Consultation Question 33

Object

Representation ID: 1919

Received: 17/03/2021

Respondent: Burley Parish Council

Concerns at the approach adopted in respect of affordable housing policy have been expressed at Q4. In addition it is a surprise that despite a wealth of evidence in the Local Plan that should be used as input, it has clearly had little or no consideration e.g. looking at the suggested targets used in HO5, there are issues affecting the credibility of the figures in Zones 3 and 4.

Affordable home payment contributions by a developer can be made instead of delivering affordable housing on a development site. If BDMC have a genuine commitment to deliver affordable housing across the District, why is this even considered in the Local Plan? What is the justification or basis for this policy when affordable housing is needed in all areas of development?

Object

Representation ID: 3284

Received: 22/03/2021

Respondent: Wilsden Parish Council

In Policy HO5 E third bullet appears to an interpretation of para 64 of the NPPF but it is unclear and omits the reference to “specific groups”.

Object

Representation ID: 3698

Received: 23/03/2021

Respondent: Mr Philip Sutcliffe

he green belt was set up to stop urban expansion. In the case of
Bradford, to stop it becoming part of Leeds. Bradford planning office
being completely undemocratic wishes to pour cement and tarmac all
over the green belt in Tong. The reason I say undemocratic is as
follows. ~There has not been one survey, or opinion poll taken in
Bradford, which agrees with Bradford councils views on building on
green belt. In fact approx 90 % of population of Bradford totally
disagree with Bradford councils housing and road plans. However, the council which claims
represents the people is acting like a fascist state.

Your new road and housing plans directly effect my Grade II house and
land. However, you have not had the decency to contact me over the
last 10 years. I doubt you care less about me than the environment and
the creatures that need it.

Object

Representation ID: 5460

Received: 24/03/2021

Respondent: Mr Peter Jenkins

Developers should be made to provide the affordable housing not just pay to avoid this obligation.
Wharfedale numbers of affordable houses not realistic or provable

Comment

Representation ID: 10332

Received: 24/03/2021

Respondent: Barratt Homes and David Wilson Homes Yorkshire West

Agent: Sheppard Planning

H05: Affordable Housing

Barratt are concerned that Part E of the policy is too prescriptive about the acceptable tenure mix. As noted above Para 11a) of NPPF seeks flexibility in policies and the Plan period is 18 years, over which time the needs of the population in Bradford are likely to change.

It is suggested that Part E is amended to remove the “starting point” for negotiations in favour of a reference to the then current SHMA. This approach would better accord with national policy and allow for suitable updates to the basic guidance that informs applications during the Plan Period.

This would also recognise Governments drive to increase home ownership and, as a more flexible policy approach, would not exclude the high proportion of affordable rental properties should this be needed and justified in the area.

Support

Representation ID: 10963

Received: 24/03/2021

Respondent: P&D Northern Asset Management

Agent: Pegasus Group (Manchester)

We note that Queensbury falls within Zone 3 (Outer Bradford and Keighley Zone) which requires a 15% affordable housing requirement on greenfield sites and 10% of brownfield sites. We concur with this requirement and can confirm the Queensbury Golf Course site will be able to deliver this many affordable homes, which would equate to 39 affordable homes based on 260 dwellings.

We consider the remaining parts of the policy dealing with vacant building credits, tenure, and rural housing are appropriate and there is sufficient flexibility built into the policy to allow for alternative approached to be taken towards the delivery of affordable housing, which is in line with current national policy guidance.

Object

Representation ID: 11415

Received: 17/03/2021

Respondent: Mr Robert Felstead

Have concerns about the approach adopted in respect of affordable housing policy. There is more evidence that should be used as input to this policy. Agree in principle to the figures for Zones 1 & 2. Zones 3 & 4 lack credibility based on evidence – most homes in zones 3 & 4 are rented and are amongst the most deprived in the UK, whilst the SHMA states that 25% of the district’s housing need is for affordable homes.

Affordable home payment contributions can be made instead of delivering provision on site - if there is a genuine commitment to deliver affordable housing across the district ‘to level up’, why is this considered in the Local Plan? No justification or basis on which this policy is built. No ring-fencing of affordable housing for local residents; say 10%, and yet this is an aim of the Local Plan. Why is not this documented?

Comment

Representation ID: 15776

Received: 24/03/2021

Respondent: West Yorkshire Combined Authority (WYCA)

The Plan also sets out, primarily through Policy HO5: Affordable Housing, how it intends to deliver a sufficient supply of good quality affordable housing that meets identified needs across the District.

The Policy sets varying degrees of affordable housing contribution for all major residential developments (10 or more homes) across four ‘Affordable Housing Zones’ and dependent upon greenfield/brownfield status, above the identified size thresholds. These elements of the Plan support the SEP ambition to increase housing growth and the provision of affordable homes.

Object

Representation ID: 16970

Received: 23/03/2021

Respondent: Avant Homes

Agent: ID Planning

Whilst we note the policy states the proposed mix is the starting point for negotiations, it is considered the proposed mix too prescriptive, particularly having regard to government drive to increase home ownership.

Required Change
The bullet points in part E of Policy HO5 should be removed so that tenure mixes are considered on a site by site basis having regard to the SHMA or other up to date verifiable evidence

Object

Representation ID: 17657

Received: 23/03/2021

Respondent: Barratt Homes and David Wilson Homes

Agent: ID Planning

Part E of Policy HO5 sets out the tenure mix which will be starting point for all affordable housing negotiations (65% affordable housing for rent and 35% affordable home ownership and at least 10% available for home ownership in line with national policy). This mix is based on the recommendations set out in the SHMA.
The government has announced measures to increase home ownership by investing in new shared ownership mode. The new model will provide about half of the new homes for affordable home ownership and the reminder for discounted rent.
Whilst we note the policy states the proposed mix is the starting point for negotiations, it is considered the proposed mix too prescriptive, particularly having regard to government drive to increase home ownership.
Required Change
The bullet points in part E of Policy HO5 should be removed so that tenure mixes are considered on a site by site basis having regard to the SHMA or other up to date verifiable evidence.

Object

Representation ID: 17692

Received: 23/03/2021

Respondent: Bannister Investments Limited

Agent: ID Planning

Whilst we note the policy states the proposed mix is the starting point for negotiations, it is considered the proposed mix too prescriptive, particularly having regard to government drive to increase home ownership.
Required Change
The bullet points in part E of Policy HO5 should removed so that tenure mixes are considered on a site by site basis having regard to the SHMA or other up to date evidence.

Support

Representation ID: 18389

Received: 22/03/2021

Respondent: Mapeley STEPS Limited

Agent: Montagu Evans LLP

It is a strategic priority to deliver more family homes across the district including sufficient affordable housing (Policy HO5).
The Council’s approach to the strategic allocation of sites and ensuring efficient use of land through appropriate density and mix of development is supported. The HMRC Shipley site is a sustainable, suitable and deliverable location for a high quality residential led development to deliver much needed housing for the District.

Object

Representation ID: 18396

Received: 24/03/2021

Respondent: Johnson Mowat

Johnson Mowat supports and endorses the position of the HBF as set out in its representations regarding draft Policy HO5.

In particular, part E of the draft Policy incorrectly reflects national planning policy and needs to be corrected.

Paragraph 64 of the NPPF clearly states that ‘where major development involving the provision of housing is proposed, planning policies and decisions should expect at least 10% of the homes to be available for affordable home ownership’, which is then qualified by footnote 29 to confirm that this 10% of the total number of homes forms part of the overall affordable housing contribution from the site.

Bullet point 3 under part E of the draft Policy suggests that this 10% is the proportion of the overall affordable housing contribution that should be available for affordable home ownership, which is incorrect.

For example, a 50 unit scheme in a location where the affordable housing target is 20% (10 units) would provide 5 units for affordable home ownership (i.e. 10% of 50) and the remainder (5 units) of other tenures.

Comment

Representation ID: 19931

Received: 23/03/2021

Respondent: Climate Action Ilkley

Number of people: 7

2. All developments should include a significant proportion of affordable housing and meet requirements for density to accommodate these. They should not have a high proportion of detached, expensive houses, which are not attainable by many of the people we need to ensure Ilkley continues to thrive, such as younger people and those working in the public sector and service industries.

Object

Representation ID: 20000

Received: 24/03/2021

Respondent: Avant Homes

Agent: Tetra Tech (Leeds)

The ability to deliver the objectives of Policy HO5 are reliant on an appropriate starting point for overall housing supply and spatial strategy. We consider the approach set out in Policy SP8 will compromise the ability to meet the objectives of Policy HO5.

The majority of the growth in the plan is proposed in the Regional City of Bradford (72%) where much of the city is expected to provide a maximum of 15% affordable housing, with this being 10% for development in Inner Bradford. It is therefore extremely unlikely that 441 affordable dwellings per annum will be delivered by policy HO5.

We therefore suggest, as we did in the CSPR 2019, that the scale of need for affordable housing justifies an uplift to the overall housing requirement figure.

the restriction of housing supply in the higher market value areas will compound the affordability gap. The situation can only be addressed through amendment to Policy SP8.

Object

Representation ID: 21811

Received: 23/03/2021

Respondent: Duncan Watson

Concerns at the approach adopted in respect of affordable housing policy have been expressed at Q4. In addition it is a surprise that despite a wealth of evidence in the Local Plan that should be used as input, it has clearly had little or no consideration e.g. looking at the suggested targets used in HO5, there are issues affecting the credibility of the figures in Zones 3 and 4.

Affordable home payment contributions by a developer can be made instead of delivering affordable housing on a development site. If BDMC have a genuine commitment to deliver affordable housing across the District, why is this even considered in the Local Plan? What is the justification or basis for this policy when affordable housing is needed in all areas of development?

Object

Representation ID: 21894

Received: 23/03/2021

Respondent: Catherine Starling

Concerns at the approach adopted in respect of affordable housing policy have been expressed at Q4. In addition it is a surprise that despite a wealth of evidence in the Local Plan that should be used as input, it has clearly had little or no consideration e.g. looking at the suggested targets used in HO5, there are issues affecting the credibility of the figures in Zones 3 and 4.

Affordable home payment contributions by a developer can be made instead of delivering affordable housing on a development site. If BDMC have a genuine commitment to deliver affordable housing across the District, why is this even considered in the Local Plan? What is the justification or basis for this policy when affordable housing is needed in all areas of development?

Object

Representation ID: 21923

Received: 23/03/2021

Respondent: Dr Samantha Cook

Concerns at the approach adopted in respect of affordable housing policy have been expressed at Q4. In addition it is a surprise that despite a wealth of evidence in the Local Plan that should be used as input, it has clearly had little or no consideration e.g. looking at the suggested targets used in HO5, there are issues affecting the credibility of the figures in Zones 3 and 4.

Affordable home payment contributions by a developer can be made instead of delivering affordable housing on a development site. If BDMC have a genuine commitment to deliver affordable housing across the District, why is this even considered in the Local Plan? What is the justification or basis for this policy when affordable housing is needed in all areas of development?

Object

Representation ID: 21952

Received: 23/03/2021

Respondent: Birgit Almond

Concerns at the approach adopted in respect of affordable housing policy have been expressed at Q4. In addition it is a surprise that despite a wealth of evidence in the Local Plan that should be used as input, it has clearly had little or no consideration e.g. looking at the suggested targets used in HO5, there are issues affecting the credibility of the figures in Zones 3 and 4.

Affordable home payment contributions by a developer can be made instead of delivering affordable housing on a development site. If BDMC have a genuine commitment to deliver affordable housing across the District, why is this even considered in the Local Plan? What is the justification or basis for this policy when affordable housing is needed in all areas of development?

Object

Representation ID: 21981

Received: 23/03/2021

Respondent: Mrs Corrie Hardaker

Concerns at the approach adopted in respect of affordable housing policy have been expressed at Q4. In addition it is a surprise that despite a wealth of evidence in the Local Plan that should be used as input, it has clearly had little or no consideration e.g. looking at the suggested targets used in HO5, there are issues affecting the credibility of the figures in Zones 3 and 4.

Affordable home payment contributions by a developer can be made instead of delivering affordable housing on a development site. If BDMC have a genuine commitment to deliver affordable housing across the District, why is this even considered in the Local Plan? What is the justification or basis for this policy when affordable housing is needed in all areas of development?

Object

Representation ID: 22010

Received: 23/03/2021

Respondent: Carly Mitchell

Concerns at the approach adopted in respect of affordable housing policy have been expressed at Q4. In addition it is a surprise that despite a wealth of evidence in the Local Plan that should be used as input, it has clearly had little or no consideration e.g. looking at the suggested targets used in HO5, there are issues affecting the credibility of the figures in Zones 3 and 4.

Affordable home payment contributions by a developer can be made instead of delivering affordable housing on a development site. If BDMC have a genuine commitment to deliver affordable housing across the District, why is this even considered in the Local Plan? What is the justification or basis for this policy when affordable housing is needed in all areas of development?

Object

Representation ID: 22039

Received: 23/03/2021

Respondent: Helen Ross

Concerns at the approach adopted in respect of affordable housing policy have been expressed at Q4. In addition it is a surprise that despite a wealth of evidence in the Local Plan that should be used as input, it has clearly had little or no consideration e.g. looking at the suggested targets used in HO5, there are issues affecting the credibility of the figures in Zones 3 and 4.

Affordable home payment contributions by a developer can be made instead of delivering affordable housing on a development site. If BDMC have a genuine commitment to deliver affordable housing across the District, why is this even considered in the Local Plan? What is the justification or basis for this policy when affordable housing is needed in all areas of development?

Object

Representation ID: 22071

Received: 23/03/2021

Respondent: Rebecca Spencer

Concerns at the approach adopted in respect of affordable housing policy have been expressed at Q4. In addition it is a surprise that despite a wealth of evidence in the Local Plan that should be used as input, it has clearly had little or no consideration e.g. looking at the suggested targets used in HO5, there are issues affecting the credibility of the figures in Zones 3 and 4.

Affordable home payment contributions by a developer can be made instead of delivering affordable housing on a development site. If BDMC have a genuine commitment to deliver affordable housing across the District, why is this even considered in the Local Plan? What is the justification or basis for this policy when affordable housing is needed in all areas of development?

Object

Representation ID: 22100

Received: 23/03/2021

Respondent: Lucy Ashton

Concerns at the approach adopted in respect of affordable housing policy have been expressed at Q4. In addition it is a surprise that despite a wealth of evidence in the Local Plan that should be used as input, it has clearly had little or no consideration e.g. looking at the suggested targets used in HO5, there are issues affecting the credibility of the figures in Zones 3 and 4.

Affordable home payment contributions by a developer can be made instead of delivering affordable housing on a development site. If BDMC have a genuine commitment to deliver affordable housing across the District, why is this even considered in the Local Plan? What is the justification or basis for this policy when affordable housing is needed in all areas of development?

Object

Representation ID: 22129

Received: 23/03/2021

Respondent: Mr Chris Turner

Concerns at the approach adopted in respect of affordable housing policy have been expressed at Q4. In addition it is a surprise that despite a wealth of evidence in the Local Plan that should be used as input, it has clearly had little or no consideration e.g. looking at the suggested targets used in HO5, there are issues affecting the credibility of the figures in Zones 3 and 4.

Affordable home payment contributions by a developer can be made instead of delivering affordable housing on a development site. If BDMC have a genuine commitment to deliver affordable housing across the District, why is this even considered in the Local Plan? What is the justification or basis for this policy when affordable housing is needed in all areas of development?

Object

Representation ID: 22158

Received: 23/03/2021

Respondent: Judy Breckett

Concerns at the approach adopted in respect of affordable housing policy have been expressed at Q4. In addition it is a surprise that despite a wealth of evidence in the Local Plan that should be used as input, it has clearly had little or no consideration e.g. looking at the suggested targets used in HO5, there are issues affecting the credibility of the figures in Zones 3 and 4.

Affordable home payment contributions by a developer can be made instead of delivering affordable housing on a development site. If BDMC have a genuine commitment to deliver affordable housing across the District, why is this even considered in the Local Plan? What is the justification or basis for this policy when affordable housing is needed in all areas of development?

Object

Representation ID: 22198

Received: 23/03/2021

Respondent: Mr Paul Hardaker

Concerns at the approach adopted in respect of affordable housing policy have been expressed at Q4. In addition it is a surprise that despite a wealth of evidence in the Local Plan that should be used as input, it has clearly had little or no consideration e.g. looking at the suggested targets used in HO5, there are issues affecting the credibility of the figures in Zones 3 and 4.

Affordable home payment contributions by a developer can be made instead of delivering affordable housing on a development site. If BDMC have a genuine commitment to deliver affordable housing across the District, why is this even considered in the Local Plan? What is the justification or basis for this policy when affordable housing is needed in all areas of development?

Object

Representation ID: 22227

Received: 23/03/2021

Respondent: Helen Taylor

Concerns at the approach adopted in respect of affordable housing policy have been expressed at Q4. In addition it is a surprise that despite a wealth of evidence in the Local Plan that should be used as input, it has clearly had little or no consideration e.g. looking at the suggested targets used in HO5, there are issues affecting the credibility of the figures in Zones 3 and 4.

Affordable home payment contributions by a developer can be made instead of delivering affordable housing on a development site. If BDMC have a genuine commitment to deliver affordable housing across the District, why is this even considered in the Local Plan? What is the justification or basis for this policy when affordable housing is needed in all areas of development?

Object

Representation ID: 22256

Received: 23/03/2021

Respondent: Dr Ceri Pitches

Concerns at the approach adopted in respect of affordable housing policy have been expressed at Q4. In addition it is a surprise that despite a wealth of evidence in the Local Plan that should be used as input, it has clearly had little or no consideration e.g. looking at the suggested targets used in HO5, there are issues affecting the credibility of the figures in Zones 3 and 4.

Affordable home payment contributions by a developer can be made instead of delivering affordable housing on a development site. If BDMC have a genuine commitment to deliver affordable housing across the District, why is this even considered in the Local Plan? What is the justification or basis for this policy when affordable housing is needed in all areas of development?

Object

Representation ID: 22285

Received: 23/03/2021

Respondent: Mrs Sonya Hampton

Concerns at the approach adopted in respect of affordable housing policy have been expressed at Q4. In addition it is a surprise that despite a wealth of evidence in the Local Plan that should be used as input, it has clearly had little or no consideration e.g. looking at the suggested targets used in HO5, there are issues affecting the credibility of the figures in Zones 3 and 4.

Affordable home payment contributions by a developer can be made instead of delivering affordable housing on a development site. If BDMC have a genuine commitment to deliver affordable housing across the District, why is this even considered in the Local Plan? What is the justification or basis for this policy when affordable housing is needed in all areas of development?