Object

Representation ID: 22763

Received: 16/03/2020

Respondent: Mr Bryan Robinson

I have a particular grievance concerning affordable housing.

From current experience I am concerned that the proposals for 33% affordable housing targets in Broadland & South Norfolk and 28% in Norwich will be fall short in implementation worsening the shortage to meet the current need as identified in the latest 2017 SHMA report.

Currently, Viability Assessments are permitted by developers to allow reductions in affordable housing where full provision will not be viable. Hypothetical submissions are being made by landowners with the sole intention of increasing the land values for selling on to developers with reduced the affordable housing provisions.

I have referred examples to both Broadland and South Norfolk where affordable housing numbers have been reduced by landowners. As an example Broadland planning approval 20160498 reduces the affordable housing to 15% for the first phase based on a Viability Assessment submitted on behalf of the landowner. The submission was checked by the expert appointed on behalf of the Council who failed to note that the floor areas for sales were less than those for used in calculation of the construction costs. Both the expert and Broadland stand by the decision. The expert stating that the sales values use internal floor areas and construction values use external floor areas. Quite frankly this type of response destroys any confidence in the planning system and questions whether statements in the Draft Plan will have any relevance.

I do not believe Councils should be considering viability for Outline Planning applications. Developers will be carrying out financial assessments which will dictate the residual value of the land, rather than an excessive land value dictating the level of affordable housing.

More worrying is that both Broadland and South Norfolk have reduced the affordable housing targets from 33% to 28% based on an assessment by officers of the 2017 SMHA report with shows an overall need of 28% for Greater Norwich. This decision has not been taken to either Council for debate or the Development Documents amended.

The GNLP assessment of the same SMHA report concludes that 33% is still required for Broadland and South Norfolk but despite being aware of this different interpretation, there are currently at least two applications within Broadland proposing 28% affordable housing without a Viability Assessment, presumably based on prior discussions with officers.

How is it possible for officer representatives from Broadland and South Norfolk on the GNDP to be supporting two opposing interpretations of the SMHA report for affordable housing requirements?

Also of concern is the fact that I wrote to the Leaders of both Council on 10 January 2010. Mr Fuller has confirmed that he is happy for Mr Vincent to reply on behalf of both Councils as he is chair for the GNDP. As of today and despite a reminder, Mr Vincent has not replied apart from an initial e-mail saying that he would look in to the matter.