Consultation Question 33

Object

Representation ID: 27899

Received: 23/03/2021

Respondent: Samantha 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?

Comment

Representation ID: 27919

Received: 24/03/2021

Respondent: E.M. Farming & Leisure Ltd

Agent: McLoughlin Planning

Policy requires affordable housing on major residential developments, setting targets based on zones/locations and site’s PDL/greenfield status. It also suggests a tenure mix. Within the Preferred Option no affordable housing will be provided in East Morton.

Viability Assessment highlights issues in lower/lower medium value zones, recommending reduced affordable housing requirements in them. It recommends a zero requirement for lower value zones, but highlights it may be possible to set a level of 10% and consider proactive interventions to support delivery. Not clear what interventions are proposed.

Potential misinterpretation of NPPF where planning policies should expect at least 10% of the homes to be available for affordable home ownership, unless this would exceed the affordable housing requirement in the area

Nneed to address affordable housing requirements is recognised. Affordable housing policies must not only taken account of need but also viability and deliverability.

Unrealistic to negotiate on every site individually because the base-line aspiration of a policy/combination of policies is set too high - will jeopardise future housing delivery.

Object

Representation ID: 28198

Received: 24/03/2021

Respondent: Sarah Lucas

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: 28288

Received: 24/03/2021

Respondent: Stephen Mould

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: 29026

Received: 23/04/2021

Respondent: Abi Lafbery

•Section 106 agreements for affordable housing will still include a caveat allowing developers and builders to make affordability payments in lieu of housing to council.
•Affordable home payment contributions can be made in lieu of delivery of affordable housing provision on site. This caveat appears in the Sun Lane Section 106 agreement made between CEG and Bradford Council, held by Bradford Council It undermines the purpose of Core Strategy policy HO5 and statement 3.3.9.
•We would ask that it is considered in the affordable homes policy for ‘ring-fencing’ 10% of all affordable housing supply for local people living within a 5 mile radius of any development site.

Object

Representation ID: 29221

Received: 23/03/2021

Respondent: Rachel Wood

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: 29574

Received: 23/03/2021

Respondent: Harvey Bosomworth

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: 29614

Received: 17/03/2021

Respondent: Mr Mark Summerson

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: 30013

Received: 23/03/2021

Respondent: Daniel 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: 30094

Received: 23/03/2021

Respondent: Mrs Savia Lorain Hughes

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: 30144

Received: 17/03/2021

Respondent: The Strategic Land Group

Agent: Walsingham Planning

Paragraph 64 of the NPPF confirms 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 , unless this would exceed the level of affordable housing required in the area, or significantly prejudice the ability to meet the identified affordable housing needs of specific groups.

The above text does not direct that alternative targets should be proposed for greenfield and brownfield land, as such, a single figure should be proposed for each of the suggested areas, so for Zones 3 and 4, a single figure of 10% should be adopted.

Noting that the delivery of Bradford’s housing targets, particularly the adopted Core Strategy figure, requires extensive greenfield and Green Belt development to ensure its achievement, additional barriers, such as an increased affordable housing target, should not be imposed to reduce or potentially prevent the chances of this essential housing being expediently delivered within the new Local Plan.

Object

Representation ID: 30177

Received: 23/03/2021

Respondent: Catherine Terry

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?