation with local stakeholders is key at any development, especially rural schemes. However there may be certain circumstances where Parish Councils or
Meetings object to a scheme on a basis that holds no material planning consideration and as such we feel that they should be considered as important stakeholders rather than absolute decision makers.
Scale of Development
We feel that impose a standard number of dwellings (i.e. typically no more than 5) is restrictive and will set a precedent that is not appropriate at larger rural settlements. To leave the state as ‘small in scale’ is enough and will allow the proper stakeholders to come to an informed decision as each rural exception site is unique.
8. Design Issues
We approve of the council’s approach to ‘pepperpotting’; however we feel that to restrict clusters to 6 affordable dwellings in all situations is restrictive. We suggest that the wording state
‘it is the council’s aim to have clusters of 6’. For management purposes we feel distribution should state that ‘where possible blocks of flats with a common entrance should be of one tenure type’.
Appendix 2
There is a typing error in the first paragraph of page 6. It states “I% of the unsold equity” and should read “1% of the unsold equity”.

Appendix 4, Development Standards
Code for Sustainable Homes (CSH)
The draft RSS, in Appendix C (vii): Schedule of Carbon Reduction Requirements, is proposing that all developments of 10 or more dwellings should meet CSH Level 4 in the 2008-2010 period. We feel this SPD should aim for the same.
Lifetime Homes
This should refer to the Joseph Rowntree Lifetime Homes Standards for harmony.
Unit Sizes
We do not feel that delivery of 1 bedroom 1 person flats at 30m² and 3 bedroom 4 person houses at 80m² constitutes sustainable development and as such they should be removed.
Fixtures and Fittings
We feel that Appendix 4, Development Standards should include a standard Fixtures and
Fittings List for all affordable dwellings. A sample is included here:
 All rear (and front where appropriate) gardens to be turfed and have 1.8m high close boarded fencing to boundaries
 Provide external lights to the rear of the property
 All properties to have vinyl/ tiles in kitchens and bathrooms
 Ceiling height tiling to three sides of bath to be provided
 Toilet roll and towel holder to be provided
 Provide and wall mounted shower (either electric or value and kit)
 Provide steel baths – for rented units
 Provided gas and electric points to cooker space (where gas is available) for rented units only
 Provide shower curtain and rail
 Provide a door bell and door number to front door
 Provide door stops to all internal doors
 Provide softwood curtain battens to each window
 Digital TV (Sky+ or equivalent) to be installed
Appendix 6, Affordability criteria for intermediate housing
We note the position with regard to the measure of affordability against market rents in the private sector.
The differentiation of a minimum of 20% below a market rent for an intermediate sale product we believe is too low as it potentially means when all housing costs are taken in to account, the % of equity purchased could be a small share which may mean that the purchaser is vulnerable to changes in interest rates and may struggle to find a value for money product from a lender.
We welcome the Council's approach on large strategic sites and support the principle that the intermediate housing should be available to a range of people in housing need. This ensures there is a mix of incomes and households on the site and that the community is sustainable. This can be achieved by offering a range of equity purchase opportunities.
As affordability is linked to market rents we feel that, to promote transparency Appendix 6 should include wording to the effect: “Market rents will be set by an independent RICS surveyor”
SOMER HOUSING GROUP