ipswich.gov.uk

Policy CS12 Affordable Housing

Showing comments and forms 1 to 8 of 8

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26303

Received: 02/03/2020

Respondent: Home Builders Federation Ltd (HBF)

Agent: Home Builders Federation Ltd (HBF)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

CS12 is unsound and not consistent with national policy. The phrase 'at least 15%' does not provide the necessary clarity for applicants and decision makers and should be removed.

Change suggested by respondent:

The phrase 'at least' should be removed from the policy.

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26350

Received: 02/03/2020

Respondent: Home Builders Federation Ltd (HBF)

Agent: Home Builders Federation Ltd (HBF)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

CS12 is unsound and not consistent with national policy. The viability assessment may have underestimated the level of abnormal costs that occur when developing brownfield sites. Given that the Viability Assessment shows that development of brownfield land is marginal the Council may need to consider a lower affordable housing requirement on such sites, or amend other policy requirements in the plan.

Change suggested by respondent:

Consider a lower affordable housing requirement on brownfield sites or amend other policy requirements in the plan.

Support

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26358

Received: 02/03/2020

Respondent: Rentplus UK Ltd

Agent: Rentplus UK Ltd

Representation Summary:

Pleased to see that, as was previously set out at the Preferred Options stage, policies CS8 and CS12 and their supporting text refer to the up-to-date definitions of affordable housing, as set out in Annex 2 of the Framework. This ensures the Plan is consistent with national policy and is therefore sound in this regard.

Change suggested by respondent:

N/A

Attachments:

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26368

Received: 02/03/2020

Respondent: Rentplus UK Ltd

Agent: Rentplus UK Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The SHMA 2019 does not refer to full range of tenures set out in Annex 2. Continue to recommend that a focused update to the SHMA is prepared in order to inform policy and planning decisions. Updates should assess needs for products such as affordable rent-to-buy. To ensure that the plan is effective, supporting text to CS12 should contain new paragraph after paragraph 8.153, committing to keeping the SHMA up to date; this would also help in the application of CS8.

Change suggested by respondent:

Add new paragraph after paragraph 8.153. Potential wording as follows: "In order to inform negotiation and decision taking and best meet the affordable housing needs of the Borough, the Council shall keep the Strategic Housing Market Assessment regularly updated. Any updates to the SHMA will contain up to date assessments of need for the full range of affordable housing tenures as defined in the National Planning Policy Framework. The Council will also consider other evidence of local needs where supported by the Council.

Attachments:

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26417

Received: 02/03/2020

Respondent: Gladman Developments

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The approach is not effective given the level of affordable housing needs within Ipswich will not be met over the plan period. The Council needs to address this situation if it is to meet the housing market areas full housing needs. NPPF p60 is clear that in addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for. The Council must allocate additional housing land to make a meaningful contribution to housing land supply and boost affordable housing delivery.

Change suggested by respondent:

This issue can be addressed through the allocation of sites within the vicinity of Ipswich within neighbouring districts such as the Orwell Green Garden Village.

Attachments:

Support

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26471

Received: 02/03/2020

Respondent: Associated British Ports

Agent: Associated British Ports

Representation Summary:

ABP notes the requirement for major new development (10+ dwellings) to provide 15% affordable housing and welcomes the flexibility within the wording of Policy CS12 both in respect of the proportion of affordable housing and tenure mix where development viability justifies it.

Change suggested by respondent:

N/A

Attachments:

Support

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26558

Received: 02/03/2020

Respondent: Cardinal Lofts (Mill) Ltd

Agent: Cardinal Lofts (Mill) Ltd

Representation Summary:

The Company welcomes the acknowledgement that, in some cases, such as due to the high cost of development and ‘abnormals’ relating to a site, it may not always be viable to provide full affordable housing provision. It is understood that the Council will shortly be progressing with its proposed Community Infrastructure Levy. This will place additional financial burdens upon development and, in some circumstances, reduce the amount of affordable housing that can be provided (on viability grounds). Summary: General support.

Change suggested by respondent:

N/A

Attachments:

Object

Ipswich Borough Council Local Plan Core Strategy and Policies Development Plan Document Review - Final Draft

Representation ID: 26585

Received: 02/03/2020

Respondent: Bloor Homes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The plan allocates a total of 1,647 affordable dwellings
(assuming 30% IGS and ISPA4 and 15% on all other sites including windfall). In all likelihood this is overly optimistic given that most windfall sites are likely to be small and fall below the threshold set in Policy CS12. Based on the 239 dwellings per year in the SHMA, this would result in 38% of the affordable need. This is insufficient. Contrary to NPPF 20 and PPG. The Site can come forward to provide market and affordable housing to assist with meeting the need, working with East Suffolk.

Change suggested by respondent:

Allocate the Site at Humber Doucy Lane to help address the affordable housing shortage.

Attachments: