Chichester Local Plan 2021-2039 - Main Modifications consultation

“Provision of affordable housing will be required as set out in criteria 1 to 4 below and in accordance with the type, mix and tenure requirements set out in Policy H5 (Housing Mix).

*This excludes any application which is seeking to deliver specialist accommodation for older persons housing including retirement housing (Use Class C3) and extra care housing.*”

Policy H4: Affordable Housing

Under MM35, several minor amendments have been proposed to emerging Policy H4, these changes however do not materially affect the way the policy is interpreted.

This is disappointing to see given the significant work that has previously been issued to the Council regarding the viability of specialist forms of accommodation. Our previously submitted Hearing Statement (September 2024) has been appended under Appendix 1 to this consultation response for ease of reference, and we respectfully request that the findings of the statement are considered as part of this consultation.

The findings clearly identified that 20% affordable housing is shown to be unviable when tested accurately against the specialist housing typology. The statement concluded that emerging Policy H4 was unsound on the grounds the affordable housing targets were not justified in respect of older persons housing.

It is disappointing to see that the previous recommendations in proposing nil affordable housing for specialist accommodation for older persons on the grounds of viability has not been duly considered. Detailed comments on the plan wide viability underpinning the policy were previously made, however no further analysis appears to have been undertaken to reflect this. The PPG on viability requires that local planning authorities engage with stakeholders on viability matters to create realistic and deliverable policies.

“It is the responsibility of plan makers in collaboration with the local community, developers and other stakeholders, to create realistic, deliverable policies. Drafting of plan policies should be iterative and informed by engagement with developers, landowners and infrastructure and affordable housing providers” Paragraph: 002. Reference ID: 10-002-20190509.

This has not occurred in this instance.

The Local Plan is therefore considered to be unsound on the grounds the affordable housing targets are not justified, positively prepared or effective. Policy H4 is not realistic with respect to older persons housing and will not encourage delivery of schemes.

The guidance in the NPPF and the PPG state that the role for viability assessment is primarily at the Plan making stage:

"Where up-to-date policies have set out the contributions expected from development, planning applications that comply with them should be assumed to be viable. It is up to the applicant to demonstrate whether particular circumstances justify the need for a viability assessment at the application stage. The weight to be given to a viability assessment is a matter for the decision maker, having regard to all the circumstances in the case, including whether the plan and the viability evidence underpinning it is up to date, and any change in site circumstances since the plan was brought into force (paragraph 57.)"

RECOMMENDATION:

Therefore, in addition to MM35, we again request the following modification is made to the wording of Policy H4:

“Provision of affordable housing will be required as set out in criteria 1 to 4 below and in accordance with the type, mix and tenure requirements set out in Policy H5 (Housing Mix).

*This excludes any application which is seeking to deliver specialist accommodation for older persons housing including retirement housing (Use Class C3) and extra care housing.*”

A nil affordable housing rate could facilitate a step-change in the delivery of older person’s housing in the Chichester helping to meet the diverse housing needs of the elderly as detailed in Policy H8: Specialist Housing. The benefits of specialist older persons’ housing extend beyond the delivery of planning obligations as these forms of development contribute to the regeneration of town centres and assist Council’s by making savings on health and social care.