Object

Representation ID: 25786

Received: 13/03/2019

Respondent: Home Builders Federation Ltd (HBF)

When the NPPF was first published Councils were advised by the Planning Inspectorate to include some 'model' wording in local plans with regards to the presumption in favour of sustainable development. However, it is our understanding that this advice has since been rescinded and that such statements are no longer a requirement of local plans. Given this position and the fact that S1 repeats national policy it should be deleted.

Object

Representation ID: 25787

Received: 13/03/2019

Respondent: Home Builders Federation Ltd (HBF)

We would agree with the Council's assessment of housing need of 479 dwellings per annum. However, this is the starting point for assessing needs and national policy/ guidance expect Councils to consider whether other factors will necessitate a higher requirement. Given that the level of affordable housing needs within Ipswich that will not be met the Council need to consider whether additional sites could be allocated that would make a further contribution to meeting these needs. It will also be important to raise this with neighbouring authorities to consider whether it is possible to allocate additional sites near Ipswich.

Object

Representation ID: 25789

Received: 13/03/2019

Respondent: Home Builders Federation Ltd (HBF)

The Council has adopted a stepped housing trajectory. However, the lack of a five-year housing land supply (on adoption) is not a relevant justification. Paragraph 3-034 of PPG indicates two circumstances where a stepped trajectory may be appropriate. Whilst it appears the Council can satisfy one of these tests (strategic sites and late-delivery) we suggest that the step as set out does not reflect expected delivery. We recommend that whilst a requirement in the first two years of 350 dpa is acceptable this should increase to 400 homes between 2020/21 and 2022/23. At 2023/24 this should then increase to 550.

Object

Representation ID: 25790

Received: 13/03/2019

Respondent: Home Builders Federation Ltd (HBF)

Whilst Strategic Housing Market Assessments (SHMA) can provide a broad snapshot in time of what is needed across an LPA or HMA they do not provide a definitive picture as to the demand for different types of homes in specific locations. It should be left for developers to supply the homes they consider are necessary to meet demand.

Therefore, suggest that the policy requires applications for housing development to have regard to the evidence on housing mix but that the final mix is left to agreement between the applicant and developer on a site by site basis to establish flexibility.

Object

Representation ID: 25792

Received: 13/03/2019

Respondent: Home Builders Federation Ltd (HBF)

It is important that the Council revisit the self-build evidence to test whether those individuals currently on the list are still interested in a plot on which to build their own home. This has been the case at the EIP for both the Hart and Runnymede Local Plans.

This is to test whether those currently on the list are still interested in a plot. This has been the case at the EIP for both the Hart and Runnymede Local Plans. Our concern is that Council are over-estimating the number of households wanting to build and this will leave plots vacant.

Object

Representation ID: 25793

Received: 13/03/2019

Respondent: Home Builders Federation Ltd (HBF)

We could not find any evidence to support the level of private outdoor space being proposed in this policy. The size of any private outdoor space should be left to the discretion of the developer who are aware of the demands of their customers. The approach taken by the Council could potentially reduce the amount of land available for housing in what is a very constrained borough. Therefore, we would suggest that whilst we accept that some private outdoor amenity space will be required the Council should not set out minimum specifications for such space.