Strategaeth a Ffefrir

Gwrthwynebu

ID sylw: 28001

Derbyniwyd: 19/09/2019

Ymatebydd: Home Builders Federation Ltd

Although the management of open space in some cases may need to be carried out by an organisation other than the Council this should not be the default position but instead an option along with the ability for the Council to adopt the facility.

Not accepted: Council budgets mean that CCBC is unable to maintain open space sites in perpetuity.

Gwrthwynebu

ID sylw: 28002

Derbyniwyd: 19/09/2019

Ymatebydd: Home Builders Federation Ltd

Whilst we have no objection to this in principle in relation to affordable housing, we do object to any level of control which the Council intend to impose through policy on the private homes for sale element of any new development.

Accepted in part: Subject to PPW paragraph 4.2.5 and the LHMA.

Sylw

ID sylw: 28003

Derbyniwyd: 19/09/2019

Ymatebydd: Home Builders Federation Ltd

BP01: Growth Level Options Report
The Development Plans Manual states "The critical point is ensuring that both economic and housing growth are broadly aligned, accepting that there is no direct mathematical relationship. Both forecasts and the scale of growth should be aligned to support each other". The scale of growth proposed by the Preferred Strategy, far from supporting the Councils approach to the economy, appears likely to constrain such growth and increase pressure for unsustainable in-commuting contrary to the wording above.
Housing Mix - we do not agree that the mix of market housing on a site might be controlled.

Not accepted - the housing growth figure takes into account the increase in jobs - see Background Paper 1

Gwrthwynebu

ID sylw: 28004

Derbyniwyd: 19/09/2019

Ymatebydd: Home Builders Federation Ltd

BP07 Housing Land Supply
The HBF considers that CAT4 sites should not be included in the commitments calculation.
The housing trajectory does not take account of committed sites. The council do not reduce the level of windfalls due to changes in funding for RSLs.
The commitments should be discounted to take account of the recognised likelihood of non-delivery from allocated sites.
The non-delivery of Council owned allocated sites needs to be considered when looking at allocations in the future.

Accepted in part. The Deposit Plan will include a full housing trajectory as per the tables in the draft LDP Manual (Edition 3). This will use the WG methodology and should address some of the issues raised here.

Gwrthwynebu

ID sylw: 28005

Derbyniwyd: 19/09/2019

Ymatebydd: Home Builders Federation Ltd

Topic Paper 1
LDP AMR findings - Table P15 - The HBF do not consider the answer given is reasonable.
CCBC graph P17 - The supporting text around this graph is very negative and leads the Council to a reason for reducing the housing requirement, however the last two years of the graph show a significant increase in levels of housing delivery.
P18/19 the comment about 100% affordable homes will need to be revisited.
P21 The HBF considers that deallocation should also apply to any site where it cannot be shown that it will come forward in the Plan Period.

Not accepted.

Gwrthwynebu

ID sylw: 28006

Derbyniwyd: 19/09/2019

Ymatebydd: Home Builders Federation Ltd

BP09 LHMA
The HBF notes that the affordable housing need calculation looks at current and future housing need, however, this figure is then considered against the overall housing need figure which is calculated using past trends and takes no account of any backlog as a result of under delivery.

Not accepted. This is due to availability of data in relation to AH need. Whilst there is currently a shortfall in housing delivery in relation to the adopted LDP housing requirements, these were based on previous WG projections which were superseded even before adoption of the LDP. The RLDP use the latest available data refer to BP/1 & BP/11.

Gwrthwynebu

ID sylw: 28007

Derbyniwyd: 19/09/2019

Ymatebydd: Home Builders Federation Ltd

BP10 Affordable Housing Viability Summary
The HBF questions the purpose and role of this paper in the Plan process, why is a separate summary document required.

Accepted in Principle: Summary document prepared due to timescale for Preferred Strategy. BP/10 - 'Affordable Housing Viability Study' currently being finalised.

Gwrthwynebu

ID sylw: 28008

Derbyniwyd: 19/09/2019

Ymatebydd: Home Builders Federation Ltd

The HBF questions why are the Council choosing to use a different methodology to the latest WG one? There appears to be no explanation for this in the document.
Based on the comparison between the different methods used shown in Table 1 the HBF objects to the proposed growth option as it would result in a higher level of affordable homes being provided, above the identified need.

Not accepted. This is due to availability of data in relation to AH need. Whilst there is currently a shortfall in housing delivery in relation to the adopted LDP housing requirements, these were based on previous WG projections which were superseded even before adoption of the LDP. The RLDP use the latest available data refer to BP/1 & BP/11.