Policy HS2: Affordable Housing

Showing comments and forms 1 to 29 of 29

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 842

Received: 29/11/2016

Respondent: Mr Alan Gordon

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Object to HS2: accept self-build as form of affordable housing for smaller sites and additional to affordable housing targets for larger sites.

Full text:

This policy should formally accept self-build as a kind of housing delivery that can be more affordable and should be an important inclusion in any affordable housing strategy.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 1162

Received: 28/11/2016

Respondent: Croudace Homes Ltd

Agent: Portchester Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Object to HS2: awkwardly worded, targets should be clear and unequivocal, inconsistency with SP8 / HS3

Full text:

Policy HS2: Affordable Housing:
The Policy is objected to. This is because the policy is awkwardly worded - i.e. because it places the actual targets at the end of the policy wording, this is confusing to the reader. The affordable housing provision targets should form part of Item a(i) of the policy.

Further, in relation to Item (a)(i) it is unclear what the words "maximised having regard to the targets" mean. This could be interpreted that there may be circumstances where the Council would be seeking to require a greater provision than the target? The policy should simply set clear, fixed and unequivocal targets.

In addition, in relation to the reference to policy HS3, in Item (b)(v) of Policy HS2, it is relevant to note that Policy HS3 does not tie-up with policy SP8(f) on the mix of affordable housing types. How are frictions between Pollices SP8 and HS3 to be resolved?

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 2285

Received: 31/10/2016

Respondent: Mr Maurice Filby

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Great need for affordable housing. Planning permission should only be granted when the targeted quota is reached.

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 3809

Received: 30/11/2016

Respondent: Beechwood Homes

Agent: JB Planning Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Object to HS2: Tenure split should be an aspiration, no reference to viability, review mechanisms only appropriate on strategic-scale development

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 3816

Received: 30/11/2016

Respondent: James Property Investments LLP

Agent: JB Planning Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Object to HS2: Tenure split should be an aspiration, no reference to viability, review mechanisms only appropriate on strategic-scale development

Full text:

See attached

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 3837

Received: 30/11/2016

Respondent: MR Robert Parker

Representation:

Support HS2:
- 'Flexibility' needs to be built into the policy as viability is very much site specific
- CIL

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 3841

Received: 29/11/2016

Respondent: Pigeon Land Ltd

Agent: Keymer Cavendish Limited

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Object to HS2: Council needs to specify tenure mix precisely, seeks justification of affordability, cannot require retention in perpetuity, requirement to consider other surveys does not provide clear policy

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 3911

Received: 29/11/2016

Respondent: Letchworth Garden City Heritage Foundation

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Support the provision of affordable housing in line with the provisions of the policy.

The definition of affordable housing should be broadened and clarification whether low cost market housing for local people can be included. Definition should include recognition of Community Land Trust and co-operative housing models as a way of delivering homes.

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4098

Received: 30/11/2016

Respondent: The Crown Estate

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Object to HS2: Flexibility and viability considerations identified in supporting text and Policy SP7 not included in policy

Full text:

See attached

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4181

Received: 30/11/2016

Respondent: Pirton Parish Council

Representation:

Support HS2: recognition of affordability problems of shared ownership and emphasis on rent

Full text:

See attachments

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4199

Received: 30/11/2016

Respondent: Ashill

Agent: CBRE Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Object to HS2: Payments in lieu should not be relegated to supporting text, additional text proposed, plan does not take full account of viability

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4207

Received: 30/11/2016

Respondent: Countryside Properties (UK) Ltd

Agent: Strutt & Parker

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Object to HS2: Unclear if development can sustain the requirements, uncertainty as to level of CIL and s106 required, viability not sufficiently addressed

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4219

Received: 30/11/2016

Respondent: Bloor Homes South Midlands

Agent: White Peak Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Object to HS2: 40% affordable housing not viable East of Luton, consider Luton affordable housing targets for consistency, targets inconsistent with SP8

Full text:

See attached

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4239

Received: 30/11/2016

Respondent: E W Pepper Ltd

Agent: Bidwells

Representation:

Support HS2: Acknowledgement that viability issues may arise in some circumstances

Full text:

See attached

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4261

Received: 29/11/2016

Respondent: Save Rural Codicote

Agent: Hutchinsons

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Object on the following grounds:
the broadbrush requirement for affordable housing for all sites over 25 dwellings;
policy does not make provision for ensuring affordable housing is offered to Codicote residents first.

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4278

Received: 25/11/2016

Respondent: Rentplus

Agent: Tetlow King Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Object to HS2: Rent to Buy not specifically mentioned, retention in perpetuity only applicable to rural exception sites

Full text:

See attachment

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4340

Received: 29/11/2016

Respondent: Warden Developments Ltd

Agent: Phillips Planning Services Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Object on the following grounds:
concern that the target percentage of 40% affordable dwellings will be seen as a minimum target leading to onerous levels of justification for any departure from it;
residential development should not be overburdened with aspirational affordable housing targets; and
the identified figure of 33% in the SHMA should be used as the target for the district.

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4393

Received: 30/11/2016

Respondent: New Road Developments Ltd

Agent: DLP (Planning) Limited

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation:

Object on the following grounds:
the policy should be amended to recognise that the delivery of affordable housing should take into account, and be based upon, viability considerations. This would accord with policy SP7.

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4501

Received: 30/11/2016

Respondent: Transition Town Letchworth

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Object to HS2:
- Rented and social housing stock is not evenly distributed
- Local plan provides opportunity to ensure that adequate affordable housing is provided in each town

Full text:

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Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5197

Received: 29/11/2016

Respondent: Greene King PLC

Agent: David Russell Associates

Legally compliant? Yes

Sound? No

Duty to co-operate? Not specified

Representation:

Object to HS2: Increase in targets since Preferred Options, small nos of affordable housing difficult to manage, review mechanisms should allow for decrease in affordable housing

Full text:

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Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5414

Received: 29/11/2016

Respondent: Graveley Parish Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Object to para 8.17: CGB2 Provides opportunity for affordable housing on the edge of villages, contrary to other policy requirements of the plan and NPPF

Full text:

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Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5520

Received: 30/11/2016

Respondent: Home Builders Federation Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Object to HS2: Relationship with CIL / s106 unclear in viability terms, policy not sufficiently precise/is unclear at i), ii) and iii), clause c unenforceable, para 8.15 and proposed use of supplementary guidance contrary to NPPF.

Full text:

See attachment

Attachments:

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5565

Received: 30/11/2016

Respondent: Mrs Brenda Parker

Representation:

Support HS2:
- I agree with fully.

Full text:

Representation on the Local Plan 2011-2031 submission document ("LPSD")
Objections
1.1 The LPSD proposal of 2,100 homes to the East of Luton will destroy the rural nature of the village of Cockernhoe. Reference to Cockernhoe can be backdated to the 10th Century by a manuscript of 980AD. The village of Cockernhoe, incorporating Mangrove, numbers 130 dwellings. Cockernhoe ward numbers 205 dwellings. The nearest point of Cockernhoe village to the existing Luton dwellings is 200 metres and this boundary around the village should not be encroached upon as it is surely the minimum needed to retain Cockernhoe's rural nature. In my view the release of Green Belt land surrounding the required settlement boundary of Cockernhoe would not meet the "tests of soundness" set out in the National Planning Policy Framework ("NPPF") -see 1.5 below.
1.5 The NPPF specifically seeks to stop urban sprawl where this affects communities. This is clearly the case with regard to Cockernhoe and other villages/communities affected by this East Of Luton proposal, which should be stopped.
1.7 The 2,100 homes to the East of Luton proposal is not "exceptional circumstances". Considering the objections to the proposal by residents of Luton in addition to those of North Herts it is disturbing that NHDC has recommended this proposal.
There are alternative areas, such as land adjacent to Butterworth Green and North of the A505, which could be developed without encroaching upon any existing settlement. There is no need to destroy the rural nature of an existing community, Cockernhoe, which has existed for more than 1,000 years.
The need to properly assess the need for development is difficult. In December 2012 NHDC concluded the need was 10,700 dwellings. By 2014 this had increased to 12,200 for their own needs and now in 2016 to 14,000. This must be due to immigration and therefore it must be concluded that "Brexit" will reduce this figure - but NHDC say not! None of us knows what the result will be! To make a decision in the next 5 years to destroy the rural nature of Cockernhoe and associated communities in Cockernhoe ward and the affected areas of Luton is surely irresponsible! The 14,000 dwellings required by NHDC for its' own needs already represents an increase of 25.5% compared to the 55,000 dwellings existing in NHDC in 2011. In England as a whole there were 22,976,000 dwellings in 2011 (Housing statistics release 28th April 2016 by the Department for Communities and Local Government). A 25.5% increase overall in England would mean this number of dwellings increasing by 6.0m by 2031,representing a population increase of 14m which is clearly incorrect. In the period from 31st March 2001 to 31st March 2015 the increase in dwellings in England was 2.3m. In conclusion the need for 14,000 new homes is virtually a guess having increased by 31% from the estimate in 2012. Thus these additional new homes should not be added to by the extra 2,100 homes for Luton. See clause 2.8 below for calculation of the figure needed.
1.8 The duty to co-operate should be qualified as to "where they are able to". A significant proportion of residents of North Herts already work outside the district, see clause 2.76, and this would be the same with the 14,000 homes required for North Herts own needs. Thus surely NHDC has already complied with its' duty to co-operate.
1.9 To the West of Luton Redrow is building some 350 homes at Caddington Woods. This is some 650m from the outskirts of the Bedfordshire village of Caddington. Why is this development so small? There was a proposal to build 5,500 homes there in 2015 that was rejected by Luton, see www.bushwood.info/docs/Bushwood-Masterplan.pdf. This was as close to Caddington as the 2,100 dwellings are to Cockernhoe. I believe Luton councillors were concerned about objections from residents of the village of Caddington but obviously completely ignored the objections by North Herts residents and those from affected areas of Luton. Similarly the majority of NHDC councillors have ignored the objections from their community.
1.19 Whilst NHDC have consulted with the local community on the incorporation of the 2,100 homes to the East of Luton they have ignored their objections. There is little purpose in requiring a consultation process if you ignore the result.
1.22 Similarly to 1.19 above the previous consultations have been ignored.
1.26 Similarly to 1.19 above the previous consultations have been ignored.
1.27 Similarly to 1.19 above the previous consultations have been ignored.
2.8 The forecast of an increase in population in North Herts of 24,000 by 2031 does not require the building of 16,000 new dwellings. Assuming households on average of 2.4 this would require 10,000 new dwellings. There is significant inconsistency in these figures. If you then add the 1,600 households on the housing register (clause 2.25) you would need a maximum of 11,600 homes.
2.77 The intention to improve physical and mental wellbeing for the several thousand residents of Wigmore, Luton and Cockernhoe ward affected by the 2,100 homes to the East of Luton is completely ignored by this proposal.
2.83 The new development of 2,100 homes East of Luton will not:
(a) Enable the village of Cockernhoe to embrace their role within North Herts. The village will be lost forever and just be part of the urban community of Luton
(b) The District's historical rural areas will not be protected
3.7 Cockernhoe is being sacrificed and it is clear is outside NHDC's strategic objectives for ENV2, ECON4, ECON 6. I do not believe that ECON8 will be possible for the 2,100 dwellings proposed and think the road infrastructure will not be possible to accommodate this growth. I cast doubt on the methods of collection of the data. For instance in the last two months we have had 3 occasions where the roads have been gridlocked for various reasons. When you are sitting in such a traffic jam how does the cables across the road measure that. They surely measure the traffic that crosses them and not the queue of traffic wanting to cross them. SOC 4 is being completely ignored for the rural community of Cockernhoe where its' residents have objected to these plans over the course of the last 8 years.
4.0(b) Once again Cockernhoe is being excluded from this policy. The 2,100 homes surrounding Cockernhoe are twice as big as the future increase to the District's largest town of Hitchin (1,009).
4.9 The settlement boundary of Cockernhoe, within the classification of a Category "A" village, should not be expanded to include the area covered by the land allocated for the 2,100 homes. Such area should be given a classification of its' own so that objections can be raised against that but not reflect on Cockernhoe's own inclusion within the policy of category "A" villages.
4.13 Similarly to 4.9 above the East of Luton development should not be associated with Cockernhoe's own settlement boundary.
4.53 I disagree that the 2,100 proposal East of Luton, resulting in the rural nature of Cockernhoe being destroyed, qualifies as existence of "exceptional circumstances".
4.55 Green Belt is surely pointless if it can be removed by Council at will and against the will of the local community affected by its' removal.
SP6 I do not believe that adequate proposals have been made to deal with the road infrastructure needed for the 2,100 homes proposed.
SP8 (b) I disagree with this policy.
SP19 This policy should be cancelled as inappropriate and undeliverable to the satisfaction of residents of Cockernhoe and the affected parts of Luton.
13.66 I totally disagree with inclusion of the East of Luton expansion within the Cockernhoe settlement boundary. It should have a classification of its own.

Support
4.9 Policy SP2 concerning general development being allowed within the defined settlement boundaries of the Category "A" villages is a significant step forward. These 23 villages include Cockernhoe but the settlement boundary of that village has been expanded to include space for the 2,100 new homes planned. This is wrong the settlement boundary of Cockernhoe is clearly shown on the map in white. The additional area coloured brown should not be associated with Cockernhoe's settlement boundary but should be attributed a classification of its' own.
SP5 (a) (iii) I support the definition of settlement boundaries for villages, including Cockernhoe, in SP2, see 4.9 above that were previously "washed over" by the Green Belt.
SP7 I'm in full agreement with this policy.
4.128 I agree with the NPPF, which supports the argument to exclude the proposed 2,100 new homes East of Luton.
8.5 Policy HS2 I agree with fully.

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5580

Received: 30/11/2016

Respondent: Picture srl

Agent: Keymer Cavendish Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Object to HS2: Emphasis on rented placed high financial burden on sites, cost of rents higher than buying in some developments.

Full text:

See attached

Support

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5650

Received: 21/11/2016

Respondent: Homes England (Herts Team)

Representation:

Support for HS2:
- the overall affordable provision could potentially be exceeded with the provision of Starter Homes as an affordable product

Full text:

See attachment

Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5954

Received: 24/11/2016

Respondent: Hitchin Town Action Group (HTAG)

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Support for:
- the approach and target percentages, including omission sites for under 10 homes to enable smaller local builders to be involved.
- HS2c.ii. : supporting text referring to such mechanisms (para. 8.10) relates to reviews of viability, not to security for occupiers.
- HS2 c.ii. should be deleted since any review could only undermine security for occupiers, and therefore undermine the purpose of the policy.
- Policy D1(a)7 for developments with a mixture of land uses, forms of tenure and built form - policy HS2 and para 5.29 alone will not achieve the economically and socially sustainable developments

Full text:

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Attachments:

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 5976

Received: 29/11/2016

Respondent: F and P Property Management

Agent: Rapleys LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Object to HS2: No reference to viability, criterion c does not take individual site circumstances into account.

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6117

Received: 21/11/2016

Respondent: Rumball Sedgwick

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Object to HS2: Threshold for smaller sites unclear

Full text:

See attached

Object

Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 6624

Received: 29/11/2016

Respondent: Bellcross Company LTD

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Object to HS2: Criterion a should refer to viability, site specific circumstances to be taken into account, criterion c too specific and should be deleted

Full text:

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