MM6.

Showing comments and forms 1 to 7 of 7

Object

Joint Local Plan Main Modifications

Representation ID: 22449

Received: 25/04/2023

Respondent: Mr Alan Lewis

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Could the period in Table 4 and Table 5 be harmonised with the plan period such that the figures for the number of affordable houses are the same as those given on Page 32 SP02 (MM8).

Full text:

Could the period in Table 4 and Table 5 be harmonised with the plan period such that the figures for the number of affordable houses are the same as those given on Page 32 SP08 (MM8).

Object

Joint Local Plan Main Modifications

Representation ID: 22689

Received: 03/05/2023

Respondent: Artisan PPS Ltd

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Whilst we welcome the inclusion of a reference to First Homes, notwithstanding the transitional arrangements, the omission of First Homes in policy is disappointing and Artisan objects on this basis. Just because Part 1 qualifies under the transitional requirements is not by itself a good enough reason to overlook First Homes in this way, particularly as reference to Starter Homes has been retained in the Plan.

Full text:

Please see attached document

Attachments:

Object

Joint Local Plan Main Modifications

Representation ID: 22741

Received: 02/05/2023

Respondent: Llanover Estates

Agent: LRM Planning Ltd

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

Accordingly, our comments herein are reflective of the need to increase the provision of new homes. This representation is to be read in conjunction with separate submissions detailing the contribution
that the following sites could make towards ensuring that the Plan is sound.
a. Land at Churchway, Redgrave; and
b. Land at Mill Road, Botesdale.

We are of the view that these objectives can form an appropriate basis for addressing the key issues
(which include Delivering housing, achieving an uplift in delivery, a growing and ageing population and
high levels of housing need with poor affordability). However, if an appropriate level of housing and
suitable land is not identified and delivered through the plan, then it is inevitable that the plan will fail to
meet its objectives and that the key issues will be exacerbated. It is therefore imperative that an
appropriate level of housing needs are provided for and that a robust supply of land is identified.

Full text:

Please refer to attached representation.

Object

Joint Local Plan Main Modifications

Representation ID: 22757

Received: 03/05/2023

Respondent: . Harris Strategic Land Limited

Agent: Richard Brown Planning

Legally compliant? Not specified

Sound? No

Representation Summary:

This policy is now inappropriately called ‘community led and rural exception housing’ that, in our view is very different to affordable – affordable means less value than normal housing.Community led and rural is about it being something that comes from the community and in a rural location. That is not the same thing.When comparative analysis is undertaken against the affordable housing needs identified in the 2012 SHMA, a shortfall of -1,650 net affordable dwellings has arisen in the 10-year period since 2011/12.The Plan could be made sound by confirming allocations at either Part 1 or confirming general location of development.

Change suggested by respondent:

The Plan could be made sound by confirming allocations at either Part 1 or confirming general location of development

Full text:

• Affordable housing is recognised as one of the key social issues in the plan (page 10)
• House prices on average 11 times the average earnings
• Also recognised in the ‘vision’ (page 14) – reflects how centrally important this is as an issue
• Most of the text on affordable housing is struck out (page 33 and 34).
• Confirmed it will be delivered by s106. No permissive policy which would allow affordable housing to come forward.

There are two main issues,

First, without market housing coming forward, severe doubts about how this would be achieved.

Second, Given the extent of the problem, the plan could have a specific permissive policy to deal with this.

This policy is now inappropriately called ‘community led and rural exception housing’ that, in our view is very different to affordable – affordable means less value than normal housing. Community led and rural is about it being something that comes from the community and in a rural location. That is not the same thing. Affordable housing also often not well located in rural areas, as sometimes those who need affordable housing, are also perhaps less likely to have a private car, and are more reliant upon public transport.

In the 10 monitoring years since the start of the Mid Suffolk Core Strategy Review in 2012, net affordable housing delivery represented just 14% of overall housing delivery, equating to just 229 (net of RtB) affordable dwellings per annum. This compares poorly with the prevailing 35% policy expectation contained in adopted policy H4.

When comparative analysis is undertaken against the affordable housing needs identified in the 2012 SHMA, a shortfall of -1,650 net affordable dwellings has arisen in the 10-year period since 2011/12.

Shortfalls continue to arise against the affordable housing needs identified in the 2017 SHMA, a shortfall of -252 net affordable dwellings has arisen in the seven-year period since 2014/15. Whilst the same can be said for the 2019 SHMA update which demonstrates a shortfall of -141 dwellings in the three years since the start of the SHMA period in 2018/19.

The point made is that no allocation = no provision for affordable.

The Plan could be made sound by confirming allocations at either Part 1 or confirming general location of development

• Affordable housing is recognised as one of the key social issues in the plan (page 10)
• House prices on average 11 times the average earnings
• Also recognised in the ‘vision’ (page 14) – reflects how centrally important this is as an issue
• Most of the text on affordable housing is struck out (page 33 and 34).
• Confirmed it will be delivered by s106. No permissive policy which would allow affordable housing to come forward.

There are two main issues,

First, without market housing coming forward, severe doubts about how this would be achieved.

Second, Given the extent of the problem, the plan could have a specific permissive policy to deal with this.

This policy is now inappropriately called ‘community led and rural exception housing’ that, in our view is very different to affordable – affordable means less value than normal housing. Community led and rural is about it being something that comes from the community and in a rural location. That is not the same thing. Affordable housing also often not well located in rural areas, as sometimes those who need affordable housing, are also perhaps less likely to have a private car, and are more reliant upon public transport.
In the 10 monitoring years since the start of the Mid Suffolk Core Strategy Review in 2012, net affordable housing delivery represented just 14% of overall housing delivery, equating to just 229 (net of RtB) affordable dwellings per annum. This compares poorly with the prevailing 35% policy expectation contained in adopted policy H4.

When comparative analysis is undertaken against the affordable housing needs identified in the 2012 SHMA, a shortfall of -1,650 net affordable dwellings has arisen in the 10-year period since 2011/12.

Shortfalls continue to arise against the affordable housing needs identified in the 2017 SHMA, a shortfall of -252 net affordable dwellings has arisen in the seven-year period since 2014/15. Whilst the same can be said for the 2019 SHMA update which demonstrates a shortfall of -141 dwellings in the three years since the start of the SHMA period in 2018/19.

The point made is that no allocation = no provision for affordable.
The Plan could be made sound by confirming allocations at either Part 1 or confirming general location of development

Object

Joint Local Plan Main Modifications

Representation ID: 22772

Received: 03/05/2023

Respondent: Obsidian Strategic

Agent: Carter Jonas

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

The identified annual affordable housing need (of 127 dwellings per annum) has been and is expected to be met during the period to 2030, but there is no certainty that this trend would continue during the period 2030 to 2037 when delivery is limited and no additional allocations are anticipated within the Mid Suffolk area in the Part 2 Local Plan. There is a strong case for additional allocations to be required to be made in the Part 2 Local Plan to meet future affordable housing needs in Mid Suffolk.

Full text:

Please see attached document.

Object

Joint Local Plan Main Modifications

Representation ID: 22813

Received: 03/05/2023

Respondent: Taylor Wimpey

Agent: Boyer Planning

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

It is currently unclear how Policy SP02 Affordable Housing, along with Tables 4 and 5, are to be implemented in practice. The policy and supporting text do not indicate whether the affordable housing mix set out in Tables 4 and 5 are a starting point for considerations into the delivery of affordable housing, or whether it is a requirement. Furthermore, the policy text does not refer to Table 4 and 5, increasing the uncertain weight these tables have in any decision.

Change suggested by respondent:

The policy and supporting text should be reworded to
clearly state the weight these two tables should carry in decision making in the Districts. The issue of what weight the tables containing each District’s affordable housing mix was raised in our representations for the Regulation 19 consultation.

Full text:

Please see attached document.

Object

Joint Local Plan Main Modifications

Representation ID: 22861

Received: 03/05/2023

Respondent: Manor Oak Homes

Agent: Carter Jonas (Cambridge)

Legally compliant? Not specified

Sound? Not specified

Representation Summary:

We note that paragraph 4.1 of the Babergh and Mid Suffolk Joint Annual Monitoring (AMR) Report 2021- 2022 (December 2022) states that the “delivery of housing and affordable housing remains a key priority".Given that the annual affordable housing requirement has not been met in recent years, and the lack of evidence to demonstrate that affordable housing would be delivered in the later years of the plan period., we consider that there is a strong need for the Plan to be amended to make provision for housing allocations in Mid Suffolk in the Part 2 Local Plan.

Change suggested by respondent:

Given that the annual affordable housing requirement has not been met in recent years, and the lack of evidence to demonstrate that affordable housing would be delivered in the later years of the plan period., we consider that there is a strong need for the Plan to be amended to make provision for housing allocations in Mid Suffolk in the Part 2 Local Plan.

Full text:

MM6 (paragraphs 07.03 – 07.09):
The supporting text includes reference to both the Babergh and Mid Suffolk Affordable Housing Mix Tables.
We note that paragraph 4.1 of the Babergh and Mid Suffolk Joint Annual Monitoring (AMR) Report 2021- 2022 (December 2022) states that the “delivery of housing and affordable housing remains a key priority”.
Tables 4 to 18 in the AMR show the housing figures for both Babergh and Mid Suffolk for the current and previous AMR years. Where data is available, they also show the number / percentage of these that were delivered as affordable homes and, the number/percentage that came forward as windfall development.(please see attachment)
*Completion figures in 2021-22 may be higher than average due to on-site monitoring restarting following COVID-19 preventing checks from taking place in 2020 and 2021.
For Mid Suffolk, the overall profile of affordable housing appropriate to meet the population over the Plan period derived from Local Housing Need is 22.7%, and for Babergh the figure is 26.8%.
It is evident from the above tables that neither Authority has been satisfying its affordable housing delivery requirement.
Furthermore, the AMR acknowledges that not every development will deliver affordable housing, therefore the policy requirement will need to exceed this in order to deliver this need.
Given that the annual affordable housing requirement has not been met in recent years, and the lack of evidence to demonstrate that affordable housing would be delivered in the later years of the plan period., we consider that there is a strong need for the Plan to be amended to make provision for housing allocations in Mid Suffolk in the Part 2 Local Plan.
Our Client’s land at Haughley (east of Steggall Road) is one such suitable site.

Attachments: