MM37.
Object
Joint Local Plan Main Modifications
Representation ID: 22430
Received: 18/04/2023
Respondent: Baylham Parish Meeting
Legally compliant? Yes
Sound? No
Clause 2 is all embracing with no caveats
There is no explanation of ‘well connected’,
there is no mention of relationship to settlement boundaries and
there is no mention of impacts on landscape, heritage, etc ie it should read - ..........size to it and is in compliance with all other relevant policies of the Plan.
Clause 2 is all embracing with no caveats
Object
Joint Local Plan Main Modifications
Representation ID: 22661
Received: 03/05/2023
Respondent: Pigeon Investment Management Ltd
Agent: Turley
Legally compliant? Yes
Sound? No
Pigeon is generally supportive of a Policy which offers flexibility for proposals outside the built-up area and provides a positive opportunity to meet housing need as a rural exception in line with the guidance in the NPPF. However, Pigeon raises an objection to the Policy as currently drafted on the basis that the Policy is not ‘consistent with national policy’. To be found sound, the policy needs to be drafted so that it recognises the full range of affordable tenures as set out in NPPF Annex 2 and remove the cap of 35%, ensuring communities flexibility in delivering community-led schemes.
Pigeon considers that the addition of a footnote to identify the housing tenures and a modification to remove ‘35%’ can address their objections.
Pigeon continues to be generally supportive of a policy which offers flexibility for proposals outside the built-up area and provides a positive opportunity to meet housing need as a rural exception, in line with the guidance in the NPPF.
However, to be found sound, Part ‘3’ of the Policy needs to be drafted so that it recognises the full range of affordable tenures as set out in NPPF Annex 2 in line with Paragraph 62 which include affordable housing for rent, starter homes, discounted market sales housing and other affordable routes to home ownership for those who are not able to achieve home ownership through the market.
In order to deliver genuinely community-led housing schemes, which respond to local need, it is not justified for the Councils to include a limit on the ratio of affordable to market housing delivered on rural exception sites. Such matters will be dependent on site/scheme specifics. As such, the policy is not justified in setting a maximum cap of 35% market housing. It should be for each scheme to demonstrate the level of affordable and market housing it can deliver and therefore be assessed on its own merits. The 35% is an arbitrary figure, which should be removed in order to make this policy sound, ensuring communities have complete flexibility in delivering community-led schemes.
Support
Joint Local Plan Main Modifications
Representation ID: 22701
Received: 03/05/2023
Respondent: Artisan PPS Ltd
Artisan supports the change in approach to affordable housing policy, i.e. the removal of the duplication that was in SP02 and LP08.
Please see attached document
Object
Joint Local Plan Main Modifications
Representation ID: 22702
Received: 03/05/2023
Respondent: Artisan PPS Ltd
Legally compliant? Not specified
Sound? Not specified
We seek further clarity on what is meant in paragraph 2 by 'well-connected to an existing settlement'. Does this mean adjacent to settlement as suggested by support text 13.23? We note the Criteria for 'well-related' set out in CS20 of the Babergh Core Strategy
(2014):
Please see attached document
Object
Joint Local Plan Main Modifications
Representation ID: 22704
Received: 03/05/2023
Respondent: Artisan PPS Ltd
Legally compliant? Not specified
Sound? Not specified
In paragraph 3, viability is discussed. A development is either viable or it is not. A viability assessment will demonstrate that a development is viable or not. There is no need for the word "convincingly" to be before demonstrate as this implies there is a higher, unspecified threshold that applicants will be expected to meet. Before an applicant proceeds in spending thousands of pounds on a viability assessment particularly in respect of a rural exception site, they will want the requirements to be clear, transparent and for there to be some degree of certainty that the Councils will accept the conclusions. Accordingly, Artisan objects to the words "convincingly".
Please see attached document
Object
Joint Local Plan Main Modifications
Representation ID: 22705
Received: 03/05/2023
Respondent: Artisan PPS Ltd
Legally compliant? Not specified
Sound? Not specified
We object to the 35% upper limit. If more market housing would facilitate more affordable housing in a community, what is the problem?
Please see attached document
Object
Joint Local Plan Main Modifications
Representation ID: 22761
Received: 03/05/2023
Respondent: . Harris Strategic Land Limited
Agent: Richard Brown Planning
Legally compliant? Not specified
Sound? Not specified
In our view, this policy is now inappropriately called ‘community led and rural exception housing’ that, in my 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.
In our view, this policy is now inappropriately called ‘community led and rural exception housing’ that, in my 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.