Object

Representation ID: 9991

Received: 27/07/2022

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

DM1 is unsound is it is unjustified
19. The HBF is concerned that the affordable housing requirements set out in DM1 could have a significant impact on viability of development whilst also undermining the Council’s ability to deliver a mix of affordable housing tenures. The Council’s Viability Assessment acknowledges that development viability across its urban areas is challenging with few typologies being able to show policy compliance. However, the HBF are also concerned that the Council’s Viability Assessment of some greenfield development could also be compromised by the additional costs being placed on it through national and local planning policy. It is also important to note that increasing build costs faced by the industry will make meeting the full suite of policies in the local plan in addition to requirements of national policy even more difficult.
20. The conclusions in the Viability Assessment are that there is no single level of affordable housing provision where it can be said most schemes are viable. The HBF would not disagree with this statement and welcome the recognition in DM1 that the requirements of this policy can be varied where they make development unviable. However, one area in which the Council could make a change to DM1 that would potentially improve viability is being more flexible upfront with regard to the tenure mix on development.
21. At present DM1 effectively removes the ability to deliver much needed shared ownership accommodation in order to deliver First Homes and social/ affordable rented properties. We recognise that Councils are required to deliver 25% of affordable housing as First Homes but in areas such as Bedford even with a 50% discount this may not be possible for many of those in housing needs. Currently, shared ownership can be sold at 25% equity share or less compared to the proposed 50% in the proposed First Homes policy meaning a mortgage for families will be more out of reach going forward as many use the 25% initial equity share to get on to the property ladder and eventually work up to more whilst aspiring to come out of affordable housing.
22. The current tenure split in Bedfordshire Borough in Policy 58S of the Local Plan 2030 allows for 78% rent (social and/or affordable rent) and 22% other affordable tenures (i.e. shared ownership). This means that Registered Providers can offer on the full affordable housing provision, but in the new proposals they would only be able to provide rented tenures reducing much needed and popular shared ownership housing from those in need. We consider the proposed tenure mix that will effectively remove the Council’s ability to provide shared ownership products is short sighted. The proposed tenure split will penalise many first-time buyers especially young families who rely on shared ownership to be able to buy their first family home. This could further exacerbate affordable rent waiting lists in the borough and increase the need for this tenure putting more pressure on the Local Authority.