Cyngor Bro Morgannwg
Vale of Glamorgan Council

On the basis of the above, it is proposed that Policy SP7 and Policy SP8 should be aligned so that they are consistent with each other and provide flexibility on a “case-by-case basis”. This would ensure that the RLDP will meet the third test of soundness (Will the Plan deliver?).

Policy SP7 stipulates that in order to meet the affordable housing target of 3,070 dwellings during the RLDP period “a mix of affordable housing will be required, informed by the Local Housing Market Assessment LHMA, waiting list data and the Older Persons Housing Strategy. This should include a range of tenures, types and sizes of homes, as well as an appropriate balance of general needs and specialist accommodation”.

Whilst it is understood that it is a core RLDP objective to deliver affordable homes in VoG which respond to identified need, Policy SP7 must allow for viability to be considered. Whilst paragraph 6.120 of the RLDP states “In calculating the affordable housing target, the Council recognises that the number of affordable homes delivered during the plan period could be lower as a result of site viability constraints or greater where they are on sites delivered by the Council, Registered Social Landlords or on land owned by the Welsh Government”, this recognition is not transferred into the wording of Policy SP7.

The blanket approach to affordable housing requirement percentage across VoG fails to take into account that there may be unique technical complexities at individual allocations that are required to be overcome before sites can be delivered. This is in 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.”

Policy SP8 sets out that Primary and Minor Rural Settlements should meet an affordable housing requirement level of 40%. We do query why affordable housing led allocations in the same geographic areas have a requirement of 50% affordable housing? It is understood from paragraphs 6.122-6.123 of the RLDP that the affordable housing percentage requirements for the settlements in VoG are being carried over from the adopted LDP. However, this does not explain why windfall sites in the Primary and Minor Rural Settlements outside of the Strategic Growth Area would need to provide a minimum 40% affordable housing and the Affordable Housing Led Schemes in the Primary and Minor Rural Settlements outside of the Strategic Growth Area would need to provide a minimum of 50%. Further evidence is required on this matter to ensure that Policy SP8 meets the second test of soundness (Is the Plan appropriate?).

Policy SP8 also states that: “The provision of affordable housing will be negotiated on a site-by-site basis considering the evidenced viability of the development.” Policy SP8 also states: “Where developers claim that the target is unviable, a detailed viability assessment must be submitted and independently reviewed.” The consideration of viability in Policy SP8 is endorsed as it is consistent with paragraph 4.2.32 of PPW.

Policy SP8 also states that: “The exact mix of affordable housing required will be considered on a case-by-case basis having regard to the Council’s latest needs evidence at the
time of the application”. Again, this level of flexibility is endorsed. However, we are concerned that there is contradiction between Policy SP7 (Affordable Housing) and Policy SP8 that needs to be addressed. As drafted Policy SP8 (which relates to all new residential developments in VoG including Affordable housing led allocations) allows flexibility for the delivery of mix of affordable homes as it allows for the exact mix to be considered on a case-by-case basis having regard to the Council’s latest evidence needs. Yet, Policy SP7 (which relates to all affordable residential units to be delivered in the RLDP period) applies a blanket approach that requires the mix of affordable housing to be informed by the Council’s evidence base only, with no flexibility or consideration for site-specific cases or viability. Thus, the two policies as drafted in the RLDP currently contradict one another. This is especially important for the affordable led schemes as the housing mix (affordable and market) can have a big impact on the viability of the scheme given that they have more onerous planning obligations.