The report was compiled by Arcadis Consulting (UK) Limited, who were commissioned by the Welsh Government in April 2016 to undertake the research. The purpose was to identify reasons why housing allocations or commitments that are assessed as deliverable during the Local Development Plan (LDP) process are becoming stalled due to viability issues at later planning stages; and to make recommendations in respect of further changes to planning policy, processes and/or behaviours, which address the research findings.
It also makes recommendations covering all stages of the planning process, from site identification during the preparation of a LDP, to the assessment of sites at the development management stage.
HBF sat on the project steering group which met three times to monitor progress and comment on the various stages and drafts of the work. Members were also contacted directly by the Consultants and given the opportunity to contribute comments.
The report concludes that viability is clearly an important consideration in planning, and at all stages of the planning process, from LDP preparation through to development management. Evidencing viability and deliverability to the extent that it creates certainty is becoming more critical, in order to deliver regeneration objectives, provide infrastructure and bring sites forward for development. However it is also clear from the research that viability is a complex issue, and that there is evidence of a real disconnect between the aspirations of housebuilders/developers on the one hand and local planning authorities on the other. It identifies that open and positive engagement between stakeholders in the planning process appears to be a relatively rare occurrence. Ultimately, a lack of certainty about how and when sites may come forward for development may undermine the robustness of the development plan process, creating uncertainty and prolonged negotiations for later development management stages, making the JHLAS process a less effective tool for monitoring housing land supply, and with knock-on effects on housing delivery.
Although HBF generally welcome the findings of the report, we have some concerns about how some of the recommendations will work in practice, particularly taking into account the current resource issues being experienced by Local Planning Authorities (LPAs). These include:
Developers / Site Promoters to submit a Residual Land Value appraisal at candidate site, based on methodology and requirements identified by the LPA on a Wales-wide basis.
Outline viability assessments to be prepared by the LPA in conjunction with developers / site promoters for strategic sites prior to their allocation in the Local Development Plan (LDP).
Early and effective involvement of statutory undertakers in LDP preparation is required to help overcome uncertainties over strategic infrastructure costs.
Statements of Common Ground to be prepared for individual sites, covering the key components of viability and deliverability.
We are also particularly concerned about recommendation no. 14 which states:
Viability assessments prepared to accompany planning applications should be available in the public domain in order to promote greater transparency.
The Welsh Government are planning two dissemination events on the 7 February – Llandudno Junction and 10 February – Cardiff, an invite and details of the events have been circulated to members today.
Home Builders Federation
London, SE1 9PL
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