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Review Report
7.6
Representation ID: 27168
Received: 22/12/2017
Respondent: Home Builders Federation Ltd
The HBF objects to some of the wording as it is wrong to say that it is the changes to TAN1 which have caused the under delivery of new homes, TAN1 is only a way of measuring the genuinely available land, it does not have an impact on the actual delivery of homes.
Additional wording is required in light of the Ministers recent statement regarding LDP's and the need for them to move forward jointly.
The HBF objects to some of the wording as it is wrong to say that it is the changes to TAN1 which have caused the under delivery of new homes, TAN1 is only a way of measuring the genuinely available land, it does not have an impact on the actual delivery of homes.
Additional wording is required in light of the Ministers recent statement regarding LDP's and the need for them to move forward jointly.
Not Accepted
Object
Review Report
8.1
Representation ID: 27169
Received: 22/12/2017
Respondent: Home Builders Federation Ltd
HBF object to the suggestion that the housing number should be reduced to a level which will ensure delivery, as this would be contrary to national guidance. The housing level should be set as a result of the identified need and any additional aspiration for growth which the Council may identify. Ensuring the right sites are allocated and that they are deliverable taking account of the impact of the plans policies is the issue.
The HBF are concerned that the wording of this paragraph suggests that the only way to deliver more homes is to ask for less in the first place. The housing provision should be set taking account of the identified need as a starting point as advised in PPW, and then making adjustments to allow for any economic or other aspirations which are linked to the need for housing, the wider North Wales Growth Deal is relevant for instance. It would be wrong for the plan to set the housing need at a level just to give a better chance of being able to deliver the numbers particularly if this is based on historical build rates. What is more important is to ensure that the sites allocated are the right ones and can be delivered and that other policies do not affect this deliverability.
Noted.
Comment
Review Report
3.3
Representation ID: 27170
Received: 22/12/2017
Respondent: Home Builders Federation Ltd
The HBF suggest that this would be a good point to include a reference to the potential impact of the North Wales Growth Deal and its ambitions for economic growth which will need to be matched by the provision of new homes in the right locations. There doesn't appear to be any mention of it anywhere else in the document.
The HBF suggest that this would be a good point to include a reference to the potential impact of the North Wales Growth Deal and its ambitions for economic growth which will need to be matched by the provision of new homes in the right locations. There doesn't appear to be any mention of it anywhere else in the document.
Accepted. The North Wales Growth Bid submission post-dated the LDP Review Report but details will be included in the revised Review Report.
Object
Review Report
4.4
Representation ID: 27171
Received: 22/12/2017
Respondent: Home Builders Federation Ltd
The current commentary on windfall sites is one sides and does not include a number of the factors that could have an effect on the level of windfall development.
The HBF do not consider that this paragraph on windfall's currently provides all sides of the story. There are many factors which could affect the level of windfall development, firstly the windfall level could have been set at an unrealistic level so was never going to be achieved. Secondly by their nature there is not an unlimited supply of windfall sites and no guarantee of when they will come forward so their availability is likely to reduce over time, both of these points should be included within the paragraph. Further if it is just down to small sites as explained in the paragraph it would help to provide some data to support this.
Noted. All housing requirements and sources of supply will be re-assessed as part of the LDP Review process.