Cyngor Bro Morgannwg
Vale of Glamorgan Council

The consideration of viability and the removal of the arbitrary upper limits on site sizes for allocations in Primary and Minor Rural Settlements will ensure that Policy SP2 meets the third test of soundness (Will the Plan deliver?). The proposed amendment to the wording of Policy SP2 is as follows:

“For the purposes of this policy small scale affordable housing led developments are defined as providing a minimum of 50% affordable housing on sites of circa 25 dwellings in Minor Rural Settlements or circa 50 dwellings in Primary Settlements. The type, scale and mix of affordable housing will be expected to reflect the latest evidence, including specialist older person housing. Proposals which do not meet the minimum 50% affordable housing provision will not be supported.”

Policy SP2 lists Colwinston as a “Minor Rural Settlement” in the settlement hierarchy. Policy SP2 also states that:

“For the purposes of this policy small scale affordable housing led developments are defined as providing a minimum of 50% affordable housing on sites of up to 25 dwellings in Minor Rural Settlements or up to 50 dwellings in Primary Settlements. The type, scale and mix of affordable housing will be expected to reflect the latest evidence, including specialist older person housing. Proposals which do not meet the minimum 50% affordable housing provision will not be supported.”

The RLDP seeks a high proportion of affordable homes alongside other overly prescriptive policies relating to net zero carbon emissions from new dwellings, residential density, and open space provision. In order to achieve these objectives in a deliverable and sustainable way, it is essential that the RLDP provides sufficient flexibility in both policy application and housing mix. Without such flexibility, the cumulative impact of multiple prescriptive requirements risks undermining site viability. A balanced approach is therefore necessary to ensure that the Council’s housing, climate, and place making ambitions can be realised without constraining the delivery of much needed homes.

Policy SP2 requires on-site provision of 50% affordable homes on all new sites in Minor Rural and Primary Settlements. Policy SP2 as drafted also limits maximum dwelling numbers to sites of 25 dwellings in Minor Rural Settlements and up to 50 swellings in Primary Settlements. There are a number of concerns with this approach as drafted:

1. Whilst it is understood that it is a core RLDP objective to deliver much needed affordable homes in VoG, Policy SP2 must incorporate sufficient flexibility to allow for viability considerations to be taken into account. Whilst it is understood that the sites proposed for allocation in the RLDP will have provided a Viability Assessment demonstrating that they can be delivered, there is a need to be cautious. Additional policy burdens (e.g. those relating to net zero carbon operational development) could go beyond what has been tested at RLDP preparation stage. Without an explicit mechanism to consider viability, the delivery of entire allocations, both market and affordable housing across the Minor Rural and Primary Settlements, could be jeopardised unintentionally. The blanket approach to the 50% affordable housing requirement across site allocations fails to consider the unique technical complexities of each individual allocation that are required to be overcome before sites can be delivered. This is in direct contrast to PPW paragraph 4.2.32 which states that:

“When setting the affordable housing thresholds and/or site-specific targets planning authorities must consider their impact on site viability to ensure residential sites remain deliverable.”

2. The upper limits of 25 and 50 dwellings for Primary and Minor Rural Settlements respectively are arbitrary and unevidenced. Given the identified need for housing and affordable housing as set out in our comments to Policy SP1, allocated Rural Affordable Housing-Led Sites that have limited constraints (e.g. Allocation HG4(1)) should be allowed to be expanded and accommodate further dwelling numbers should the sites be suitable to allow this. Each site should be considered on its own merit rather than having a 25 unit limit applied as a matter of course. Allocation HG4(1) is located in the HMA of Llandow. Table 5 of the Draft Local Housing Market Assessment 2023 Summary Note Evidence Base Document provides an estimate of the overall additional affordable housing need from 2023 to 2038 as being 52 units per annum which is significantly more than what is proposed for allocation. It is also worth noting that Registered Social Landlords will prefer to have a higher number of affordable units under their management in a particular location to ensure efficiencies in management and operation.

3. Land to the East of Colwinston (HG4(1)) is allocated for 25 dwellings with a minimum provision of 50% on-site affordable housing. As 50% of 25 is 12.5 dwellings, this would need to be rounded up to 13. As such, allocation HG4(1) is required to provide a minimum of 52% on-site affordable housing. As a minimum, allocation HG4(1) should be allowed to provide 26 dwellings so that the “minimum” on-site provision of 50% set out by Policy SP2 is truly a minimum.