Consultation Question 33

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.

Object

Representation ID: 25199

Received: 23/03/2021

Respondent: Stephen Radcliffe

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: 25228

Received: 23/03/2021

Respondent: Denise Stanford

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: 25440

Received: 23/03/2021

Respondent: Rebecca Stokes

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: 25489

Received: 23/03/2021

Respondent: Mary Pawson

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: 25718

Received: 24/03/2021

Respondent: Mrs Penny Price

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: 25747

Received: 24/03/2021

Respondent: Mrs Sue Bell

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: 25776

Received: 24/03/2021

Respondent: Mrs M Armitage

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: 25805

Received: 24/03/2021

Respondent: Stuart Bell

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: 25834

Received: 24/03/2021

Respondent: Jackie Cooper

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: 25863

Received: 24/03/2021

Respondent: Elizabeth Archer

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: 25892

Received: 24/03/2021

Respondent: Jill Buckley

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: 25921

Received: 24/03/2021

Respondent: Andy Wheeler

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: 25950

Received: 24/03/2021

Respondent: Christine 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: 25979

Received: 24/03/2021

Respondent: Norah and David Jackman

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: 26008

Received: 24/03/2021

Respondent: Tom Chatwyn

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: 26037

Received: 24/03/2021

Respondent: Katherine Elston

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: 26066

Received: 24/03/2021

Respondent: Peter Whiffin

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: 26095

Received: 24/03/2021

Respondent: Catherine MacIntosh-Dixon

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: 26124

Received: 24/03/2021

Respondent: Philip Batty

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: 26153

Received: 24/03/2021

Respondent: Sophie Lamb

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: 26182

Received: 24/03/2021

Respondent: Emma and Anthony Reed

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: 26211

Received: 24/03/2021

Respondent: Helen Haskins

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: 26240

Received: 24/03/2021

Respondent: Mrs Janet Sage

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: 26269

Received: 22/03/2021

Respondent: Mr Paul Grant

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: 26299

Received: 22/03/2021

Respondent: Louise Grant

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: 26334

Received: 24/03/2021

Respondent: Prof. Jonathan 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: 26363

Received: 24/03/2021

Respondent: Catherine Flint

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: 26576

Received: 24/03/2021

Respondent: Mr Bernard Poulter

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: 26691

Received: 24/03/2021

Respondent: Mr Owen Sage

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?