BASE HEADER

Yes

ID sylw: 108369

Derbyniwyd: 07/03/2025

Ymatebydd: Mackenzie Miller Homes

Asiant : Lichfields (Birmingham)

9.1 Mackenzie Miller Homes agrees with the approach laid out in Draft Policy Direction 10 as
this is in line with Paragraph 63 of the NPPF which 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.
9.2 Additionally, 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.” As such, Mackenzie Miller Homes
agrees that the SWCs should have regard to the latest evidence in drafting policies relating
to housing tenure and type in due course, in accordance with the NPPF.
9.3 Furthermore, 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 is clear that:
9.4 “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.”
9.5 In Paragraph 72, the NPPF is also clear that planning policies should have regard to the
economic viability of sites. Paragraph 35 states that planning policies should not undermine
the deliverability of the Local Plan. Importantly, 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.
9.6 In this respect, it is recognised that the SWCs have not yet specified a proposed affordable
housing requirement. The PPG4 clearly states that the SWLP should aim to meet as much of
its identified affordable housing needs as possible, although it is not obligated to fulfil these
needs entirely.5 Therefore, it is crucial for the SWCs to test various requirements through
the Viability Assessment to ensure that the overall deliverability of the SWLP is not
compromised (Para 34). This is especially important for allocations within the Green Belt,
considering the NPPF’s ‘Golden Rules’ (Paras 67, 68, and 156a).
9.7 Nevertheless, Mackenzie Miller Homes 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. In Paragraph 82(d), the NPPF is clear that planning policies should be
flexible enough to adapt to unforeseen circumstances and changing economic conditions. Therefore, Mackenzie Miller Homes 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.”