Policy 7.5: Affordable Housing

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Comment

Draft Local Plan

Representation ID: 13151

Received: 24/02/2016

Respondent: Alexandra Hammond

Representation Summary:

I don't think the 35% minimum of affordable housing goes far enough given that that will include social housing. At the end of 2012 there were around 1000 people on the social housing waiting list. The plan is for a little over 5000 new homes, so around 20% should be for social housing. This leaves only 15% for "affordable" homes. I expect the 35% also includes the sheltered housing that will need to be replaced.
More affordable properties (if not all properties) should be offered to people with a strong local connection first.

Full text:

To whom it may concern,

Firstly, thank you for giving the community the opportunity to find out about and comment on the council's plans for our town. I think it would be useful for residents to have a summarised version as at over 200 pages long it is more than most people are going to be willing to peruse. I have done my best to read as much as I can in one evening and shall comment on the points I consider most important. I welcome the drop in events being held and I hope to attend. I am one of the unfortunate residents who has missed the boat when it comes to buying a property in Brentwood, and possibly even Essex. I grew up in Brentwood as have many generations of my family before me.

With the exception of the land off Doddinghurst Road on either side of the A12, I agree to the proposals for the building of more properties. I think the land by Doddinghurst Road would be better used to provide a slip road giving access to the A12 at that point. It would reduce the traffic heading through Brentwood town centre and possibly open up opportunities to build dwellings in Pilgrims Hatch and further north in the borough without impacting so much on traffic through the town. I expect this would not be a popular suggestion if it is even possible!

Your plan doesn't make the definition of the term "intermediate" clear. Would this be "affordable" properties such as shared ownership and Help to Buy? A household of two people earning the average wage of £26,500 (perhaps teachers or nurses) with two dependants under 18 could perhaps borrow £225,000. Will there be family homes which would be affordable to that kind of family? I recently called Help to Buy East and South East to get an indication of the value of the property my husband and I could purchase using the Help to Buy Equity Loan scheme. I was told we could buy a property in the region of £210,000 which was disappointing given that we would require a family sized home and for that in Essex the minimum cost would be around £260-270k for a new build. Given that Brentwood has very high house prices compared to other towns in Essex I am concerned that "affordable" homes will still be out of the reach of many of the town's residents, including ourselves. I was very excited when I first heard of the Government's new Starter Homes scheme, however when I realised that the scheme had a long way to go before being finalised and available for use I was very disappointed, as my husband will have passed the cut off age of 40 by that time. Maybe it may be an option for my children to purchase a home in 15 years or so!

I don't think the 35% minimum of affordable housing goes far enough given that that will include social housing. At the end of 2012 there were around 1000 people on the social housing waiting list. The plan is for a little over 5000 new homes, so around 20% should be for social housing. This leaves only 15% for "affordable" homes. I expect the 35% also includes the sheltered housing that will need to be replaced. I understand that the developers want to maximise their profits and I'm sure if all the properties build were sold at market value they would sell with no problems, however this wouldn't be right for the community. Another thing that is very important for me is that the more affordable properties (if not all properties) are offered to people with a strong local connection first, but I from what I have read something is in place to ensure this happens. I know many people are moving out from London as the city becomes even more affordable and it would be pretty galling if these families were snapping up our "affordable" homes.

I also think that the ratio of 1,2,3 and 4 properties should be reconsidered. Given that families on the waiting list for social housing are waiting longer for 3 bedroom properties than for smaller ones it makes me think the need for larger properties is high.

I recently enquired about the homes to be built on the old Warley Adult College site and the developer informed me that the flats would not be eligible for the scheme and there was no guarantee that the houses would be part of the scheme either. This is because according to them the terms of Right to Buy state that there must be no longer than 6 months between reservation and completion. Do you think this could be an issue with providing other Help to Buy homes in the proposed developments? How could this be prevented?

I am intrigued by the 5% self build allocation on larger developments. How would somebody get involved with that? Would you be looking for people to set up a Community Land Trust?

There isn't a huge amount of detail said in the draft plan regarding the William Hunter Way improvements. I agree with the general consensus that a cinema would be a great asset to the community and should be built on the site. My main concern would be how to provide enough parking to replace the spaces lost by the building. Would there be underground parking or perhaps rooftop parking similar to The Brewery in Romford? If Lidl is to go ahead with opening a store at Wates Way then perhaps another supermarket on the William Hunter Way site would not be necessary.

I was recently searching for part time office based job in Brentwood, which was not that easy due to the lack of jobs being advertised. Any opportunity to create more jobs in the town and reduce the need for commuting can surely only be a good thing.

That is all the feedback I have for now. I hope that you can address my concerns.

Comment

Draft Local Plan

Representation ID: 13152

Received: 24/02/2016

Respondent: Alexandra Hammond

Representation Summary:

The ratio of 1,2,3 and 4 properties should be reconsidered. Given that families on the waiting list for social housing are waiting longer for 3 bedroom properties than for smaller ones it makes me think the need for larger properties is high.

Full text:

To whom it may concern,

Firstly, thank you for giving the community the opportunity to find out about and comment on the council's plans for our town. I think it would be useful for residents to have a summarised version as at over 200 pages long it is more than most people are going to be willing to peruse. I have done my best to read as much as I can in one evening and shall comment on the points I consider most important. I welcome the drop in events being held and I hope to attend. I am one of the unfortunate residents who has missed the boat when it comes to buying a property in Brentwood, and possibly even Essex. I grew up in Brentwood as have many generations of my family before me.

With the exception of the land off Doddinghurst Road on either side of the A12, I agree to the proposals for the building of more properties. I think the land by Doddinghurst Road would be better used to provide a slip road giving access to the A12 at that point. It would reduce the traffic heading through Brentwood town centre and possibly open up opportunities to build dwellings in Pilgrims Hatch and further north in the borough without impacting so much on traffic through the town. I expect this would not be a popular suggestion if it is even possible!

Your plan doesn't make the definition of the term "intermediate" clear. Would this be "affordable" properties such as shared ownership and Help to Buy? A household of two people earning the average wage of £26,500 (perhaps teachers or nurses) with two dependants under 18 could perhaps borrow £225,000. Will there be family homes which would be affordable to that kind of family? I recently called Help to Buy East and South East to get an indication of the value of the property my husband and I could purchase using the Help to Buy Equity Loan scheme. I was told we could buy a property in the region of £210,000 which was disappointing given that we would require a family sized home and for that in Essex the minimum cost would be around £260-270k for a new build. Given that Brentwood has very high house prices compared to other towns in Essex I am concerned that "affordable" homes will still be out of the reach of many of the town's residents, including ourselves. I was very excited when I first heard of the Government's new Starter Homes scheme, however when I realised that the scheme had a long way to go before being finalised and available for use I was very disappointed, as my husband will have passed the cut off age of 40 by that time. Maybe it may be an option for my children to purchase a home in 15 years or so!

I don't think the 35% minimum of affordable housing goes far enough given that that will include social housing. At the end of 2012 there were around 1000 people on the social housing waiting list. The plan is for a little over 5000 new homes, so around 20% should be for social housing. This leaves only 15% for "affordable" homes. I expect the 35% also includes the sheltered housing that will need to be replaced. I understand that the developers want to maximise their profits and I'm sure if all the properties build were sold at market value they would sell with no problems, however this wouldn't be right for the community. Another thing that is very important for me is that the more affordable properties (if not all properties) are offered to people with a strong local connection first, but I from what I have read something is in place to ensure this happens. I know many people are moving out from London as the city becomes even more affordable and it would be pretty galling if these families were snapping up our "affordable" homes.

I also think that the ratio of 1,2,3 and 4 properties should be reconsidered. Given that families on the waiting list for social housing are waiting longer for 3 bedroom properties than for smaller ones it makes me think the need for larger properties is high.

I recently enquired about the homes to be built on the old Warley Adult College site and the developer informed me that the flats would not be eligible for the scheme and there was no guarantee that the houses would be part of the scheme either. This is because according to them the terms of Right to Buy state that there must be no longer than 6 months between reservation and completion. Do you think this could be an issue with providing other Help to Buy homes in the proposed developments? How could this be prevented?

I am intrigued by the 5% self build allocation on larger developments. How would somebody get involved with that? Would you be looking for people to set up a Community Land Trust?

There isn't a huge amount of detail said in the draft plan regarding the William Hunter Way improvements. I agree with the general consensus that a cinema would be a great asset to the community and should be built on the site. My main concern would be how to provide enough parking to replace the spaces lost by the building. Would there be underground parking or perhaps rooftop parking similar to The Brewery in Romford? If Lidl is to go ahead with opening a store at Wates Way then perhaps another supermarket on the William Hunter Way site would not be necessary.

I was recently searching for part time office based job in Brentwood, which was not that easy due to the lack of jobs being advertised. Any opportunity to create more jobs in the town and reduce the need for commuting can surely only be a good thing.

That is all the feedback I have for now. I hope that you can address my concerns.

Object

Draft Local Plan

Representation ID: 13557

Received: 22/03/2016

Respondent: Ms Linda Campbell

Representation Summary:

Greenbelt should be kept for further generations
Roads overloaded to standstill already
No evidence of needing this housing where is proof?
Unsustainable with our failing roads as they are
This is not Affordable housing for my generation
I disagree with carving up greenbelt to make one huge urban sprawl of concrete

Full text:

I am objecting as I live in a village we have greenbelt that needs to be saved ,we do not need more housing & there is no evidence that we need LDP ,supposed this has come from Government ,where is the proof that this housing is needed? I have recently become a road user ,passing my driving test yet I can not get either out of my driveway or to me local station or to my local town to work or college ,this is due to standstill traffic on Billericay road and/or the A128, no brainer more housing more traffic =more pollution ,Basildon hosp ,Gp &schools can not cope the strain on these is already immense & so I object

Object

Draft Local Plan

Representation ID: 14021

Received: 08/04/2016

Respondent: Glenda Fleming

Representation Summary:

Object. A rigid approach is not appropriate for all sites as it depends on the local character of the area and neighbouring properties could be adversely affected, leading to planning objections and delays. It is also inappropriate for rental housing to be exactly the same specification as open-market owner-occupied housing. Pepperpotting of social housing throughout a development is not always the solution
favoured by RSLs.

Full text:

See two attached comment sheets.

Attachments:

Comment

Draft Local Plan

Representation ID: 14196

Received: 04/04/2016

Respondent: Mr Michael Jarvis

Representation Summary:

I see no mention of how the following will be effectively embraced:
- Affordable housing for those on low income

Full text:

I see no mention of how the following will be effectively embraced:
- Affordable housing for those on low income
- Appropriate independent accommodattion for those with a variety oif disabilities- not everyone lives in group homes
- Parking issues that will result by building a large number of flats in and around the town centre and on existing parking spaces
- How to revitalise the High Street - it is currently suffering from decay in quality shops - it is slowly turning into a haven of hairdressers, charity shops, and lower end chain restaurants. I see no attempt at upping the quality
- How will "Night Time Economy" will be radically improved - it is a steep hill to climb from drunken gangs to a safe environemtn for all the family. The High Street is regarded as a "no go" area at night
- The report has a great deal of hyperbole and wishful thinking- I see little hard evidence on some of the claims. Whenever claims are made garding a number of the above issues a "get out" clause is immediately given shaying why things will not happen.

Attachments:

Comment

Draft Local Plan

Representation ID: 14420

Received: 18/04/2016

Respondent: Doddinghurst Parish Council

Representation Summary:

Policy 7.5 g (i). The Parish Council understands the drive for affordable housing but is nevertheless concerned about the possibility of unintended consequences of this policy clause which has the laudable intent of making new homes truly affordable in Brentwood, but, the Parish Council suspects that this approach could backfire badly in one of two ways, by either
(i) Deterring development entirely, or
(ii) By resulting in homes built to every minimum standard in the book in a race to the bottom in design with microscopic footprints and amenity space. In short, homes that are affordable but quite undesirable.

Full text:

1. The Parish Council considers that the proposed document and its supporting material, the Site Allocation and Pattern Maps, are well-constructed and contain well thought through and comprehensive policies that the Parish Council supports overall.
The Parish Council would like to congratulate the Borough Planning team working on this project for their hard work in producing this Draft Document for consultation.

2. A number of detailed comments, observations and requests are made as follows:
Recommendations for improvement. (NB. Reference in this paper to the "LDP" means the Brentwood Draft Local Plan (2013 - 2033):

2.1 Whilst mapping of the Parish Council boundaries is in the Pattern book on Page 18 it isn't referenced anywhere in the LDP, but knowledge of the Parish Council boundaries would help better inform the reader and make some of the statements easier to understand. For example paragraph 9.58 on Page 142 is being interpreted by many as meaning the whole of the area of the Parishes listed (they are called settlements in the document) are urban when it is the established residential areas that are being referred to as an urban classification and excluded from the Green Belt. Clear understanding is not helped by the fact that the proposals map (Fig 9.2) isn't referenced in 9.58 and you have to read the glossary to understand what a proposal map is. Parish Councils are referred to on page 16 of the LDP para 2.40, so perhaps a reference to the mapping of the Parish Council areas could be included here?

2.2 Errors observed on Page 42 of the LDP. Hook End and Wyatts Green are not separate villages as implied in the "Cat 4 smaller villages" table but are wards of Blackmore Parish Council and are within the Blackmore Parish Council area. Stondon Massey and Navestock (which are separate parished areas) are missing altogether.

2.3 Page 93 of the LDP. The Willows, Place Farm Lane is within the boundary of Doddinghurst Parish Council and therefore the address should be Doddinghurst and not Kelvedon Hatch. This error is also repeated in the pattern book on page 30.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.5 LDP Policy 9.9 clause l. (NB has a stray "m" at the beginning). The Parish Council support the preservation of Bungalows but this particular clause relates only to the redevelopment of dwellings in the Green Belt. LDP Para 7.65 reflects on the fact that the population is aging but the need is not simply for specialist housing for the elderly. LDP Para 2.34 explains that there is a growth in numbers of the elderly in the Borough and para 9.76 expressly mentions giving older people the opportunity to downsize. This is no less so than in the villages, where there is a need for more bungalows for conventional retail purchase - not affordable or sheltered homes, to allow for the "churn" of people in the villages - for the elderly to "downsize" and families to "upsize" to the properties that now too large, or with gardens and stairs that are no longer an asset but a liability, for the aged. With the emphasis on affordable housing everywhere in the LDP the need for new bungalows has been somewhat squeezed out and there is no clear pathway in the policy document to facilitate this key provision - but with all the Green Belt safeguards that the Borough Council have rightly included. Can 9.76 perhaps reference approved Neighbourhood Plans as evidence of such requirement as well as the Council's Strategic Housing Market Assessment and local housing strategy?

2.6 LDP Policy 7.5 g (i). The Parish Council understands the drive for affordable housing but is nevertheless concerned about the possibility of unintended consequences of this policy clause which has the laudable intent of making new homes truly affordable in Brentwood, but, the Parish Council suspects that this approach could backfire badly in one of two ways, by either
(i) Deterring development entirely, or
(ii) By resulting in homes built to every minimum standard in the book in a race to the bottom in design with microscopic footprints and amenity space. In short, homes that are affordable but quite undesirable.

2.7 Green Belt and its development by stealth.
(i) The "Agricultural Business". One of the loopholes exploited by land speculators in the past and present (and we can point to several examples), is for an individual/ company to purchase a large green belt field, or either have (or purchase) an area of land behind their property, and then to set up a small scale rural business such as, e.g.: a stable; an egg farm; a mushroom farm etc. A typical approach will be where, sooner or later, an application will be lodged for some form of building annex where a person can live in order to tend "The Farm" and then in due course for this to be followed by an application for a full scale residential development. Once the residence is completed, the business soon seems to become unviable and ceases to trade, and the dwelling is sold for residential purposes.
(ii) As well as this approach we see the more clandestine method adopted in quiet backwaters where large screens or fences are put up to camouflage the field behind which small dwellings are constructed and then after 10 years a certificate of lawfulness is requested to make the development legal.
The question is, is there anything that can be done in the LDP to close these loopholes that are regularly exploited?

3. Consultation response approval.
The contents of this response to the Consultation detailed above has been agreed by the Parish Council have been as discussed at a meeting to review the LDP on the 7th January 2016.

Attachments:

Comment

Draft Local Plan

Representation ID: 14790

Received: 21/04/2016

Respondent: Mr Jon Bright

Representation Summary:

On the question of affordable housing (Policy 7.5), I am aware that developers will at times seek to avoid any affordable quotas, instead making a payment for the Council / HA to develop elsewhere. I think this leads to less mixed communities and should be resisted as far as possible.

Full text:



I was pleased to be able to attend your presentation at the Ingatestone Community Centre on 22nd February. I have since been able to download the Draft Plan and read some parts of it. Overall it seems very comprehensive, well-reasoned and informative.
As a former local government housing officer for some 30+ years, I very much support the provision of more genuinely affordable housing for the Borough in general and Ingatestone in particular. The sites earmarked within Ingatestone seem to me to be good & appropriate options.
Of course the definition of "affordable" is somewhat contentious & at times Orwellian - i.e affordability = unaffordabilty. The Government seems to regard affordable as being something like 80% of market rents for the rented sector, although their whole housing policy now seems to lean overheavily towards owner-occupation with little regard for those that are unable or do not wish to buy. My view is that there is a definite need for more sub-market rented homes, provided by Housing Associations or dare I say it the local authority itself.
Obviously in an ideal world, every bit of open countryside would be protected (I say this as a keen rambler in the countryside & elsewhere), and places like Ingatestone Garden Centre (IGC) wouldn't be closing. But as IGC has closed down that seems to be an ideal site for genuinely affordable rented housing and/or low-cost owner-occupied dwellings - ideally affordable in perpetuity and perhaps with a reasonable priority for local people. I think somewhere like Ingatestone needs an increase in that type of provision. What it doesn't need is more footballers' mansions, or developments like that at Trueloves Lane (where, hilariously, the new homes were marketed as affordable with a price tag of some £1.5 million!). Without more affordable housing, where do people expect the next generation to live? Kids living with parents until they're about 50? Or moving to Scunthorpe (for example) just to find somewhere to live.
Reading a recent article in "Inside Housing" it was reported that just over 10% of England was currently used for housing. Nationally, to build some 2.5 million homes over the coming years would only take things up to around 12%. So I think we are some way short yet of concreting over the entire countryside, as some fear.
As you state in your report, any new development needs to be appropriate in scale and design for its location, have suitable infrastructure, protect Green Belt as much as possible, have suitable landscape buffers / definable boundaries etc (e.g. between Ingatestone & Mountnessing) and, where affordable housing is included with a scheme, to be well integrated (i.e. avoiding what has been referred to in the media as "poor doors"!).
On the question of affordable housing (Policy 7.5), I am aware that developers will at times seek to avoid any affordable quotas, instead making a payment for the Council / HA to develop elsewhere. I think this leads to less mixed communities and should be resisted as far as possible.
From some of the conversations I overheard at the meeting of 22nd February, I suspect a fair few local residents won't share most of my views, and will probably be in the "nimby" camp, of not building anything anywhere ever. I wonder how many of those objecting are living in developments which were themselves once open land and no doubt subject to similar objections a generation or two ago?
One thing I'd query - in Sections 7.20 /7.21 you refer to 17.1% of local households having someone with a disability / long-term illness, yet only 5% provision for such groups is proposed for new developments.
I remember at one time there was discussion of "lifetime homes" - developing new homes that could be easily adaptable for people in all stages of their life. But these are probably not popular with developers.
To finish on a parochial note, I'm wondering what the plans are for 24 Norton Road, Ingatestone - the former Children & Families Consultation Service offices - which have been empty and boarded up for some months now. I assume this site will be earmarked for housing?
Many thanks.
John Bright CIHCM

Attachments:

Comment

Draft Local Plan

Representation ID: 15108

Received: 26/04/2016

Respondent: Ursuline Sisters

Agent: JTS Partnership LLP

Representation Summary:

Policy 7.5 has had no regard to the provision of 'Starter Homes', as has been set out within the Housing and Planning Bill 2015. Under the Bill, Local Planning Authorities are under a duty to promote the supply of starter homes. It is acknowledged that it is currently unclear whether such a provision is to be made alongside or as part of overall affordable housing provision. However, the Local Planning Authority should acknowledge the Housing and Planning Bill 2015 and give consideration to its likely impacts, and how such requirements are to be dealt with by policy.

Full text:

See attached

Attachments:

Comment

Draft Local Plan

Representation ID: 15247

Received: 29/04/2016

Respondent: Tesco Stores Limited

Agent: GL Hearn

Representation Summary:

Evidently not all schemes will be able to deliver policy-compliant affordable housing provision (taking account of site viability) and some developments will fall below the threshold. Assuming 30% affordable housing delivery with a target of 362 dwellings per annum, 109 affordable homes would be delivered per annum. The plan thus can be expected to meet less than half of the affordable need - providing a clear basis considering higher provision.
The high need for affordable housing clearly points to a need to consider increasing overall housing delivery.

Full text:

See attached

Attachments:

Comment

Draft Local Plan

Representation ID: 15314

Received: 04/05/2016

Respondent: Wiggins Gee Homes Ltd

Agent: David Russell Associates

Representation Summary:

There are uncertainties surrounding the provision of affordable housing as a result of proposed changes to national policy

The owner is willing to include a good proportion of affordable housing in developing Crow Green Lane site (159), even a higher level than the minimum requirement, provided that development of the whole site remains financially viable.

Full text:

See attached.

Attachments:

Comment

Draft Local Plan

Representation ID: 15352

Received: 05/05/2016

Respondent: Countryside Properties

Agent: Colliers International

Representation Summary:

Question whether it would be possible to implement criteria g. (availability at a cost low enough for them to afford, determined with regard to local incomes and local house prices ) in practice given the provisions set out in the Housing and Planning Bill. Anticipated that, once the Bill has been passed, local authorities will be under a duty to promote the supply of starter homes regardless of local needs. We would therefore request justification on how this element of the policy would work in practice, and suggest the wording of this element of the policy will evolve once the Bill has been passed.

Full text:

see attached

Attachments:

Support

Draft Local Plan

Representation ID: 15353

Received: 05/05/2016

Respondent: Countryside Properties

Agent: Colliers International

Representation Summary:

Welcome Section h iii) of the policy, which allows flexibility where proposals cannot viably support the provision of the full affordable housing requirement. We support the opportunity for developers to submit evidence which demonstrates the level of affordable housing that can be provided without jeopardising the viability of the development.

Full text:

see attached

Attachments:

Object

Draft Local Plan

Representation ID: 15605

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Representation Summary:

In supporting text to Policy 7.5, paragraph 7.57 notes that the SHMA suggests a 35% affordable housing target on "all suitable sites" to be justified, subject to viability and the balance of tenure mix. There is no evidence to demonstrate that BBC has undertaken a viability assessment to establish whether a 35% target is viable. This Policy requirement therefore does not accordance with NPPF in that sustainable development requires careful attention to viability and costs in plan-making and decision-taking, and therefore the scale of obligations and policy burdens (such as affordable housing) should not be such that development viability is threatened.

Full text:

See attached.

Attachments:

Object

Draft Local Plan

Representation ID: 15606

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Representation Summary:

Part (e) seeks to require affordable housing standards to be equal to that of market housing in terms of appearance, built quality and materials. With regards to building standards and as stated above, Local Plans should not set local technical standards or requirements relating to the construction, internal layout or performance of dwellings. In addition, whilst the external appearance of affordable units can be sought to be indistinguishable from market dwellings, the internal layout is limited to the requirements of the Affordable Housing Provider.

Full text:

See attached.

Attachments:

Object

Draft Local Plan

Representation ID: 15612

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Representation Summary:

Part (g) bullet (i) of Policy 7.5 advises that affordable housing should be at a cost low enough for eligible households to afford. This is a matter for an Affordable Housing Provider, to be agreed, and such wording is therefore not considered appropriate in a Local Plan policy.

Part (g) bullet (ii) directs that affordable housing should remain at an affordable price for future eligible households. Similarly, this requires agreement with an Affordable Housing Provider or as part of a Section 106 Agreement, and such wording is not considered appropriate in this context.

Full text:

See attached.

Attachments:

Comment

Draft Local Plan

Representation ID: 15805

Received: 11/05/2016

Respondent: Persimmon Homes Essex

Representation Summary:

The policy requires the exact mix to have regards to policy 7.2 however we reiterates our concerns in relation to the use of the two documents (SHMA and Council's Housing Strategy) in determining the most appropriate mix and the consistency in which this policy will be applied to residential development.

There is no reference on the Council's approach to the Starter Homes Initiative. Whilst it is not clear as to how the Government fully intend to implement this approach, Policy 7.5 should have regard to National Policies approach in delivering affordable housing.

Full text:

See attached.

Attachments:

Support

Draft Local Plan

Representation ID: 16113

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Representation Summary:

This policy provides a level of certainty to the developer as to what the Council expects to be achieved on the site, whilst providing flexibility to take into account when site constraints do not allow for a target compliant development.

Full text:

See attached.

Attachments:

Comment

Draft Local Plan

Representation ID: 16145

Received: 16/05/2016

Respondent: Threadneedle Property Investments Ltd

Agent: Barton Willmore

Representation Summary:

The minimum requirement should be removed in lieu of a viability led approach to ensure the requirement for affordable housing is balanced and the delivery of development sites is not stalled, in line with paragraph 173 of the NPPF.

Full text:

See email.

Attachments:

Object

Draft Local Plan

Representation ID: 16149

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Representation Summary:

The evidence base as it relates to affordable housing is out of date. This is being addressed in ongoing work towards an update to the SHMA, published on 15 March 2016. This update needs to address recent government announcements and measures that propose to considerably increase provision. The DLP should consider full objectively assessed need for market and affordable housing, which now needs to reflect the government's latest initiative towards building 400,000 affordable
homes, of which 50% should be starter homes.

Full text:

See attached

Attachments:

Support

Draft Local Plan

Representation ID: 16328

Received: 18/05/2016

Respondent: Ingatestone and Fryerning Parish Council

Agent: Ingatestone and Fryerning Parish Council

Representation Summary:

Strongly support the provision of sufficient high quality affordable housing to meet local needs and unlike those at the True Love site these should be integrated and spread evenly through the site rather than grouped in one area.

Full text:

See attached.

Attachments: