Local Plan 2036: Issues and Options Stage

Document Section 1. North Somerset Local Plan 2036: Issues and Options Document Potential new policy areas Q41. Do you have any views on the review of affordable housing policies? [View all comments on this section]
Comment ID 9138657//7
Respondent Home Builders Federation Ltd (… [View all comments by this respondent]
Response Date 12 Dec 2018
Comment

The new Local Plan should set out the level and type of affordable housing provision required together with other necessary infrastructure but such policies should not undermine the deliverability of the Local Plan (2018 NPPF para 34). Viability assessment is highly sensitive to changes in its inputs whereby an adjustment or an error in any one assumption can have a significant impact on the viability or otherwise of development. The cumulative burden of policy requirements should be set so that most sites are deliverable without further viability assessment negotiations (2018 NPPF para 57). It is important that the Council understands and tests the influence of all inputs on viability as this determines whether or not land is released for development. The Harman Report highlighted that "what ultimately matters for housing delivery is whether the value received by land owners is sufficient to persuade him or her to sell their land for development".

The HBF have objected to Policy 3 : Affordable Housing of the WoE JSP which proposes a minimum target of 35% affordable housing on sites of 5 or more dwellings. As set out in the HBF representation to the WoE JSP consultation the proposed site threshold of 5 or more dwellings is unjustified and inconsistent with national policy. Furthermore insufficient viability testing has been undertaken. The Council is reminded that if the new Local Plan is to be compliant with the NPPF then development should not be subject to such a scale of obligations and policy burdens that viability is threatened.

The Council’s definition of affordable housing should be aligned with the Government’s Affordable Housing definition set out in the 2018 NPPF.

 

Summary
should set out level and type of affordable housing
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