Review Report

Object

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'.

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

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.

Noted. This will be considered as part of the LDP Review.

Comment

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.

Noted. Changes in means to secure infrastructure requirements may be required. This will be considered as part of LDP Review.

Object

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.

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

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.

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

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.

Noted.

Object

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.

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

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.

Noted.

Comment

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.

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

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.

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.