BASE HEADER

Yes

ID sylw: 108192

Derbyniwyd: 27/02/2025

Ymatebydd: St Philips

Asiant : Lichfields (Birmingham)

Do you agree with the approach laid out in Draft Policy Direction 10- Providing the Right Tenure and Type of Homes? 2.72 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.” St Philips 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. 2.73 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.” 2.74 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. 2.75 In this regard, it is acknowledged that the SWAs have not quantified a proposed affordable housing requirement yet. The PPG8 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.9 In this context, it will be critical for the SWAs to test different requirements through the Viability Assessment to ensure that the affordable housing requirement 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). 2.76 Notwithstanding the above, St Philips 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, St Philips 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.” 2.77 Notably, this approach would align with SOADC’s approach within the adopted Core Strategy (i.e. Policy CS.18).