Object

Representation ID: 24373

Received: 22/03/2021

Respondent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Our previous Regulation 18 representation sought to comment on the sections relation to affordable housing
and purpose-built student accommodation (PBSA). In terms of the first bullet point of this policy, we requested
that the following wording (underlined) should be added:
“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”

The revised policy has been re-worked and now includes a section (b) relating to brownfield sites and affordable
housing. This states:
“for brownfield sites where the applicant can demonstrate that particular circumstances justify the need
for a viability assessment at decision-making stage;
 affordable housing on-site except where exceptional circumstances justify off-site provision;
 a mix of affordable housing sizes, types, and tenures in agreement with the local authority, taking
account of the most up-to-date local evidence of housing need. This will include 10% of the
affordable homes being available for affordable home ownership where this meets local needs;
 affordable housing of at least equivalent quality to the market homes on-site”

We welcome the inclusion of viability text within the policy, however, would request the below amendment on
the first bullet point to ensure that the viability testing as referred to within the NPPF is appropriately
incorporated into the policy:
“affordable housing on-site except where viability assessments or exceptional circumstances justify offsite provision”;

See attachment for full submission and suggested amendments to the policy.