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Viability Study
Representation ID: 24476
Received: 22/03/2021
Respondent: Dentons
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
1 Representation
1.1 We welcome the positive basis on which the overall Plan approach has been prepared, in particular the introduction of significant housing supply to contribute to the housing trajectory from strategic regeneration sites. It is clear from the published Trajectory that these sites will make a critical contribution to overall supply (both in terms of amount and resilience of supply) throughout the Plan period.
2 Soundness Issues
2.1 Based on the currently-published information, the Plan is not demonstrably sound in terms of justification, effectiveness and consistency with NPPF in respect of
(a) evidence of infrastructure need and associated costs;
(b) deliverability.
2.2 This gives rise to concerns about soundness for the purposes of NPPF35 and 16(b).
2.3 The Interim Viability Study did assess the deliverability of the ESRA with the scale of infrastructure contributions likely to be required. The scale of these contributions and the extent to which the
2.4 The NPS Final Viability Report (12 January 2021, FVR) adopts a generic 1,000 home typology (T11) but this does not relate to the ESRA and the FVR acknowledges that:
56. With regard to the assessment of ‘specific circumstances of strategic sites’ it is acknowledged that such sites will be impacted by strategic infrastructure costs over and above the usual developments costs of an average development site.
57. These strategic sites will be appraised in greater detail independently. What this Viability Appraisal achieves is to demonstrate whether the development of notional sites using an adjusted but standardised approach, can incorporate the emerging planning policies into the development costs while still achieving a satisfactory developers return and adequate land value to ensure land is bought forward for development.
2.5 As such, the evidence base for the Plan does not adequately demonstrate the following in relation to the ESRA:
(a) What the scale of burdens are intended to be in the ESRA (including the relative contribution of CIL); or
(b) How those burdens will affect deliverability.
2.6 That is contrary to both limbs of NPPF34.
2.7 The Plan should be clear about the scale of costs assumed for the ESRA, as well as amore appropriate land value and site preparation cost dynamics and constraints. It should not defer that to a SPD stage, which is not subject to EiP and which would create doubt about the requirements applicable to ESRA sites under Policies 5, 7.1 and GNLP0360/3053/R10.
2.8 This reflects the emphasis in the Planning Practice Guidance in relation to Local Plan preparation that:
Policy requirements, particularly for affordable housing, should be set at a level that takes account of affordable housing and infrastructure needs and allows for the planned types of sites and development to be deliverable, without the need for further viability assessment at the decision making stage.
2.9 PPG recognise that area-wide assessment is limited and "more detailed assessment may be necessary for particular areas or key sites on which the delivery of the plan relies". More detailed assessment on the issues above in relation to the ESRA is needed at this stage to properly support the welcome allocation of the ESRA as a regeneration area that is needed to make a substantial contribution to housing supply, effective use of previously developed land and environmental improvement over the plan period.
2.10 We also consider that the requirements for the ESRA SPD have not been adequately established in Policies 7.1 and GNLP0360/3053/R10. This relates to the scope, timing and scale of the masterplanning process and whether elements of it are Justified and will be Effective.
1 Representation
1.1 We welcome the positive basis on which the overall Plan approach has been prepared, in particular the introduction of significant housing supply to contribute to the housing trajectory from strategic regeneration sites. It is clear from the published Trajectory that these sites will make a critical contribution to overall supply (both in terms of amount and resilience of supply) throughout the Plan period.
2 Soundness Issues
2.1 Based on the currently-published information, the Plan is not demonstrably sound in terms of justification, effectiveness and consistency with NPPF in respect of
(a) evidence of infrastructure need and associated costs;
(b) deliverability.
2.2 This gives rise to concerns about soundness for the purposes of NPPF35 and 16(b).
2.3 The Interim Viability Study did assess the deliverability of the ESRA with the scale of infrastructure contributions likely to be required. The scale of these contributions and the extent to which the
2.4 The NPS Final Viability Report (12 January 2021, FVR) adopts a generic 1,000 home typology (T11) but this does not relate to the ESRA and the FVR acknowledges that:
56. With regard to the assessment of ‘specific circumstances of strategic sites’ it is acknowledged that such sites will be impacted by strategic infrastructure costs over and above the usual developments costs of an average development site.
57. These strategic sites will be appraised in greater detail independently. What this Viability Appraisal achieves is to demonstrate whether the development of notional sites using an adjusted but standardised approach, can incorporate the emerging planning policies into the development costs while still achieving a satisfactory developers return and adequate land value to ensure land is bought forward for development.
2.5 As such, the evidence base for the Plan does not adequately demonstrate the following in relation to the ESRA:
(a) What the scale of burdens are intended to be in the ESRA (including the relative contribution of CIL); or
(b) How those burdens will affect deliverability.
2.6 That is contrary to both limbs of NPPF34.
2.7 The Plan should be clear about the scale of costs assumed for the ESRA, as well as amore appropriate land value and site preparation cost dynamics and constraints. It should not defer that to a SPD stage, which is not subject to EiP and which would create doubt about the requirements applicable to ESRA sites under Policies 5, 7.1 and GNLP0360/3053/R10.
2.8 This reflects the emphasis in the Planning Practice Guidance in relation to Local Plan preparation that:
Policy requirements, particularly for affordable housing, should be set at a level that takes account of affordable housing and infrastructure needs and allows for the planned types of sites and development to be deliverable, without the need for further viability assessment at the decision making stage.
2.9 PPG recognise that area-wide assessment is limited and "more detailed assessment may be necessary for particular areas or key sites on which the delivery of the plan relies". More detailed assessment on the issues above in relation to the ESRA is needed at this stage to properly support the welcome allocation of the ESRA as a regeneration area that is needed to make a substantial contribution to housing supply, effective use of previously developed land and environmental improvement over the plan period.
2.10 We also consider that the requirements for the ESRA SPD have not been adequately established in Policies 7.1 and GNLP0360/3053/R10. This relates to the scope, timing and scale of the masterplanning process and whether elements of it are Justified and will be Effective.
Object
Publication
0360/3053/R10 Policy
Representation ID: 24477
Received: 22/03/2021
Respondent: Dentons
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
1 Representation
1.1 We welcome the positive basis on which the overall Plan approach has been prepared, in particular the introduction of significant housing supply to contribute to the housing trajectory from strategic regeneration sites. It is clear from the published Trajectory that these sites will make a critical contribution to overall supply (both in terms of amount and resilience of supply) throughout the Plan period.
2 Soundness Issues
2.1 Based on the currently-published information, the Plan is not demonstrably sound in terms of justification, effectiveness and consistency with NPPF in respect of
(a) evidence of infrastructure need and associated costs;
(b) deliverability.
2.2 This gives rise to concerns about soundness for the purposes of NPPF35 and 16(b).
2.3 The Interim Viability Study did assess the deliverability of the ESRA with the scale of infrastructure contributions likely to be required. The scale of these contributions and the extent to which the
2.4 The NPS Final Viability Report (12 January 2021, FVR) adopts a generic 1,000 home typology (T11) but this does not relate to the ESRA and the FVR acknowledges that:
56. With regard to the assessment of ‘specific circumstances of strategic sites’ it is acknowledged that such sites will be impacted by strategic infrastructure costs over and above the usual developments costs of an average development site.
57. These strategic sites will be appraised in greater detail independently. What this Viability Appraisal achieves is to demonstrate whether the development of notional sites using an adjusted but standardised approach, can incorporate the emerging planning policies into the development costs while still achieving a satisfactory developers return and adequate land value to ensure land is bought forward for development.
2.5 As such, the evidence base for the Plan does not adequately demonstrate the following in relation to the ESRA:
(a) What the scale of burdens are intended to be in the ESRA (including the relative contribution of CIL); or
(b) How those burdens will affect deliverability.
2.6 That is contrary to both limbs of NPPF34.
2.7 The Plan should be clear about the scale of costs assumed for the ESRA, as well as amore appropriate land value and site preparation cost dynamics and constraints. It should not defer that to a SPD stage, which is not subject to EiP and which would create doubt about the requirements applicable to ESRA sites under Policies 5, 7.1 and GNLP0360/3053/R10.
2.8 This reflects the emphasis in the Planning Practice Guidance in relation to Local Plan preparation that:
Policy requirements, particularly for affordable housing, should be set at a level that takes account of affordable housing and infrastructure needs and allows for the planned types of sites and development to be deliverable, without the need for further viability assessment at the decision making stage.
2.9 PPG recognise that area-wide assessment is limited and "more detailed assessment may be necessary for particular areas or key sites on which the delivery of the plan relies". More detailed assessment on the issues above in relation to the ESRA is needed at this stage to properly support the welcome allocation of the ESRA as a regeneration area that is needed to make a substantial contribution to housing supply, effective use of previously developed land and environmental improvement over the plan period.
2.10 We also consider that the requirements for the ESRA SPD have not been adequately established in Policies 7.1 and GNLP0360/3053/R10. This relates to the scope, timing and scale of the masterplanning process and whether elements of it are Justified and will be Effective.
1 Representation
1.1 We welcome the positive basis on which the overall Plan approach has been prepared, in particular the introduction of significant housing supply to contribute to the housing trajectory from strategic regeneration sites. It is clear from the published Trajectory that these sites will make a critical contribution to overall supply (both in terms of amount and resilience of supply) throughout the Plan period.
2 Soundness Issues
2.1 Based on the currently-published information, the Plan is not demonstrably sound in terms of justification, effectiveness and consistency with NPPF in respect of
(a) evidence of infrastructure need and associated costs;
(b) deliverability.
2.2 This gives rise to concerns about soundness for the purposes of NPPF35 and 16(b).
2.3 The Interim Viability Study did assess the deliverability of the ESRA with the scale of infrastructure contributions likely to be required. The scale of these contributions and the extent to which the
2.4 The NPS Final Viability Report (12 January 2021, FVR) adopts a generic 1,000 home typology (T11) but this does not relate to the ESRA and the FVR acknowledges that:
56. With regard to the assessment of ‘specific circumstances of strategic sites’ it is acknowledged that such sites will be impacted by strategic infrastructure costs over and above the usual developments costs of an average development site.
57. These strategic sites will be appraised in greater detail independently. What this Viability Appraisal achieves is to demonstrate whether the development of notional sites using an adjusted but standardised approach, can incorporate the emerging planning policies into the development costs while still achieving a satisfactory developers return and adequate land value to ensure land is bought forward for development.
2.5 As such, the evidence base for the Plan does not adequately demonstrate the following in relation to the ESRA:
(a) What the scale of burdens are intended to be in the ESRA (including the relative contribution of CIL); or
(b) How those burdens will affect deliverability.
2.6 That is contrary to both limbs of NPPF34.
2.7 The Plan should be clear about the scale of costs assumed for the ESRA, as well as amore appropriate land value and site preparation cost dynamics and constraints. It should not defer that to a SPD stage, which is not subject to EiP and which would create doubt about the requirements applicable to ESRA sites under Policies 5, 7.1 and GNLP0360/3053/R10.
2.8 This reflects the emphasis in the Planning Practice Guidance in relation to Local Plan preparation that:
Policy requirements, particularly for affordable housing, should be set at a level that takes account of affordable housing and infrastructure needs and allows for the planned types of sites and development to be deliverable, without the need for further viability assessment at the decision making stage.
2.9 PPG recognise that area-wide assessment is limited and "more detailed assessment may be necessary for particular areas or key sites on which the delivery of the plan relies". More detailed assessment on the issues above in relation to the ESRA is needed at this stage to properly support the welcome allocation of the ESRA as a regeneration area that is needed to make a substantial contribution to housing supply, effective use of previously developed land and environmental improvement over the plan period.
2.10 We also consider that the requirements for the ESRA SPD have not been adequately established in Policies 7.1 and GNLP0360/3053/R10. This relates to the scope, timing and scale of the masterplanning process and whether elements of it are Justified and will be Effective.
