Object

Representation ID: 66246

Received: 24/06/2014

Respondent: Crest Strategic Projects

Agent: d2planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Objections are lodged to the proposed 40% affordable housing provision. This is contrary to the evidence which concludes that 35% affordable housing is a viable level. The purpose of the Plan led system is to provide certainty to developers, landowners etc. If the Council ignore their own evidence and adopt a higher threshold for affordable housing, there will be no guarantee that they would adopt a flexible approach once the 40% threshold was adopted.

This approach is totally contrary to the guidance in the NPPF which requires that viability of affordable housing and other policy requirements of the plan are deliverable and to ensure that these do not render development unsuitable and thus that plans undeliverable. The onus should not be placed on the developer to provide viability but for the Council to ensure that viability has been assessed when arriving at the initial figure for affordable housing within policy. This is in line with the NPPF but also the decision in Blyth Valley DC v Persimmon Homes (North East) limited (2008).

Concerns are also expressed at the content of the viability assessment which underpins the affordable housing policy. It considered that either a number of costs have not been taken into account e.g. biodiversity offsetting, flood mitigation etc or that the figures included within the viability assessment are too low e.g. planning contributions.