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Review Report
4.9 LDP Housing Requirements
Representation ID: 27158
Received: 22/12/2017
Respondent: Home Builders Federation Ltd
HBF objects to the statement that the 'LDP target was unrealistic'.
HBF objects to the statement 'This issue was exacerbated in 2015 by changes to TAN1'.
The HBF does not agree with the statement that the 'LDP target was unrealistic'. At the time it was based on the information available and went through scrutiny at the plans inquiry and was adopted by the Council. Although circumstances and the data available may now have changed, at the time it was the appropriate target.
The HBF object to the statement 'This issue was exacerbated in 2015 by changes to TAN1'. The method of calculation does not directly affect the land supply as the wording suggests. TAN1 is purely a method by which to monitor the land available. One of the reason TAN1 was changed was that WG realised that relying on past build rates gave a false land supply figure and merely allowed Councils to continue to fail in the supply of new homes. An LDP should be about planning for the future needs and demands of the area as well as taking account of economic and other aspirations. A plan based on past records would be to plan for continued failure.
Accepted in part. Whilst we acknowledge that the housing target was found sound at Examination, subsequent WG projections have indicated far lower housing requirements. The Inspector did not take into account the reduced level of delivery since 2008, although CCBC argued to reduce the requirement for this reason.
PPW does now change the emphasis to be given to WG household projections when calculating LDP household requirements than was the case PPW prior to Edition 8. This will be clarified.
Object
Review Report
4.11 Conclusion
Representation ID: 27159
Received: 22/12/2017
Respondent: Home Builders Federation Ltd
There is no comment on the fact that some of the previously allocated sites may have in fact been the wrong sites to allocate, particularly any rolled over from previous plans.
No account taken of the issues identified in the WG Longitudinal and Viability study regarding site viability and deliverability.
There has been no discussion about one of the other factors which has affected the provision of housing, which is around the suitability of the sites allocated. Although it is accepted that the allocated sites went through a degree of scrutiny as part of their allocation in the LDP, the recent WG study entitled 'Longitudinal Viability Study of the Planning Process' has highlighted the need to look at deliverability and viability far more closely than it has been in previous LDP's. The HBF would request an additional paragraph which refers to this study and looks at the issues from the report referred to above in more detail thus giving a more balance view.
Noted. This will be considered as part of the LDP Review.
Comment
Review Report
5.1.3
Representation ID: 27160
Received: 22/12/2017
Respondent: Home Builders Federation Ltd
A further review of CIL has now been announced by central government and it should also be noted that CIL powers will be devolved to Wales in April 2018.
A further review of CIL has now been announced by central government and it should also be noted that CIL powers will be devolved to Wales in April 2018.
Noted. Changes in means to secure infrastructure requirements may be required. This will be considered as part of LDP Review.
Object
Review Report
5.2.1
Representation ID: 27161
Received: 22/12/2017
Respondent: Home Builders Federation Ltd
The HBF does not believe it is right to state that the build rate is 'extremely ambitious', as it was proven and agreed at the time of the plans adoption.
The HBF does not believe it is right to state that the build rate is 'extremely ambitious', as it was proven and agreed at the time of the plans adoption.
Not accepted. The point of this paragraph is that in comparison with recent build rates the Council maintain that building 435 per year is extremely ambitious. The housing requirement will be reviewed using the latest evidence as part of the LDP review process.
Object
Review Report
5.2.2
Representation ID: 27162
Received: 22/12/2017
Respondent: Home Builders Federation Ltd
The economic down turn happened between 2008 and 2013 so it is incorrect to refer to it as being over recent years. In fact in recent years the number of homes in Wales has been on the increase particularly since the introduction of Help to Buy Wales in 2014, this scheme is funded until at least 2021 so there is no current reason why this should not continue to support the purchase of new homes of which currently 78% are by first time buyers.
The economic down turn happened between 2008 and 2013 so it is incorrect to refer to it as being over recent years. In fact in recent years the number of homes in Wales has been on the increase particularly since the introduction of Help to Buy Wales in 2014, this scheme is funded until at least 2021 so there is no current reason why this should not continue to support the purchase of new homes of which currently 78% are by first time buyers.
Noted. It is acknowledged that the UK is no longer in recession, however the effects of the downturn are still being felt in the delivery of housing.
Comment
Review Report
5.2.4
Representation ID: 27163
Received: 22/12/2017
Respondent: Home Builders Federation Ltd
If any of the suggested changes already made in response to earlier sections of the document are made then this paragraph will also need to be amended particularly around the fact it blames the recession as the main reason for not achieving a 5 year land supply. Reference should also be made to the WG study 'Longitudinal Viability Study of the Planning Process' in this paragraph.
If any of the suggested changes already made in response to earlier sections of the document are made then this paragraph will also need to be amended particularly around the fact it blames the recession as the main reason for not achieving a 5 year land supply. Reference should also be made to the WG study 'Longitudinal Viability Study of the Planning Process' in this paragraph.
Noted.
Object
Review Report
5.2.5
Representation ID: 27164
Received: 22/12/2017
Respondent: Home Builders Federation Ltd
This section is currently misleading and does not give a balance picture of the situation.
There are other appeal decisions in the area which have not been granted even though there is a lack of five year land supply, so this needs to be explained to give a more balanced view.
This section is currently misleading and does not give a balance picture of the situation. There are other appeal decisions in the area which have not been granted even though there is a lack of five year land supply, so this needs to be explained to give a balanced view. Although it doesn't say it in so many words, some will read the current wording as suggesting builders will be able to win any appeal and build on every green field where ever they want which is clearly not the case. The lack of success on appeal where the council has less than a five year land supply is regularly seen all across Wales.
Not accepted. This paragraph does not suggest that appellants would win appeals for residential development in all cases. It clearly refers to the requirement for speculative development to 'otherwise comply with development plan and national policies'.
Comment
Review Report
5.2.8
Representation ID: 27165
Received: 22/12/2017
Respondent: Home Builders Federation Ltd
The HBF suggests that it would be helpful to give some examples of why the level of affordable housing has not been delivered. Is it for instance as a result of site viability issues. Alternatively examples could be reference in an Appendix where a table of sites developed is provided with the level of affordable achieved and if below policy requirement the reason why this is the case.
The HBF suggests that it would be helpful to give some examples of why the level of affordable housing has not been delivered. Is it for instance as a result of site viability issues. Alternatively examples could be reference in an Appendix where a table of sites developed is provided with the level of affordable achieved and if below policy requirement the reason why this is the case.
Noted.
Comment
Review Report
5.2.9
Representation ID: 27166
Received: 22/12/2017
Respondent: Home Builders Federation Ltd
If the Council are planning to start building its own Council Housing this would be the place to refer to it and explain how this might help in the delivery of more affordable homes as it would not be reliant on securing a percentage of affordable as part of a larger private site.
If the Council are planning to start building its own Council Housing this would be the place to refer to it and explain how this might help in the delivery of more affordable homes as it would not be reliant on securing a percentage of affordable as part of a larger private site.
Noted. Following stock transfer to Cartrefi Conwy, CCBC will not be building new housing itself, though higher levels of AH delivery or 100% AH on CCBC-owned sites is being promoted.
Comment
Review Report
5.2.11
Representation ID: 27167
Received: 22/12/2017
Respondent: Home Builders Federation Ltd
Wording should be added to explain that this additional affordable housing need does not automatically mean that the policy requirement within the plan will be set higher than before as other issues such as viability will have to be considered. Also the current level has not been achieved (and if this is down to viability) an increase in policy requirement would juts potentially result in less houses both private and affordable coming forward.
Wording should be added to explain that this additional affordable housing need does not automatically mean that the policy requirement within the plan will be set higher than before as other issues such as viability will have to be considered. Also the current level has not been achieved (and if this is down to viability) an increase in policy requirement would juts potentially result in less houses both private and affordable coming forward.
Noted. The Review Report does not state that AH percentages will increase. Affordable housing requirements and delivery mechanisms will be re-assessed as part of the LDP Review process.
