Response from Mrs Joanne Harding, Home Builders Federation (HBF)
1. Mrs Joanne Harding, Home Builders Federation (HBF) : 18 Dec 2017 14:14:00
Before completing this online representation please tick the box to show that you have read the guidance notes accompanying this consultation.
I have read the guidance notes
Policy Reference
AS03 - Housing Provision
1.1 Do you consider the AONB DPD to be legally compliant?
Yes
1.3 Do you consider the AONB DPD to be sound?
No
1.4 If NO please indicate the ground(s) on which you consider the DPD to be unsound
The DPD is not effective
1.5 Please give details of why you consider the DPD is not legally compliant or is unsound or fails to comply with the Duty to Cooperate. Please be as precise as possible.
If you wish to support the legal compliance or soundness of the DPD or its compliance with the Duty to Cooperate, please also use this box to set out your comments.
Thank you for consulting with the Home Builders Federation on the Publication Draft of the Arnside and Silverdale AONB DPD.
The HBF is the principal representative body of the house-building industry in England and Wales. Our representations reflect the views of our membership, which includes multi-national PLC’s, regional developers and small, local builders. In any one year, our members account for over 80% of all new “for sale” market housing built in England and Wales as well as a large proportion of newly built affordable housing.
Policy AS03 – Housing Provision
This policy is not considered to be sound, as it is not considered to be effective.
This policy requires that proposals for new housing development will be supported where they deliver no less than 50% affordable housing. It goes on to state that only where this is demonstrably unachievable will a lower percentage be acceptable.
Whilst the HBF supports the delivery of affordable housing, the delivery of affordable housing must, however, be balanced against economic viability considerations. The HBF consider that the affordable housing requirement proposed is not viable and will hinder the delivery of both market and affordable housing if development cannot occur. The evidence contained within the Viability Study (October 2016) also highlights that the 50% affordable housing requirement is not viable, and that a number of sites are not viable even at the lower 35% level.
1.6 Please set out what modification(s) you consider necessary to resolve your objection and make the DPD legally compliant or sound, having regard to the matter(s) you have identified above. (Please note that any non-compliance with the Duty to Cooperate is incapable of modification at examination). You will need to say why this modification will make the DPD legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible.
HBF propose that the policy is modified as follows:
• ‘Proposals for new housing development will be supported where they contribute to the provision of affordable housing.'
instead of,
'Proposals for new housing development will be supported where they deliver no less than 50% affordable housing. Only where this is demonstrably unachievable will a lower percentage be acceptable.'
2.1 If your representation is seeking a modification, do you wish to participate at the oral part of the Examination?
Yes, I wish to participate at the oral examination
2.2 If you wish to participate at the oral part of the Examination, please outline why you consider this to be necessary.
To debate the comments made within our representations further and in greater detail. To ensure that the industry can respond to any additional evidence provided by the Council or others following submission of the plan.
Please tick the box if you wish to be notified when the document is submitted, recommendations published and adopted.
Please notify me
