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ID sylw: 106472

Derbyniwyd: 28/02/2025

Ymatebydd: McCarthy Stone and Churchill Living

Asiant : The Planning Bureau Ltd

We would like to remind the Council of the increased emphasis on Local Plan viability testing in Paragraph 58 of the NPPF and that the PPG states that “The role for viability assessment is primarily at the plan making stage. Viability assessment should not compromise sustainable
development but should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the
plan” (Paragraph: 002 Reference ID: 10-002-20190509). The introduction of an embodied carbon policy must not be so inflexible that it deems sites unviable and any future policy needs to ensure this to make sure it is consistent with NPPF/PPG and can justified by the
Council. The viability of specialist older persons’ housing is more finely balanced than ‘general needs’ housing and we are strongly of the view that these housing typologies should be robustly assessed in the forthcoming Local Plan Viability Assessment. Additionally, new development will often be far more sustainable in many circumstances
including building fabric by use of modern methods of construction but also extending beyond that, such as sustainability through optimisation of use of a site and operational use of carbon. Existing foundations of buildings that have reached the end of their life cycle will seldom be practicable for new buildings and particularly so in the case of much needed specialised housing for older people.