ipswich.gov.uk
CS12: Affordable Housing
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5144
Received: 04/03/2015
Respondent: The Ipswich Society
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Support but require changes. We have been unhappy that so many developers have reduced their affordable housing commitment, largely on the grounds of non-viability; we support strongly the independent review system. We feel that the wording here needs to be stronger to ensure developers compliance. We should like to see more transparency over such negotiations.
We have been unhappy that so many developers have reduced their affordable housing commitment, largely on the grounds of non-viability; we support strongly the independent review system. We feel that the wording here needs to be stronger to ensure developers compliance. We should like to see more transparency over such negotiations.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5328
Received: 05/03/2015
Respondent: Crest Strategic Projects
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Policy CS12 states that new developments at IGS will be required to provide for at least 35% on-site affordable housing. We understand that a viability appraisal has been undertaken to inform the delivery of the IGS, but question whether the Council seeking 35% affordable housing is robust and justified, especially when the affordable housing requirement is significantly lower at 15% elsewhere in the Borough. We seek further information on IBC viability assessment and reserve the right to comment further once this has been made available. As currently drafted, CS12 is not considered to be 'justified'.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5370
Received: 05/03/2015
Respondent: Mersea Homes Limited
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The requirement for 'at least' 35% affordable housing provision in the IGS is not justified by the evidence, nor does it contribute to an effective policy. CS12 has reduced the affordable housing target on sites other than IGS. We don't believe there is evidence to support this policy position; rather evidence indicates that the target for the IGS should also be reduced. The NPPF makes it clear (paragraphs 173-177) that local plan policy should not place an undue burden on development. Maintaining a 35% affordable housing target for the IGS will render it unviable, and will stall its delivery.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5400
Received: 03/03/2015
Respondent: Northern Fringe Protection Group
Number of people: 323
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The Ipswich Viability Report showed that 'the indicative scheme average equated to 31.6% affordable housing provision by number and 28.4% by floor space, alongside the full provision of infrastructure.' It is therefore unsound to set a target of 35%. Since the Garden suburb infrastructure costs were developed other costs have arisen due to wastewater infrastructure.
See attachment
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5417
Received: 05/03/2015
Respondent: Mr Arwel Owen
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The requirement for at least 35% affordable housing provision in the IGS is not justified by the evidence, nor does it contribute to an effective policy. This level of affordable housing provision is not viable in Ipswich. The NPPF makes it clear (paragraphs 173-177) that local plan policy should not place an undue burden on development and that the implications of policy should be tested during plan making. The PBA Viability Testing for the Ipswich Development Plan provides no scenario which models the IGS. On a practical level, a floorspace measure is incapable of being applied to outline planning applications.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5548
Received: 02/03/2015
Respondent: Home Builders Federation Ltd (HBF)
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy CS12: Affordable housing
The affordable housing policy is potentially unsound because the rates proposed may render the plan undeliverable and therefore the policy may prove ineffective.
It is also unclear how a policy requirement of 35% and 15% affordable housing by total floor space would work in practice. It is unclear how this would translate into a dwelling requirement.
See attached
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5577
Received: 25/02/2015
Respondent: Ipswich Conservative Group
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The percentage of affordable housing is too high and unrealistic. It affects the viability of the Northern Fringe site (Ipswich Garden Suburb) and adds to the financial burden on first time buyers.
The percentage of affordable housing is too high and unrealistic. It affects the viability of the Northern Fringe site (Ipswich Garden Suburb) and adds to the financial burden on first time buyers.
The existing Labour Administration has long been unreasonable in its demands for affordable housing. It has failed to realise that development is often put at risk by it's over the top demands for 35% affordable housing. The outcome is that either development does not take place at all or the Council backs down from its 35% figure as it has at the following sites:
* Colchester Road Fire Station
* Europa Way
* St Clement's Hospital
* "Wine Rack"
It is pleasing that there is an element of progress in the draft Strategy in that it moves from at least 35% affordable housing on sites of 15 or more dwellings and at least 20% on sites of 10 - 14 dwellings to at least 35% at the Ipswich Garden Suburb and at least 15% on sites of 15 or more dwellings in the rest of the Borough. This is a move in the right direction but, on the basis of recent experience, the 35% at the Garden Suburb is still unlikely to be viable, particularly as developers will also be faced with large infrastructure spending. In this connection, it is significant that Colchester Borough Council has adopted a policy of 20% affordable housing. The bottom line is that if the Council does not agree on a reasonable percentage of affordable housing, developments will not be viable and the very people for whom the Council wishes to provide housing will find that they remain on the Council's housing list.
The Council's percentage of affordable housing should not exceed 20%.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 5697
Received: 05/03/2015
Respondent: Save Our Country Spaces
Legally compliant? No
Sound? No
Duty to co-operate? No
SOCS endorse the Northern Fringe Protections Group's points. The Ipswich Viability Report showed that 'the indicative scheme average equated to 31.6% affordable housing provision by number and 28.4% by floor space, alongside the full provision of infrastructure.' It is therefore unsound to set a target of 35%. Since the Garden suburb infrastructure costs were developed other costs have arisen due to wastewater infrastructure.
See attached.
Object
Proposed Submission Core Strategy and Policies Development Plan Document Review
Representation ID: 24216
Received: 05/03/2015
Respondent: EDF Energy Plc
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Pleased to see the affordable housing target has been lowered and that a lower amount may be acceptable subject to viability testing. However, the policy does not provide for off-site provision or commuted sums, it would be helpful to provide these alternative arrangements.
See attachment