In light of our comments we would recommend that the Council ensure that there is sufficient headroom in the viability of developments and that its policy requirements are robustly tested and the inputs for water neutrality and nitrate neutrality in particular are re-evaluated.

Policy H4- Affordable Housing

The Local Plan is one of an alarmingly limited number of emerging Local Plans that have set a differential affordable housing rate. The policy stipulates that affordable housing requirement of 40% on Greenfield sites and 30% on previously developed land. This is commendable and suggests a greater focus on viability in the Plan making stage. The affordable housing target set out in Policy H4 are informed by the evidence base, namely the Viability Assessment taken by Dixon Searle Partnership, hereafter referred to as the viability assessment. We commend the Council for making the report available at the Regulation 18 stage.

We note that the viability assessment has assessed the viability of the extra care older persons housing typologies and that reference is also made to Sheltered housing typologies. We would recommend caution as the viability assessment clearly shows that specialist housing for older people is only marginally viable using the inputs that Dixon Searle have adopted. We are also concerned that the level of financial contributions attributed to achieving nitrate neutrality and water neutrality are massively underrepresented, we believe that figures could be up to £8k a unit for nutrient neutrality (based on examples requested in other LPAs) and given there are no example of off-site credit systems, a similar figure could potentially be required again for water neutrality. The implications of £157.2 per square metre towards CIL contributions on a 50-unit retirement scheme, in conjunction with the other s106 contributions would be as follows:

• Nutrient Neutrality is £2k per unit = £100k
• Water Neutrality is £2k per unit = £100k
• SPA mitigation - £625 per dwelling = £31,250
• Residual S106 - £1500 per unit - £75k
• A827 contribution £8k (assumed to be per development not per dwelling)

This would mean that there would be contributions of around £974,000 on an average scheme in the south of the District before affordable housing is calculated. This has massive implications for the viability of retirement housing schemes for which there is a critical need in the area, and as we are not confident that the. Figures are appropriate for nutrients and water neutrality, this could mean that some retirement housing schemes are rendered unviable by these inputs.

In light of the above, we would suggest that the Council ensure that there is sufficient headroom in the viability of developments and that its policy requirements are robustly tested and the inputs for water neutrality and nitrate neutrality in particular are re-evaluated.