Stage C Evidence Base

Comment

Representation ID: 21903

Received: 12/03/2020

Respondent: Home Builders Federation

As the Council will be aware paragraph 57 of the NPPF now places far greater weight on testing the viability of development during the preparation of the local plan with far less scope for negotiation on an application by application basis. It is therefore essential that the approach to viability is sound and reflects the approach set out in PPG. In addition, it is also important that the policies in the plan itself take account of the evidence. In some circumstances this may require policies to reflect the varied viability relating to site typologies or value areas in order to meet the broad test in paragraph 57 that planning applications that comply with the policies in an up to date local plan can be assumed to be viable. We note that the Council’s policy has taken account of difference in viability based on the location of development and this is to be welcomed.
However, we have some broad concerns regarding the viability assessment. Firstly, the Council have not taken into account abnormal costs and the impact such costs may have on viability and the willingness of landowners to sell land at reduced rates. Whilst we recognise that it is difficult to quantify these costs these are very real costs for many developments and some assessment as to their impact should be considered. Secondly the Council will need to considers costs relating to policies on electric vehicle charging points for example. The expectation is not set out in this plan but given that these could impact on viability some consideration should be given to their impact in the viability study. Finally, for larger sites the study seems to only look at CIL payments and does not appear to factor in any strategic infrastructure costs that
may occur. We note that between 10% and 20% uplift to construction costs are included for site and infrastructure. However, this would principally cover landscaping and roads to be delivered on site and not any strategic infrastructure costs. We would suggest that the Council considers the inclusion of cost to reflect any additional strategic infrastructure costs over above CIL.
To assist Councils the HBF has published a briefing note on viability, (See attached), which sets out our concerns regarding viability. We trust this will be of assistance in taking forward the viability study and if you have any question regarding his briefing please feel free to contact us.