BASE HEADER

Yes

ID sylw: 107904

Derbyniwyd: 07/03/2025

Ymatebydd: TERRA

Asiant : Lichfields (Birmingham)

Yes, paragraph 63 of the NPPF states that the size, type and tenure of housing needed for
different groups (including those who require affordable housing) should be reflected in
planning policies. Paragraph 32 states that all policies should be “underpinned by relevant
and up-to-date evidence”, which “should be adequate, proportionate and focussed tightly
on supporting and justifying the policies concerned.” Terra therefore agrees that the SWAs
should have regard to the latest evidence in drafting policies relating to housing tenure and
type in due course, in accordance with the NPPF.
2.84 In addition, Paragraph 16(d) of the NPPF states that policies should be “clearly written and
unambiguous, so it is evident how a decision maker should react to development
proposals.” In addition, Paragraph 34 clearly states that:
“Plans should set out the contributions expected from development. This should include
setting out the levels and types of affordable housing provision required, along with other
infrastructure (such as that needed for education, health, transport, flood and water
management, green and digital infrastructure). Such policies should not undermine the
deliverability of the plan.”
2.85 The NPPF is also clear that planning policies should have regard to the economic viability of
sites (Para 72) and should not undermine the deliverability of the Local Plan (Para 35). Crucially, both the NPPF and PPG are clear that contributions should be tested through the
viability process, so as to ensure that they do not undermine the deliverability of the plan.
2.86 In this regard, it is acknowledged that the SWAs have not quantified a proposed affordable
housing requirement yet. The PPG7 is also clear that the SWLP should seek to meet as much
of its identified affordable housing needs as possible, albeit, the SWLP is not required to
meet its affordable needs in full.8 In this context, it will be critical for the SWAs to test
different requirements through the Viability Assessment to ensure that it would not
undermine the deliverability of the SWLP on the whole (i.e. Para 34) – this will particularly
be the case for allocations within the Green Belt within the context of the NPPF’s ‘Golden
Rules’ (Paras 67, 68 and 156a).
2.87 Notwithstanding the above, Terra would also support the inclusion of a viability caveat
within the future affordable housing policy to enable flexibility where it is required and can
be justified. The NPPF is clear that planning policies should be flexible enough to adapt to
unforeseen circumstances and changing economic conditions (Paragraph 82d). As such,
Terra considers that such a caveat would allow developers to react flexibly to changing
economic circumstances, and suggests the below wording:
“Lower proportions of affordable housing will only be accepted where a viability
assessment, prepared in accordance with national planning policy and guidance, clearly
demonstrates that the full policy requirement cannot be achieved.”