Policy SP8: Housing (f):
This part of the policy is objected to. The proposals in item (f)(i) that 33% of all homes over the plan period should be Affordable Housing is not objected to. However, the aspiration beyond the 33% figure, introducing a 'target' of delivering up to 40% Affordable Housing where viable, is objected to. The policy needs to contain a single clear and unequivocal Affordable Housing target. This is important and necessary because land owners and house builders need to have certainty and clarity when negotiating land sale/acquisitions. Setting a target of 33% and then caveating it by saying actually the LPA may seek 40% if the Council judge that a particular site can stand it in viability terms will result in a lack of certainty and make land sale/acquisition needlessly complicated and indeed may well serve to frustrate certain sites being brought forward for development (i.e. where the Council considers a 40% target is appropriate but where the land owner concludes that such a high provision would result in an unacceptably low return on the land sale and may not agree to sell the land).
Further, it is also a concern that this part of the policy overlaps with policy HS2 with the mechanism of how those two policies interact being unclear. HS2 (despite poor drafting and presentation) is reasonably clear that the level of affordable housing for sites over 25 dwellings is 40%, but criterion (f)(i) of SP8 suggests that the 40% is somehow linked to a viability test.

Also, where is the evidence supporting the housing mix proposed in Item (f)(ii). Whilst the SHMA's evidence on mix of housing points towards more smaller units, the continuing impact of the bedroom tax and pressures on registered providers will make it harder to sell the affordable housing to an RP if there is an excess of larger units by comparison to what they are able to let. If the policy aspiration is that the supply of new affordable housing should be more mixed, the Council should acknowledge that this may have negative viability consequences.

Similarly, the policy and supporting text fails to set out the evidence and justification for the figure of 100 self-build plots in (f)(iii). This needs to be clarified before being included in a Development Plan policy.