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. There is a lack of clarity around the term ‘informed’. It is unclear whether the Council will require the mix reflect the LHMA etc or whether it is just a starting point for negotiation. It is assumed that it is just a starting point but this could helpfully be clarified.

It is noted that the Council has ambitious policies for both affordable housing and net zero operational homes. In working towards delivery of these it will be necessary to carefully consider site viability and there must be some flexibility in both Policy SP7 to ensure that necessary new homes are built.

PPW paragraph 4.2.32 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.” (Lichfields emphasis)

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 possible 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) requires the mix of affordable housing to be informed by the Council’s evidence base only, it is unclear the extent to which there is 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.