Bloor Homes fully support the provision of affordable housing as an integral part of housing development in order to meet the affordable housing needs of the District. However, the viability and deliverability of development sites cannot be compromised by over ambitious requirements to deliver affordable housing.
The Residential Options Viability Interim Report dated April 2016 by Aspinall Verdi indicates that the impact on the viability of development based on the proposed affordable housing requirement of between 30 - 40% (subject to location within District) is significant, requiring policy trade-offs between affordable housing provision and infrastructure. The cumulative impact of policy requirements within the Submission Plan will, therefore, result in the provision of affordable housing at the majority of sites being routinely negotiated on the grounds of viability, thereby considerably slowing the delivery of development. The Viability Report also highlights the effect of the proposed requirements on the viability of the SDAs. Given the reliance on SDAs to meet the full and objectively assessed needs of the District, Policy H2 is unlikely to effectively deliver the level of affordable housing required to meet identified needs with significant socio-economic consequences for the District.

The provision in Part 5 of the policy to enable the Council to consider a different level or mix of affordable housing in order to make the development viable is, therefore, welcomed by Bloor Homes. However, the NPPF is quite clear (paragraphs 158 and 173-174) that the onus is on the local authorities to demonstrate that policy requirements (cumulatively) are achievable and do not render development unviable. The viability implications of the requirements within the policy must, therefore, be considered at this stage before the targets are set to ensure the delivery of sustainable development. If a consequent reduction in the target will result in a shortfall in provision of affordable housing to meet identified needs then additional development allocations will be required to boost supply.
It is also important that affordable housing provision reflects site and location specific variables and the changing needs of the District over the plan period, both in terms of quantum and tenure. Provision must, therefore, be based upon the most up to date evidence available, including the monitoring of market activity over the plan period to identify the ability of developers to deliver affordable housing across the differing locations within the District.
In light of that, the proposed affordable housing tenure mix of 75% affordable / social rent and 25% intermediate is unduly prescriptive. The Government's proposals for Starter Homes as set out in the Housing White Paper alongside other affordable home ownership and rented tenures as a means of boosting the provision of affordable housing across the District should also be considered. This broadening of the approach to housing mix will allow for greater flexibility and will in turn assist in ensuring delivery.

Soundness:
For the reasons set out above, Bloor Homes object to Policy H2, which is considered unsound on the basis that it:
- is not justified in that it is not the most appropriate strategy and has not properly considered reasonable alternative strategies; and
- is inconsistent with national guidance in that it does not fully reflect the Government's objective to ensure affordable housing requirements are not prohibitive to the delivery of sustainable development.

Proposed Changes:
To remedy the flaws in the soundness of the plan:
- The policy should include Affordable Housing quantum and mix requirements that do not undermine the viability of schemes and delay / prevent sustainable development; and
- The policy should include sufficient flexibility to allow development to respond to site-specific constraints, evidence of need and the provision of other forms of affordable housing.