9
Affordable Housing SPD
Adopted March 2011
• Whether there is a financial or business link between the owners (e.g. if a site has been deliberately split
into two, and put in two different names);
• Whether there is a reasonable prospect of developing both sites together; and
• Whether there have been actions undertaken on behalf of an owner or developer to release land after a
site in close proximity has benefited from a planning permission.
Viability
CS POLICY 7:
“The Council will expect... (the full percentage)... requirements to be met and any proposal below
the percentages indicated will need to be fully justified through clear evidence set out in a viability
assessment, and will need to demonstrate that grant funding sources have been fully explored.”
3.12 The Council will initially expect the required level of affordable housing to be delivered without
public subsidy and provided on site. If a developer claims that it would be unviable to provide the required
amount of affordable housing then the onus will be on them to prove this through the use of an appropriate
financial viability assessment in the form of a detailed development appraisal, submitted at the same time
as their planning application. This appraisal should be in line with the Council’s latest guidance on the
Preparation of Development Appraisals.
3.13 The Council will make a judgement on whether they consider the proposed reduction in affordable
housing provision is justified based on the evidence provided and any other available information. Developers
are expected to factor in the Council’s requirements for affordable housing and other developer contributions
when assessing the value of any residential site.
3.14 While the Council acknowledges that in certain circumstances there may be exceptional and
unforeseen development costs, over and above typical build costs, which will impact on the financial viability
of a scheme, it also expects land and property values to take account of all abnormal costs which could have
reasonably been foreseen. Such costs include site clearance and demolition, landscaping, archaeological
and ecological costs, flood alleviation, drainage, planning requirements and any other development costs
including Section 106 obligations. Therefore applicants should not automatically assume that because a
site is previously developed and site clearance/decontamination is required, that these are exceptional and
unforeseen costs. Similarly it is not acceptable as part of any viability test for a developer to pay, or commit
to pay, an enhanced purchase price significantly above the market value of the site.
3.15 The Council will always seek to have transparent and open discussions with applicants, and any
commercially sensitive information that is submitted will be treated as confidential.
3.16 The Council will also expect applicants to have provided evidence demonstrating that they have
explored all possible sources of grant funding before resorting to reduced affordable housing provision. The
Council will seek to assist with trying to identify sources of grant funding wherever possible.
3.17 Developers are expected to explore every opportunity to maximise the affordable housing
provision up to the requirements set out in CS7. Close working between developers, the Council, RSLs and
where relevant the HCA (or any successor organisation) as early as possible in the planning application
process should help to achieve the highest possible levels of provision and ensure the most desirable possible
levels of housing mix and design.