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4.12.5<br />

4.12.6<br />

4.12.7<br />

The Gloucestershire SHMA 2014, updated in<br />

September 2015, provides evidence relating<br />

to affordable housing needs in the <strong>JCS</strong> area.<br />

It includes a Long-Term Balancing Housing<br />

Markets (LTBHM) model which informs this<br />

policy by providing an indication of the levels of<br />

affordable housing required from 2013-2031 to<br />

achieve a balanced housing market. Policy SD12<br />

has also been informed by:<br />

• Planning commitments at the base date of<br />

the LTBHM model (2013);<br />

• The composition (by site size) of expected<br />

housing delivery over the plan period,<br />

based on Policy SP2. This includes<br />

assumptions about district capacity and<br />

windfall development that are informed by<br />

assessments of land availability and past<br />

trends in housing delivery;<br />

• An assessment of the viability of the <strong>JCS</strong><br />

affordable housing policy and of the <strong>JCS</strong> as<br />

a whole, taking account of the cumulative<br />

requirements of all policies and the<br />

potential for Section 106 and Community<br />

Infrastructure Levy contributions.<br />

The policy reflects a strategic partnership<br />

approach to affordable housing delivery across<br />

the <strong>JCS</strong> area. This consistency of approach will<br />

help to ensure that full housing needs can be<br />

met in a way that supports urban regeneration<br />

and does not place onerous requirements<br />

on any individual local authority. The latest<br />

evidence from the 2015 SHMA, which emerged<br />

through the <strong>JCS</strong> examination, determined that<br />

there is a need for 638 affordable houses per<br />

year across the <strong>JCS</strong> area.<br />

Viability is key factor in a sites ability to<br />

contribute towards affordable housing needs<br />

and an important consideration in setting the<br />

appropriate level of contributions from new<br />

development. The latest viability evidence<br />

presented by the ‘Plan Viability, Community<br />

Infrastructure Levy and Affordable Housing<br />

Study’ (February 2016) demonstrates that<br />

viability across the <strong>JCS</strong> area and between<br />

different development types can differ<br />

significantly. Sites across the <strong>JCS</strong> area will be<br />

able to contribute to affordable housing to<br />

a greater or lesser degree depending on the<br />

circumstances of each case. The viability and<br />

infrastructure challenges need to be taken into<br />

account when considering how to meet the<br />

overall need for affordable housing across the<br />

wider area.<br />

4.12.8<br />

4.12.9<br />

4.12.10<br />

Policy SD12 reflects the need to ensure that<br />

smaller residential developments remain<br />

viable while still contributing towards essential<br />

infrastructure needs. For this reason, affordable<br />

housing is not required on sites of 0-10<br />

residential units. This is in accordance with<br />

national policy and guidance. The policy also<br />

reflects the viability of differing value areas<br />

that exist across the <strong>JCS</strong> and as such requires<br />

that sites of 11 or more dwellings provide<br />

a 40% contribution within Cheltenham and<br />

Tewkesbury, but only a 20% contribution<br />

within Gloucester.<br />

The Strategic Allocations in the <strong>JCS</strong> present<br />

altogether different viability considerations<br />

from the rest of the area. The latest viability<br />

work evidences that, for Strategic Allocations,<br />

a 35% affordable housing contribution could<br />

be viable. However, it is recognised that<br />

each of these allocations will have their own<br />

individual deliverability and viability challenges.<br />

Therefore there will need to be balance<br />

between infrastructure provision and affordable<br />

housing in the context of deliverability. Some<br />

development proposals on the Strategic<br />

Allocations may be able to achieve greater<br />

than 35% affordable housing, while others<br />

may require a greater focus on infrastructure<br />

provision to deliver the site leading to a lower<br />

affordable housing contribution. Each proposal<br />

will be submitted with detailed viability evidence<br />

to determine the appropriate balance.<br />

National Planning Practice Guidance states that<br />

affordable housing contributions should not<br />

be sought from developments of 10 units or<br />

less and this has been reflected in this policy.<br />

However, the guidance also sets out that, in<br />

designated rural areas (section 157(1) of the<br />

Housing Act 1985), local planning authorities<br />

may choose to apply a lower threshold of 5<br />

units or less. If the 5 unit threshold is applied,<br />

payment of affordable housing and tariff style<br />

contributions on developments of 6 – 10 units<br />

should be sought as a cash payment only. There<br />

are areas within the <strong>JCS</strong> that would fall under<br />

this rural area designation, such as the Cotswold<br />

AONB, and therefore each authority may choose<br />

to apply a lower threshold where appropriate.<br />

Further detail and policies may be provided<br />

through the district-level plans.<br />

4.12.11 In accordance with Policy SD11, a flexible<br />

approach is taken to the mix of housing tenures,<br />

types and sizes to be provided. This will allow<br />

local authorities and developers to refer to the<br />

most up-to-date evidence on housing need<br />

and to take account of the local context. For<br />

development at Strategic Allocations it will<br />

usually be necessary to consider the needs of<br />

more than one local authority area.<br />

Gloucester, Cheltenham and Tewkesbury Joint Core Strategy 2011-2031<br />

Adopted December 2017<br />

69

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