Comment

Representation ID: 25019

Received: 30/10/2017

Respondent: Home Builders Federation Ltd (HBF)

Whilst we welcome the collaboration between Ipswich and Suffolk Coastal, the level of housing needs identified through the SHMA is insufficient and should have taken more account of market signals. Canterbury has similar market signals to the Ipswich HMA and the Inspector considered a 20% uplift to be appropriate there. "Planning for the right homes in the right places" now provides a clearer direction as to how market signals should be taken into account. For Ipswich HMA it suggests that insufficient weight has been given to market signals, and the proposed uplifts should be increased where affordability is worst.

Comment

Representation ID: 25024

Received: 30/10/2017

Respondent: Home Builders Federation Ltd (HBF)

The eventual level of housing need to be considered by the authorities in the HMA will also dictate the development strategy adopted. As a minimum, the Councils should prepare strategies on the basis of 'Scenario B'. This is a positive approach towards housing delivery and economic growth that could be supported by the HBF. The Councils should also consider 'Scenario C'. In taking forward such an approach, with large scale strategic allocations, Councils will need to be clear about the timescales required to deliver this level of growth, and support smaller sites for quicker delivery within the first ten years.

Comment

Representation ID: 25032

Received: 30/10/2017

Respondent: Home Builders Federation Ltd (HBF)

Consider a combination of the options. Whilst some higher density development and changes of use must be considered, there will be a need for some of Ipswich's needs to be accommodated elsewhere. IBC should be clear how many homes will be provided elsewhere and ensure that the other authorities allocate sufficient sites to meet those unmet needs. SCDC options will need to take account of the need to meet some of Ipswich's unmet needs. Some could be near to Ipswich but the Council should also consider increasing housing delivery at other towns and villages. SCDC could consider an approach that draws on aspects of each option that will support the necessary growth to meet the needs of the area. The plan must be clear how needs are being met and that there are shared policies, contingency measures and monitoring to facilitate this joint working.

Comment

Representation ID: 25033

Received: 30/10/2017

Respondent: Home Builders Federation Ltd (HBF)

In establishing the appropriate housing mix and level of affordable housing provision, viability and housing needs are a primary concern. We are concerned about question 44: it is impossible to consider mix without viability and the Council can only make a decision based on the evidence it collects. Policies on housing mix, affordability and density must provide certainty about expectations and also a degree of flexibility. When testing plan viability, it is not possible to test all development scenarios. There must be flexibility within the policy to recognise that some development will be made unviable by the Local Plan polices.