Local Development Framework Consultation

Policy AS27: We support the proposed allocation of site B81 for residential development. The site is considered to be acceptable for residential development as it is deliverable in accordance with footnote 11 of the NPPF. This is because the site is available now, offers a suitable location for development (as it is a brownfield site in an accessible location) and is deliverable within 5 years. The residential development of the site would also comply with the 3 dimensions of sustainable development as outlined within paragraph 7 of the NPPF. Development of the site would have a social role as it would provide the supply of housing required to meet the needs of people of present and future generations and would also offer a high quality built development. Development of the site would also have a positive economic impact as it would support growth and potentially provide affordable housing, contributing to building a strong local economy. With regard to the environmental role, as the development would occur on brownfield land, this would protect the AONB and natural environment as development would not take place on more sensitive greenfield sites. As such, the negative impact on the AONB would be insignificant in accordance with Core Strategy policy CS5. Policy AS04: This policy states that proposals for new housing development "will be supported where they deliver at least 50% affordable housing". The justification for this requirement is stated as being "because the AONB is a sensitive landscape protected at national level". It is vital that the affordable housing requirement is however based on an adequate evidence base, as is required by paragraph 158 of the NPPF. This states that the "LPA should ensure that the Local Plan is based on adequate, up to date and relevant evidence about the economic and social characteristics and prospects of the area... and that they take full account of relevant market and economic signals". Paragraph 159 of the NPPF states that a SHMA should be undertaken to assess the housing needs within the area. It is understood that this has not been undertaken for the AONB. Furthermore, paragraph 182 of the NPPF states that the plan is to be based on proportionate evidence. It is therefore considered that the evidence provided is insufficient to support the 50% affordable housing requirement. With regard to the 50% affordable housing requirement, policy AS04 states that "only where this is demonstrably unachievable through available mechanisms will a lower percentage be acceptable". This wording is unclear as to what exactly these 'available mechanisms' are. It is considered necessary for these to be specified to ensure that the policy accords with paragraph 154 of the NPPF which states that "only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan".