A standalone Open Space Strategy is therefore not necessary and Policy CI1 should be amended to reflect this. This amendment is necessary to ensure that Policy CI1 meets the second test of soundness (Is the Plan appropriate?).

Policy CI1 sets out that “all new residential development with a net gain of 10 or more dwellings will be required to provide well-designed, accessible useable open space provision in accordance with the following benchmark open space minimum standards per 1000 population:

• 0.55 Ha of play space (12.4m2 per dwelling)
• 2.2 Ha of additional open space including community growing spaces, outdoor sports and informal open space provision (49.8m2 per dwelling)”.

The proposed 62.2 m² per dwelling requirement is overly prescriptive and not aligned with Field in Trust’s (FiT’s) methodology, which is per person and intended to be applied strategically across different open space typologies, not as a uniform per dwelling metric. FiT’s approach emphasises flexibility, multifunctionality and local context, meaning that applying a rigid per dwelling standard oversimplifies the guidance and risks generating disproportionate land take and unnecessary design constraints. When combined with the wider cumulative policy burdens of the RLDP, such an approach has the potential to impact development viability and reduce delivery.

Policy CI1 also requires an ‘Open Space Strategy’ to be submitted for all housing developments that meet the relevant thresholds. In many instances, it is appropriate for the provision of open space within a scheme to be addressed through a Design and Access Statement and / or Green Infrastructure Statement. This ensures that open space provision is considered as part of the comprehensive approach to design, landscape and biodiversity.

The wording of Policy SP16 must therefore be amended to acknowledge that the above list will apply to “All development proposals, where possible...”

The term “maximising” should also be removed entirely from Policy SP16 as the term is imprecise. Proposals should be encouraged to be efficient but to require demonstration of maximisation could also lead to viability issues.

The proposed amendments will ensure that Policy SP16 will meet the third test of soundness (Will the Plan deliver?).

It is observed that the wording of Policy SP16 states that “all development proposals” should address the causes of climate change to demonstrate policy compliance. However it is considered that it would not be feasible or even possible to provide all of the information required by Policy SP16 at the outline planning application stage and that some of the information requirements of Policy SP16 can only be expected to be provided at detailed (reserved matters/full) planning application stage. Furthermore, care needs to be taken to ensure that any additional decarbonisation policy aspirations, especially for affordable housing-led schemes, are carefully considered in terms of overall viability.

It is clear that there are some requirements in Policy SP16 that will be unachievable in many new residential developments, for example, requirements 7 relating to the optimisation of energy supply and distribution options, including provision of district heat networks.

The policy wording should be amended so that the performance requirements apply based on the date of planning permission rather than the RLDP adoption date. Changes in energy performance requirements can significantly affect site layout, building orientation, and design considerations. Without this amendment, approved schemes could unnecessarily require variations via Section 73 or Non Material Amendment applications.

As such, Policy CC1 should be amended as follows to ensure that it is precise, measurable and enforceable and achieves the three tests of soundness:

“Proposals for one or more new dwellings will be required to achieve net-zero carbon operational emissions by:
1 Following the principles of the Energy Hierarchy for Planning, prioritising a reduction in energy demand and improved energy efficiency.
2 Achieving the following standards in individual dwellings as calculated using an identified energy performance model: Developments that secure planning permission from RLDP adoption to 31st March 2030
iii. Space heating demand less than or equal to 40kWh/m2/year;
iv. Energy use intensity less than or equal to 75kWh/m2/year;

and developments that secure planning permission from 1st April 2030 onwards
iii. Space heating demand less than or equal to 15kWh/m2/year;
iv. Energy use intensity less than or equal to 40kWh/m2/year; and

3 Providing on-site renewable electricity generation with an output equivalent to at least the annual energy consumption of the development, as calculated using an energy performance model

Where the use of onsite renewable energy generation to match total energy consumption is demonstrated to not be technically feasible the following hierarchy should be followed:
• Renewable energy generation should be maximised as much as possible; and/or
• Connection made to an existing or proposed low carbon district energy network (in compliance with Policy sp1); or
• Where this is not possible the residual energy (the amount by which total energy demand exceeds the renewable energy generation) is to be offset by a contribution to the Council’s Project Zero fund as far as economic viability allows.

Compliance will be evidenced within an Energy Report.”

As an industry leader in delivering high quality and energy efficient homes, BDWR is supportive of the overall aspirations of Policy CC1. However, it is observed that the wording of Policy CC1 requires all proposals for one or more new dwellings to demonstrate policy compliance through an Energy Report. It is considered that it would not be possible to provide all of the information required to demonstrate compliance with Policy CC1 at the outline planning application stage and that the information requirements for Policy CC1 can only be expected to be provided at detailed (reserved matters/full) planning application stage.

Welsh Government consulted on changes Building Regulation relating to Part L (Conservation of Fuel and Power), Part O (Overheating) and Part F (Ventilation) for dwellings and non-domestic buildings in August 2025. It is considered that space heating demand should remain within the remit of Building Regulations control as additional local policy requirements risk creating inconsistency across Local Planning Authorities and may exceed what is necessary to align with national policy and legislation.

In addition, there needs to be clarity on where the measurement point begins (for example, if the guidance were to require developers to take the heating demand before the efficiency of an air source heat pump is factored into the heating load, then the efficiency of the heating pump could not be included in the calculation of demand). Policy CC1 should clarify that it applies only to regulated energy use. Developers have no control over how future homeowners use their homes, and therefore unregulated energy consumption such as appliance use, occupant behaviour, and plug loads, cannot form part of compliance requirements. This would also ensure consistency with Building Regulations methodology.

Alternatively, if Policy CC1 is kept in the RLDP, there must be some flexibility introduced for the requirements of Policy CC1 to fall away should Building Regulations catch up or exceed or require different provisions than the requirements of Policy CC1 during the lifetime of the RLDP. To not provide this flexibility would mean that the ability of the RLDP to deliver the new homes in VoG needs could be compromised. Clarification is also required on how the contribution to the Council’s Project Zero fund is to be calculated and whether the timeframes in Policy CC1 relate to the date of planning approval.

Furthermore, the demands of Policy CC1 have to be considered in the context of all of the other demands that impact on development viability (e.g. affordable housing). The Council must provide evidence that an assessment has been undertaken to demonstrate that development, specifically the housing allocations in Policy HG1, can bear the cumulative policy costs of the RLDP, including Policy CC1.

Policy CC2 as drafted therefore risks not achieving the third test of soundness (Will the Plan deliver?) and Policy CC2 should therefore be removed from the RLDP

As drafted, Policy CC2 sets a presumption against demolition. This could have serious impacts on delivery timescales for residential sites with, for example, unused or derelict farm buildings or where a dwelling needs to be demolished for access purposes. This could have implications on the housing delivery trajectory as set out in the Council’s Housing Land Supply and Housing Trajectory Evidence Paper.

Policy SP20 states that “Where development is considered appropriate and the on-site delivery of nature-based solutions is not feasible or sufficient, planning obligations and/or conditions will be used to secure and maintain compensatory off-site habitats and measures that are functionally related to the assets within the site and contribute to the wider local nature recovery priorities.”

The proportionate approach to biodiversity mitigation and compensation, that provides allowance for planning obligations towards off-site habitat improvement and maintenance is consistent with Chapter 6 of PPW and therefore meets the first test of soundness (Does the Plan fit?). It is essential that options are retained to provide biodiversity mitigation off site as well as on site.

As set out in our representations to RLDP Policy SP1 and SP6, the level of housing growth in the VoG should be far more aspirational than currently set out in the RLDP.

Element 1 of the RLDP Sustainable Growth Strategy commits to “Delivering a sustainable level of housing and employment growth to accord with the Vale’s position within the Cardiff Capital Region.” The supporting text sets out that the RLDP will make provision for 7,890 dwellings over the RLDP period (526dpa), plus a flexibility allowance.

Supporting paragraph 5.8 states that: “The level of growth proposed is based on average completions over the first ten years of the adopted plan period (526 dwellings per annum). This reflects an appropriate timeframe, encompassing a period of low housing completions following the economic recession and the more recent boom years following the adoption of the LDP and delivery of allocated sites. This level of growth has been demonstrated to be deliverable and is sufficiently ambitious to reflect the Vale’s position in the Future Wales national growth area. It also addresses the acute need for affordable housing, whilst being achievable within the limitations of the natural and built environment.”

It is considered that basing the future level of growth on the average completions over the last decade is far from ambitious enough to the level of housing that is actually required in VoG in the RLDP period. The last 10 years includes periods of unprecedentedly low housing delivery, for example during the Covid pandemic where, according to the Consultation Evidence Base (Housing Land Supply and Housing Trajectory December 2025), only 431 and 354 additional dwellings were delivered in 2021-22 and 2022-23 respectively. Basing housing growth on past trends in average completions takes no account of emerging demographic trends or any backlog of unmet need and does not comply with the approach set out in the Development Plans Manual. It is observed that delivery in the remaining six out of the last 10 years exceeded 526 dwellings per annum. This demonstrates that delivery within the VoG has operated above the proposed housing requirement for the RLDP period in recent times (with the exception of covid years) which provides a high level of confidence that a higher housing target could realistically be achieved.

The level of housing growth for the RLDP is therefore unambitious, particularly given that the Vale of Glamorgan sits within a National Growth Area (‘NGA’) in Policy 1 (Where Wales will grow) of Future Wales. Policy 33 (NGA – Cardiff, Newport and the Valleys) states that: “Local Development Plans should recognise the National Growth Area as the focus for strategic economic and housing growth; essential services and facilities; advanced manufacturing; transport and digital infrastructure.” As such, pursuing an approach to future delivery which seeks to maintain historic delivery rates is not reflective of Vale of Glamorgan’s role within a NGA and lacks the level of ambition for the area set out in national planning policy. The previous LDP was adopted at a period of time before Future Wales was published. Therefore pursuing an approach that seeks to maintain historic delivery rates is not considered to reflect the enhanced role that the Vale of Glamorgan has as a result of its designation as part of a national growth area within Future Wales. It is illogical that the annual requirement has gone down from the figure in the adopted LDP when the local area has been categorised as part of a national growth area in Future Wales.

In order for Policy SP1 and SP6, to achieve Test 2 (Is the Plan appropriate?) and Test 3 (Will the Plan deliver?), Policy SP1 and SP6 must be updated to accommodate a greater level of housing delivery based on the most up-to-date evidence.

Policy SP1 also states that: “The primary focus of housing growth within the Vale shall be within the Strategic Growth Area as identified on the Key Diagram. New housing developments will be concentrated in the following locations, which are served by existing public transport routes and provide the opportunity to enhance sustainable transport connectivity:
• Barry
• Penarth
• Llantwit Major
• Cowbridge
• Dinas Powys
• Rhoose
• St Athan
• Llandough
• Sully
Outside of the Strategic Growth Area, the allocation of new sites will be limited to small-scale affordable housing led sites in appropriate primary and Minor Rural Settlements.”

In order to accommodate the additional level of housing growth the VoG needs, both the Strategic Growth Area settlements, and the Primary and Minor Rural Settlements will need to be allocated additional housing sites. Land at Primrose Hill, Cowbridge (Site ID: 455) can assist greatly in accommodating this additional housing need in a sustainable location. The site is adjacent to the higher order Strategic Growth Area settlement of Cowbridge, has limited physical and environmental constraints and is capable of providing up to 220 dwellings at a density of 35 dwellings per hectare.

Policy SP1 sets out that the plan will deliver 7,890 dwellings by 2036, including a minimum of 3,070 affordable homes. Policy SP6 states that: “to meet the identified housing requirement of 7,890 dwellings, provision will be made for the delivery of 8,660 homes in the Plan Period 2021 to 2036. This will be delivered by:
• 3,837 dwellings from the existing land supply
• 3,520 dwellings on allocated sites
• 1,303 dwellings from large and small windfall developments”

The 8,660 provision equates to a flexibility allowance of 9.8% against the targeted delivery of 7,890 set out in Policy SP1. BDWR endorses the incorporation of a flexibility allowance, as is required by paragraph 5.59 of the Development Plans Manual (2020). However, it is considered that the flexibility allowance needs to be increased to a minimum of 15-20% to ensure that the ambitious anticipated annual build rate of between 885-906 dpa from 2027/28 to 2030/31 can be achieved. Whilst we note that the Development Management Manual references a starting point of 10% we note that other local authorities have utilised a higher percentage in draft plans. This includes Swansea (20%) and Monmouthshire (15%).

The number of households in VoG in mid-2021 (i.e. the start of the RLDP period) was 57,676. Based on Welsh Government’s 2022-based household projections (published in November 2025), the number of households is projected to increase to 67,299 in VoG in mid-2036 (i.e. the end of the RLDP period). This equates to a household increase of 9,623 which is 22.0% more than the 7,890 dwellings the RLDP targets for in Policy SP1.

However, the Development Plan Manual (para 5.37) also requires a conversion factor from households to dwellings with 4% being the baseline (it is acknowledged that this will vary depending on local circumstances). Taking a 4% uplift, the dwelling requirement figure would be 10,008 which is 26.8% more that the RLDP seeks to deliver in Policy SP1.

It is therefore evident that the housing requirement figure proposed in Policy SP1 is insufficient to meet the newly arising needs of VoG for the RLDP period. Neither does the proposed housing requirement make sufficient allowance for meeting the backlog of unmet affordable housing need.

A fundamental review of the housing requirement figure is required to reflect the most up to date demographic information (i.e. the 2022 household projections) as set out in the Development Plan Manual. The housing requirement figure should also be further adjusted upwards to ensure that existing backlogs of unmet housing need can be addressed and reflect the plans aspirations for economic growth and social inclusion.

Paragraph 5.34 of the Development Plans Manual (2020) states that:

“In terms of considering the level of housing provision for a plan, the most up-to- date suite of Welsh Government Population and Household Projections are a fundamental part of the evidence base.”

Paragraph 5.35 states:

“…All LPAs should use these projections and the resultant household numbers when considering the level of housing provision for a plan period”

Whilst we understand that the latest household projections were not available at the time of drafting the deposit LDP it is clear that these will need to be revisited. We note that the Inspector examining the Cardiff, Monmouthshire and Carmarthenshire LDPs have asked the authorities to review the implications of the data.

As such, it is evident that the housing requirement and the sites identified for development is insufficient to meet the actual housing needs of VoG during the RLDP period.

It is important to note that the above calculations are purely to meet newly arising need and does not make any allowance for existing unmet affordable housing needs. As stated in the supporting text of Sustainable Growth Strategy 4 of the RLDP (paragraph 5.23) “The Local Housing Market Assessment (LHMA) 2023 identifies a need for 1,075 affordable homes per annum over the next five years based on principal projections or 1,114 based on the RLDP projections. There is an identified backlog of need across all the sub-market areas in the Vale of Glamorgan, and the issue is acute in many communities.” Policy SP1 seeks to deliver only 3,070 affordable homes over the RLDP period, equating to 205 affordable dwellings per annum. This is only 18.4% of identified need per annum for the five-year period from 2023-2028 in the LHMA. Taking account of the existing unmet need will push the housing requirement even higher.

The number of affordable homes identified in Policy SP1 and Policy SP6 therefore falls drastically short of the actual need for affordable homes in VoG for the RLDP period.

In order for Policy SP1 and SP6, to achieve Test 2 (Is the Plan appropriate?) and Test 3 (Will the Plan deliver?), Policy SP1 and SP6 must be updated to accommodate a greater level of housing delivery based on the most up-to-date evidence.

In order to accommodate the additional level of housing growth the VoG needs, both the Strategic Growth Area settlements, and the Primary and Minor Rural Settlements will need to be allocated additional housing sites. Land at Primrose Hill, Cowbridge (Site ID: 455) can assist greatly in accommodating this additional housing need in a sustainable location. The site is adjacent to the higher order Strategic Growth Area settlement of Cowbridge, has limited physical and environmental constraints and is capable of providing up to 220 dwellings at a density of 35 dwellings per hectare.

Policy SP6 states that: “to meet the identified housing requirement of 7,890 dwellings, provision will be made for the delivery of 8,660 homes in the Plan Period 2021 to 2036. This will be delivered by:
• 3,837 dwellings from the existing land supply
• 3,520 dwellings on allocated sites
• 1,303 dwellings from large and small windfall developments”

The 8,660 provision equates to a flexibility allowance of 9.8% against the targeted delivery of 7,890 set out in Policy SP1. BDWR endorses the incorporation of a flexibility allowance, as is required by paragraph 5.59 of the Development Plans Manual (2020). However, it is considered that the flexibility allowance needs to be increased to a minimum of 15-20% to ensure that the ambitious anticipated annual build rate of between 885-906 dpa from 2027/28 to 2030/31 can be achieved. Whilst we note that the Development Management Manual references a starting point of 10% we note that other local authorities have utilised a higher percentage in draft plans. This includes Swansea (20%) and Monmouthshire (15%).

The number of households in VoG in mid-2021 (i.e. the start of the RLDP period) was 57,676. Based on Welsh Government’s 2022-based household projections (published in November 2025), the number of households is projected to increase to 67,299 in VoG in mid-2036 (i.e. the end of the RLDP period). This equates to a household increase of 9,623 which is 22.0% more than the 7,890 dwellings the RLDP targets for in Policy SP1.

However, the Development Plan Manual (para 5.37) also requires a conversion factor from households to dwellings with 4% being the baseline (it is acknowledged that this will vary depending on local circumstances). Taking a 4% uplift, the dwelling requirement figure would be 10,008 which is 26.8% more that the RLDP seeks to deliver in Policy SP1.

It is therefore evident that the housing requirement figure proposed in Policy SP1 is insufficient to meet the newly arising needs of VoG for the RLDP period. Neither does the proposed housing requirement make sufficient allowance for meeting the backlog of unmet affordable housing need.

A fundamental review of the housing requirement figure is required to reflect the most up to date demographic information (i.e. the 2022 household projections) as set out in the Development Plan Manual. The housing requirement figure should also be further adjusted upwards to ensure that existing backlogs of unmet housing need can be addressed and reflect the plans aspirations for economic growth and social inclusion.

Paragraph 5.34 of the Development Plans Manual (2020) states that:

“In terms of considering the level of housing provision for a plan, the most up-to- date suite of Welsh Government Population and Household Projections are a fundamental part of the evidence base.”

Paragraph 5.35 states:

“…All LPAs should use these projections and the resultant household numbers when considering the level of housing provision for a plan period”

Whilst we understand that the latest household projections were not available at the time of drafting the deposit LDP it is clear that these will need to be revisited. We note that the Inspector examining the Cardiff, Monmouthshire and Carmarthenshire LDPs have asked the authorities to review the implications of the data.

As such, it is evident that the housing requirement and the sites identified for development is insufficient to meet the actual housing needs of VoG during the RLDP period.

It is important to note that the above calculations are purely to meet newly arising need and does not make any allowance for existing unmet affordable housing needs. As stated in the supporting text of Sustainable Growth Strategy 4 of the RLDP (paragraph 5.23) “The Local Housing Market Assessment (LHMA) 2023 identifies a need for 1,075 affordable homes per annum over the next five years based on principal projections or 1,114 based on the RLDP projections. There is an identified backlog of need across all the sub-market areas in the Vale of Glamorgan, and the issue is acute in many communities.” Policy SP1 seeks to deliver only 3,070 affordable homes over the RLDP period, equating to 205 affordable dwellings per annum. This is only 18.4% of identified need per annum for the five-year period from 2023-2028 in the LHMA. Taking account of the existing unmet need will push the housing requirement even higher.

The number of affordable homes identified in Policy SP1 and Policy SP6 therefore falls drastically short of the actual need for affordable homes in VoG for the RLDP period.

We therefore request that Land at Primrose Hill (Candidate Site ID: 455) is allocated for housing development in Policy HG1. The site is located in one of the most sustainable settlements in the settlement hierarchy, Cowbridge, which is also at the top of the retail, commercial and service centre hierarchy in Policy SP11. Cowbridge has a serious lack of allocated land for housing development and major land bank sites in the RLDP as drafted.

In order for Cowbridge to match its status in the hierarchies of Policy SP2 and SP11, the RLDP needs to include Land at Primrose Hill for allocation would deliver up to 220 homes during the RLDP period. Land at Primrose Hill is within easy reach of the town centre and in close proximity to excellent commercial, educational, community and recreational facilities and services. The site is well positioned to be accessed via the local highway network, which links to both Cardiff, Penarth and Bridgend via regular bus services from bus stops adjacent to the site.

The Service Centre Settlement of Cowbridge comprises a sustainable self-contained settlement with regards to access to services such as primary and secondary schools, shops including supermarkets, medical services at the GP surgery and pharmacy, sports activities including a leisure centre, a library and places of worship. Cowbridge has excellent connections to the A48 with regular bus services providing access to Cardiff, Porthcawl and Llantwit Major.

The Service Centre Settlements are the middle-tier in Policy SP2 and as well as Cowbridge, include Llantwit Major and Penarth. The Key Settlement of Barry being the top-tier and the Primary Settlements of Rhoose, St Athan, Sully, Llandough (Penarth) and Dinas Powys being categorised as the lower-tier, below Cowbridge.

Policy HG1 sets out the housing allocations to meet the identified housing requirement set out in Policy SP6. HG1 allocates sites for a total of 3,398 dwellings across Key Sites and Housing Allocations. Of the 3,398 units:

• Key Settlement (tier 1) = 686 (20.2%)

• Service Centres (tier 2) = 340 (10%)

• Primary Settlements (tier 3) = 2,372 (69.8%)

It is clear that the allocations in Policy HG1 do not reflect the proposed settlement hierarchy with an under representation of allocations in the second tier Service Centre Settlements. There are only two allocations in Service Centre Settlements: HG1(5) at Llantwit Major for 235 units and HG1(6) at Cowbridge for 105 units.

A review by settlement further highlights the under provision of allocations and major land bank sites at Cowbridge compared to other higher order settlements:

Tier 1 Barry – 686

Tier 2 Cowbridge – 105
Llantwit Major – 475
Penarth – 576

Tier 3 Rhoose – 859
St Athan – 1,263
Sully – 175
Llandough – 133
Dinas Powys – 250

It is evident that there are fewer allocations made to Cowbridge than any other higher order settlement and significantly less than many of the tier 3 settlements. A review of the Housing Land Supply document BP9A highlights that there is only planning permission for 203 dwellings in Cowbridge that were not started as of April 2025. The case cannot be made that there is an existing unimplemented land bank to meet the needs of this settlement.

Furthermore, Paragraph 3.5 of the Local Housing Market Assessment (2023) sets out that “The 2021 LHMA indicated that the existing backlog of need is most acute from people on the housing waiting list within Barry, Penarth/Llandough, Llantwit Major, Cowbridge, Dinas Powys, Rhoose, Wenvoe and St Athan although there are a significant number of people on the waiting list across all areas of the Vale.”

Having only one allocation, and no major land bank sites at Cowbridge does not reflect the importance of Cowbridge as a Service Centre Settlement. The failure to make significant new allocations in this Tier 2 settlement undermines the ability of this important settlement to meet its housing needs including affordable needs.

Policy HG1 apportions only 105 dwellings (or only 1.3% of the housing requirement as set out in Policy SP1) to one of only three second tier settlements. Thus, the number of units allocated to Cowbridge does not align with the Settlement Hierarchy presented in Policy SP2. As explained in our representations to Policy SP1 and SP6 above, a more ambitious housing requirement is needed in the VoG.

It is therefore evident that in order for the RLDP to meet the third test of soundness (Will the Plan deliver?), Cowbridge needs additional housing allocations to ensure that housing is delivered at a scale commensurate to the settlement hierarchy in Policy SP2 and to achieve the RLDP Growth Strategy which commits to housing growth that accords with the Vale’s position within the Cardiff Capital Region.

Land at Primrose Hill (with a capacity of up to 220 dwellings) is available, with limited physical and environmental constraints, to assist with the much-needed increased delivery of housing at Cowbridge during this RLDP period.

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.”

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.