Comment

Representation ID: 22780

Received: 16/03/2020

Respondent: Whitbread PLC

Agent: Savills

This representation only seeks to comment on the sections relating to affordable housing and purpose-built student accommodation (PBSA).
• In respect of the first bullet point for affordable housing, we seek the following amendment to ensure that viability considerations are captured within the Policy.

“at least 33% affordable housing on-site across the plan area, except in Norwich City Centre where the requirement is at least 28%, unless the site is allocated in this plan or a Neighbourhood Plan for a different percentage of affordable housing, and subject to viability testing in line with the NPPF”

• In terms of the PBSA section of the policy, and the last bullet point of this section, we seek the following amendment to take account of sites already allocated for PBSA as part of a mixed use allocation site and to ensure that double counting on affordable housing is avoided. We therefore suggest the following wording:

Away from UEA campus, proposals for purpose-built student accommodation will be supported where the need for the development is justified by the current or proposed size of Norwich's higher educational institutions and the proposal will:
“………make provision for the delivery of a quantum of affordable housing that would be expected if the site were developed for general needs housing, unless the site has already been allocated for purpose built student accommodation or/and where part of the broader development scheme would deliver market housing and associated affordable housing as part of the development. Such provision may be made off-site through a commuted sum as set out in supplementary planning documents”

Our comments above are made with regard to the delivery of viable development in Paragraph 57 of the NPPF.