In introducing the report, the Project Manager (Planning Policy) explained that Members of the Planning and Transportation Policy Working Group (PTPWG) were briefed on the Whole Plan Viability Assessment in July 2024 and this included a detailed question and answer session with the consultants who produced the study. Members had noted the findings of the Assessment including the Policy recommendations set out, at that briefing.

The Project Manager (Planning Policy) said the intended Local Plan Regulation 18 consultation would cover the vision, objectives and development management policies of the plan and it was appropriate to publish this evidence, as it included the achievability of affordable housing contributions for the borough and provided the key evidence for the Affordable Housing Policy that was part of the Regulation 18 consultation. He said the viability evidence demonstrated that across the borough, the Council could seek a 30% affordable housing contribution on greenfield sites and a 10% affordable housing contribution should be sought to help the delivery of brownfield sites.

The Project Manager (Planning Policy) explained that as part of the viability testing, a series of typologies were developed to assess the draft Local Plan policy requirements of which affordable housing was included.  He said the typologies ranged from brownfield sites in urban areas to greenfield sites outside of built-up area confines and the assessment of the typologies would then inform the likely achievability of sites that would come forward in future plan drafting.

The Project Manager (Planning Policy) said the study also considered available strategic sites and it should be noted those strategic sites had been tested at a high level to inform the viability element of future drafting of the plan, and were not reflective of any live planning applications. He added that the Council’s policy direction would inevitably evolve through drafting and consultation of the Local Plan, development of its evidence base and through changes in national policy, resulting in a need to provide a partial update to the viability assessment as part of preparing the Regulation 19 consultation intended for Summer 2026. 

Members were invited to ask questions and make comments and these included:

·         Requested that for very large documents such as this, hard copies of Agendas be made available as early as possible;

·         colour coding in the charts made it clear and was helpful for visual learners;

·         how did affordable housing sit alongside the National Planning Policy Framework’s (NPPF) recommendations?;

·         highlighted some errors in tables and column headings;

·         would the evidence be updated at the Regulation 19 stage?;

·         as larger sites naturally carried abnormal costs, it was really important that the Council took particular consideration of this when costing;

·         drew attention to the differences in some of the areas that had been grouped together and suggested this should be better clarified;

·         highlighted the risks on strategic sites, in delivery and time frame;

·         sought clarification on whether the viability of strategic sites was on economic terms only?’;

·         referred to the ‘shopping list’ of developer contributions in table 8.4 in the report and questioned whether health would be included?;

·         drew attention to table 10.11, and raised concerned about the financial deliverability of the strategic sites from the delayed process and whether there had since been changes?;

·         raised that developer contributions should be higher;

·         suggested a lower affordable housing target to achieve better quality and standards on other policies; and

·         sought clarification on the process.

In response, the Project Manager (Planning Policy) said the Government encouraged the release of green belt land and sought 50% of affordable housing on this land but it was irrelevant to Swale as it did not have any. He confirmed there would be a partial update of the evidence at the Regulation 19 stage, pointing out the areas that would be reviewed. The Project Manager (Planning Policy) said the viability of strategic sites was being considered at a much higher level and there were more issues that needed to be identified before being put forward to the next stage in the process.  He advised that since the publication of the developer contributions table there had been a consultation with more detail of the contributions required by the NHS for health matters and this information would be updated at the Regulation 19 stage.

The Project Manager (Planning Policy) said there may be some fluctuations in the financial values but the approach of selections of sites were still valid.  He added that the update to the Regulation 19 would confirm changes and once sites were selected, there would be an informal engagement with the site promoters to reconfirm their availability and deliverability. In respect of higher developer contributions, the Project Manager (Planning Policy) said the document had been produced by industry specialists following national policy and guidance, and tested existing and estimated land values, building costs and sale values and they concluded the contributions set out in the document were the viable costs for land in the Swale area.  The Project Manager (Planning Policy) said the affordable housing target was determined by the Strategic Housing Market Assessment.

Resolved:

(1)  Members noted the report.