Policy HS1 - Housing Mix, Accessibility and Environmental Standard

Justification:

Housing development (new build and conversions or alterations of existing stock) should support the evolution of a balanced community and a Sustainable Linked Neighbourhood, Plymouth and South West Devon Joint Local Plan Policy SPT2.

The Hoe Neighbourhood Area is a unique locale. It is both a residential area for permanent residents and a tourism destination with associated holiday and hospitality accommodation for temporary and short-term visitors. The Hoe Neighbourhood Area is a neighbourhood within a city. Housing issues in the Hoe Neighbourhood Area are therefore inextricably linked to factors in Plymouth's wider housing and hospitality markets.

The Housing Needs Assessment prepared by AECOM for the Hoe area identified the proportion of housing tenures as 53.3% private rental, 29.6% private ownership, 15.8% social rental, and 0.2% shared ownership. Rates of private homeownership and social rental were lower than district and national averages. The Housing Needs Assessment also found that affordability is a challenge in the Hoe Neighbourhood Area, with entry-level house prices unaffordable to households on average incomes, and it recommended that affordable rental housing be prioritised.

Private rental tenure also includes Houses in Multiple Occupation, purpose-built student accommodation, and student-only dwellings (category N Council Tax exempt), of which there were 101 dwellings in the Hoe Neighbourhood Area in 2021. An Article 4 Direction incorporating the Hoe area came into force in September 2012 to control the number of properties classed as Houses in Multiple Occupation (HMO). In 2019, through the Plymouth and South West Devon Joint Local Plan, Plymouth City Council sought to further restrict the number of Houses in Multiple Occupation within the designated Article 4 area by setting a threshold to ensure the proportion of dwelling units in multiple occupation does not exceed 10% of the total dwelling stock within 100 meters of an application site. Plymouth and South West Devon Joint Local Plan Policy DEV11 also states that Houses in Multiple Occupation within the Article 4 area will be resisted where they sandwich non-HMO residential properties. In the interests of sustaining a balanced community, the Hoe Neighbourhood Forum supports the Article 4 Direction and will support its renewal if reviewed in future.

The dominance of private rental tenure is partially explained by the urban location and partly by the growing market in recent years for short-term holiday accommodation and second home ownership. A report prepared by Colliers (2019) shows that Plymouth experienced significant growth in the AirBnB market from 2014 onwards. Between 2010 and 2018 the supply grew at an annual growth rate of 74%, and there were 946 active rentals in 2018, with ongoing growth anticipated. Much of Plymouth's AirBnB supply was found to be within or close to the Hoe Neighbourhood Area.

At the time of writing, levels of short-term holiday lets and second home accommodation have not yet reached the critical levels experienced by other coastal towns. However, the Hoe Neighbourhood Forum is conscious that the issue should be monitored over the life of the Hoe Neighbourhood Development Plan to ensure that the social sustainability of the Hoe Neighbourhood Area is not endangered. Community Actions and policy review are proposed to monitor the evolving picture.

Local hospitality businesses have also noted that AirBnB accommodation is not subject to the same regulation as traditional B&Bs and hotel rooms. The Hoe Neighbourhood Forum is committed to working with local businesses through Community Aspirations to support the introduction of a level regulatory playing field for all hospitality providers.

In terms of existing stock of housing, the Housing Needs Assessment data shows that the Hoe Neighbourhood Area has a large percentage of flats, more than double the numbers in Plymouth and England. Many of the large terraced houses in the Neighbourhood Plan Area have been converted into flats, and 87.7% of all dwellings in the area have just one or two bedrooms. The percentage of both semi-detached and terraced houses is therefore much lower than comparable areas. The Housing Needs Assessment concludes that this data, compounded with information regarding an aging population, predicts the need for more three-bedroom housing and less emphasis on one- and two-bedroom homes.

The Housing Needs Assessment also found that the Hoe Neighbourhood Area has a significantly higher percentage of people aged 25-44 than both wider geographies and a lower percentage of people aged 0-15. While the Hoe Neighbourhood Area's proportion of those aged 65-84 and 85 and over is only marginally greater than wider Plymouth's, there is a large cohort of people in the age group likely to enter retirement age over the Plan period.

The construction of an extra care facility providing 80 apartments started in 2018 in Millbay, just outside of the Hoe Neighbourhood Area, but at the time of writing, this project had stalled. Even if completed, it is likely to serve a wider catchment area for the city as a whole. The Housing Needs Assessment therefore recommended that the needs of an aging population should be considered. The Hoe Neighbourhood Forum believe that this growing need can be addressed through developments and existing buildings that support multi-generational living alongside extra care and supported living facilities. The Hoe has a legacy of large terraced dwellings that, when arranged as family houses, can accommodate current trends for young people staying at home longer and older relatives being supported by their extended families.

Although Policy HS1 does not exceed the Plymouth and South West Devon Local Plan requirement, it adds detail in accordance with the Housing Needs Assessment tenure and affordability evidence. Within the Hoe Neighbourhood Area, Policy HS1 aims to achieve:

• A balanced age demographic with a mix of all ages and household types, including families and children, older people, students and sharers, couples and singles, and visitors
• A balance of tenures: private and affordable, rental and owner-occupied, shared housing, student accommodation, older-persons housing, and holiday accommodation
• A range of different size homes, from one-bedroom flats to larger family houses, including sufficient options so people can live in the area at all life stages if they wish
• A level playing field for all hospitality providers, whether regulated or unregulated (e.g., for both short-term holiday lets and traditional hoteliers).

Intent:

Policy HS1 requires that local housing needs are addressed by future residential development in reference to tenure, type, size, and accessibility. The Housing Needs Assessment commisioned by the Forum provides strong evidence for this policy.

Key Evidence Sources:

• The Hoe Housing Needs Assessment
• Colliers International Hotel and Other Accommodation Supply & Demand Study
• Appendix 2: Hoe Neighbourhood Forum Local Heritage List
• Plymouth and South West Devon Joint Local Plan Policies DEV20 and DEV21
• Plymouth and South West Devon Joint Local Plan Supplementary Planning Document (pages 38 to 53}
• Plymouth and South West Devon Strategic Housing Market Assessment Part 1
• Plymouth and South West Devon Strategic Housing Market Assessment Part 2
• Plymouth and South West Devon Joint Local Plan - Market Signals Update
• The Housing Needs of Physically Disabled People in Plymouth