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ID sylw: 108063

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

The SWLP should define and distinguish between CIL and S106 agreements to make clear developers shouldn’t contribute to the same items through both. It should also be made clear that contributions should be sought only to meet needs generated by a development, not to remedy existing deficiencies. Obligations must meet the three tests set out in Paragraph 58 of the NPPF.

The policy direction doesn’t refer to viability considerations. The SA doesn’t recognize the impacts of this omission on Objectives 9 and 11. NPPF Paragraph 35 is clear that polices should not undermine the deliverability of the plan. The Councils must undertake a viability assessment as part of the plan-making process, in line with the National Planning Practice Guidance (NPPG), to ensure contributions for infrastructure would not undermine the viability of development on allocated sites. The policy should acknowledge that applicants may provide a viability assessment at application stage

The policy should acknowledge that applicants may demonstrate the need for a viability assessment at the application stage, as per Paragraph 59 of the NPPF. This would ensure the policy is fully consistent with national policies, and that the plan is effective and deliverable.