While Barwood Land support the Council’s objectives to tackling climate change, and introducing new measures to do so, this has to be done in accordance with the requirements of the Local Plan process.
The National Planning Policy Framework (NPPF) requires Local Plans to include a viability assessment to ensure policies are feasible and deliverable. As the current Local Plan was adopted in 2017 it did not include a viability assessment.
While it is noted that the viability assessment for the DPD has included consideration of current anticipated costs for additional policies, including accessibility, EV charging, biodiversity net gain, CIL and S106 this does not include any assessment of additional requirements which may come through the Local Plan Review.
In this context we believe that while it is helpful to consider additional policy requirements this should be done in line with the Local Plan Review process to ensure the policies are viable in the context of additional amendments to the Local Plan.
In addition the assessment does not appear to give consideration to potential carbon offset costs in the scenario where development may not be able to achieve net zero onsite. To ensure the assessment is robust additional scenarios should be tested to consider the costs of offsetting and that impact on viability.
Furthermore in reviewing the viability assessment there is a mismatch between the Benchmark Land Values (BLV) stated in the report in Section 4.49 and the BNP values noted in the assessment tables in Section 6. In some cases this will both negatively and positively impact on the viability results. This needs reviewing to ensure the results of the assessment are correct.
Section 6 of the viability assessment clearly shows that policies of the DPD will have a negative impact on land values for residential development, for the mid-range value price point (E) the appraisal shows a negative impact for medium, large scale housing as well as most of the flatted schemes assessed. This shows that without a reduction in costs in other areas, i.e. the reduction in affordable housing provision in the majority of cases the policies are not viable for residential development.
We note that the viability report expects costs to reduce over time, and we agree, however for this to occur the supply chain and skills to implement some systems, for example heat pumps needs time to become established. This is a significant reason as to why the Future Homes Standard (FHS) sets out the timeframe of 2025, to allow this to develop and costs reduce.
In this context we believe the DPD is premature and should be reconsidered in terms of its viability in conjunction with the Local Plan Review. Furthermore Section 6 of the viability assessment shows that the policy requirements are not currently viable without significant reductions in costs from other areas, i.e. affordable housing. This suggests that the Council are proposing to introduce local standards that fail to meet the viability tests of the NPPF.