Comment

Representation ID: 25166

Received: 23/03/2021

Respondent: Home Builders Federation

This policy requires affordable housing contributions on all major residential development, it sets different targets based on zones and whether the site is PDL or greenfield. The affordable housing requirement ranges from 10% in Inner Bradford and Keighley to 40% on greenfield sites in Wharfedale. The policy goes on to suggest that the tenure mix will be 65% for affordable rent and 35% affordable home ownership products. It also states that in line with national policy at least 10% of the overall affordable housing contribution from a site should be available for affordable home ownership.

The Financial Viability Assessment Report sets out the latest viability position. It highlights that there are viability issues in in the lower and lower medium value zones and recommends a reduced affordable housing requirement in these areas. For the lower zones the Assessment recommends reducing the affordable housing requirement to nothing, although it does suggest that it may be possible to set the level at 10% in line with the NPPF and consider proactive interventions in the market to support delivery. It is not apparent from the policy what proactive interventions the Council proposes.

The HBF notes that the NPPF states that where major development involving the provision of housing is proposed, planning policies should expect at least 10% of the homes to be available for affordable home ownership, unless this would exceed the level of affordable housing required in the area. The HBF are concerned this has been misinterpreted by the Council. The 10% affordable home ownership is a proportion of the overall number of homes provided, not from the affordable housing contribution. As such if the Council is following the recommendation from the Viability Assessment in terms of the lower value areas the affordable housing provision from these areas should be only in the form of affordable home ownership homes. The HBF considers that the Council should also give further consideration of this NPPF requirement in relation to the tenure split proposed across other areas too. As at present it would not be possible to provide both the NPPF 10% affordable home ownership homes and the meet the proposed affordable housing split set in the policy.

The HBF supports the need to address the affordable housing requirements of the borough. The NPPF is, however, clear that the derivation of affordable housing policies must not only take account of need but also viability and deliverability. The Council should be mindful that it is unrealistic to negotiate every site on a one-by-one basis because the base-line aspiration of a policy or combination of policies is set too high as this will jeopardise future housing delivery.