B&MSDC Supplementary Planning Documents Consultation

Comment

Representation ID: 23580

Received: 18/06/2024

Respondent: Hopkins Homes

Agent: Mr David Jones

2.1 Strategic Policy 01 (SP01) – Housing Needs
Approach to Open Market Mix

Hopkins Homes support the provision of the table at paragraph 2.1.5 to identify the preferred mix for open market dwellings based on the evidence set out in the Ipswich Strategic Housing Market Assessment (SHMA, 2017 with a partial update in 2019). This provides useful detail that is lacking in the policy and clarifies the Council’s interpretation of the identified need.

Hopkins Homes is, however, concerned that paragraphs 2.1.6 and 2.1.7 appear to suggest that the identified mix will be strictly enforced. Indeed the only allowances for a change from this mix are where it is justified by a localised assessment or where the proposal is for minor residential development. We consider that such a strict enforcement would conflict with Policy SP01 which simply states that the mix of housing “should be informed by the relevant District needs assessment” (emphasis added). A requirement to be informed by is very different from a strict requirement to meet an identified mix.
We also note that the data in the table presents a combined need derived from the separate needs identified in the SHMA for owner-occupied and private rent accommodation. We support this in principle, but given that different parts of the district will have different demand for private rental properties, this further indicates why there is a need for flexibility in how the identified mix is applied. As recognised at paragraph 2.1.15 there could also be other reasons for allowing flexibility relating to site context such as high public transport accessibility, local character and landscape considerations.

2.1.6 The district-wide requirement will be used to inform is the starting point for determining the mix of open-market units on a given scheme. A more localised assessment of need or site context, such as that carried out in support of a made Neighbourhood Plan, may be used to justify a deviation from mirroring the mix recommended by the SHMA.
Local Housing Needs Surveys
Hopkins Homes supports the broad definition of Local Housing Needs Survey provided in paragraphs 2.1.8-2.1.12. This section recognises the importance of using objective data sources to assess need and not just the results of housing surveys of local residents.
2.2 Strategic Policy 02 (SP02) – Affordable Housing
Hopkins Homes is concerned that this section of the SPD fails to provide clarity regarding the requirement/need for discounted home ownership products / First Homes. Our concerns are two-fold:
1.
First Homes: We understand that under the transitional arrangements set out in the First Homes Written Ministerial Statement of 24 May 2021, the national policy requirement for 25% of affordable housing to be provided as First Homes doesn’t apply in Babergh and Mid-Suffolk and will not apply until such a time as the requirement is introduced in a subsequent update of the Local Plan. For the avoidance of doubt, it would be helpful if the SPD explained this. We note that a short explanation is provided at paragraph 3.2, but we consider that this should be expanded upon and included in section 2.2.
2.
Discounted Home Ownership Products: Policy SP02 and its supporting text currently present a confused picture with respect to the need/requirement for discounted home ownership products. The policy states that the tenure mix should be informed by the relevant district needs assessment and the supporting text includes summary tables from the SHMA which identify a need for 24.9% of affordable homes to be discounted home ownership dwellings in Babergh and 18.6% in Mid Suffolk. Despite this, paragraph
07.09 of the supporting text states that “The Councils acknowledge the role that discount home ownership including First Homes and starter homes can play in meeting housing needs, however the Councils’ will seek shared ownership and social / affordable rent provision in the first instance.” The SPD at paragraph 2.2.9 similarly states that “the preferred tenures to be secured via planning obligations are affordable rent and shared ownership”. This lack of clarity does not help housebuilders in designing their proposals and could easily be rectified by the SPD setting out a preferred tenure split for affordable housing. For example, 50% affordable rent and 50% shared ownership.

6. Commuted Sums
There would appear to be an error at paragraphs 6.1.5-6.1.7. The rates quoted in the table at 6.1.5 are different from those included in the worked examples at paragraphs 6.1.6 and 6.1.7.

Comment

Representation ID: 23581

Received: 18/06/2024

Respondent: Hopkins Homes

Agent: Mr David Jones

3.6 Suffolk Coast Recreational Disturbance Avoidance and Mitigation Strategy (RAMS)
In general this section provides a useful summary of the requirement to pay a RAMS contribution and complete the S111 form. It is, however, unclear on the responsibility for preparing the required Appropriate Assessment (AA) referred to at paragraph 3.6.7. Is the applicant required to prepare a shadow AA to be adopted by the Council, or does the applicant simply fill out the form and make the payment?

4. Biodiversity Mitigation Hierarchy and Biodiversity Net Gain
What is required to meet the Councils’ BNG requirements?
Paragraph 4.9 states that Ecological Reports submitted in support of applications will include a GIS layer showing the location and area covered by each habitat type. The only justification provided for this requirement is that it would “enable verification”. It is not standard practice to submit GIS files in support of ecological assessments, nor is this a requirement of relevant legislation and national policy on BNG. We consider that the provision of scaled PDF plans showing the location and area covered by each habitat type and based on topographical surveys (as would normally be expected in support of an application) are more than sufficient to enable verification. There is therefore no reasoned justification to require GIS files contrary to Regulation 8 of the Town and Country Planning (Local Planning) (England) Regulations 2012.
Delivering BNG Off-site
This section would benefit from reference to the Biodiversity Gain Hierarchy set out in Articles 37A and 37D of the Town and Country Planning (Development Management Procedure) (England) Order 2015:
“37A. In this Part, “biodiversity gain hierarchy” means the following actions in the following order of priority— […]
(b)in relation to any onsite habitat which is adversely affected by the development, compensating for that adverse effect by—
(i)habitat enhancement of onsite habitat;
(ii)insofar as there cannot be that enhancement, creation of onsite habitat;
(iii)insofar as there cannot be that creation, the availability of registered offsite biodiversity gain for allocation to the development;
(iv)insofar as registered offsite biodiversity gain cannot be allocated to the development, the purchase of biodiversity credits.” “37D. […] (2) In determining whether to approve a biodiversity gain plan, the planning authority must take into account—
(a)how the biodiversity gain hierarchy is to be applied, and
(b)subject to paragraph (3), where the order of priority specified in that hierarchy is not to be applied—
(i)the reason for that, or
(ii)the absence of a reason.” The above wording clearly sets out the process to be followed in way that we consider is currently lacking in the SPD.