Representation to Draft Local Plan (Regulation 18) Consultation

Policy HSG2 - Affordable housing

The consultation has not made a Local Plan Viability Assessment (LPVA) publicly available.  There is therefore no evidence demonstrating that the affordable housing requirements proposed viable.

We would highlight that the respondents were surprised that a Planning Authority would choose to publish a (Regulation 18) Local Plan without having ascertained that the policies within it are deliverable. We advised that by limiting scrutiny of the Local Plan Viability Assessment to the Regulation 19 consultation the Council is reducing the opportunities for comment on a crucial element of the evidence base and the Local Plan would be less robust as a consequence.

We would highlight that Paragraph 58 of the NPPF states that:

…All viability assessments, including any undertaken at the plan-making stage, should reflect the recommended approach in national planning guidance, including standardised inputs, and should be made publicly available.

The PPG makes it clear that Local Plan process is a collaborative process stating that ‘It is the responsibility of plan makers in collaboration with the local community, developers and other stakeholders, to create realistic, deliverable policies. Drafting of plan policies should be iterative and informed by engagement with developers, landowners, and infrastructure and affordable housing providers (Paragraph: 002 Reference ID: 10-002-20190509). 

By limiting the opportunities for comment of the Local Plan Viability Assessment we are of the view that the Council has deviated from national guidance and the Local Plan is not considered positively prepared, justified, effective and crucially is consistent with national policy.