As has been set out above, all of the ‘Group Villages’ as defined in the settlement hierarchy are limited to developments of up to 8 dwellings or 15 dwellings in exceptional circumstances, which means that the threshold for triggering the requirement for affordable housing in these localities will not typically arise as this is currently set at a threshold of 10 dwellings. Given that the 15 dwelling threshold is envisaged in relation to single brownfield sites within settlement boundaries the level of development realised under this part of the strategy is expected to be extremely limited and any such sites are highly likely to have already been considered and proposed for allocation.
This is significant given the requirements of Paragraph 64 of the Framework which states that “Provision of affordable housing should not be sought for residential developments that are not major developments, other than in designated rural areas (where policies may set out a lower threshold of 5 units or fewer).”
The Councils’ proposed approach also appears to ignore that it would encourage piecemeal and incremental development of potentially suitable development sites across multiple applications seeking to comply with the policy criteria in proposed Policy S/SB. This would be likely to result in potentially significant cumulative levels of development wherein individual applications have been determined as being below the thresholds for affordable housing provision.
Thus, the mechanism that has been created by the policy means that there will be no affordable dwellings being provided in rural areas particularly ‘Group Villages’ over the course of the plan period, subject to rural exception and exceptional schemes being brought forward outside of the Local Plan.
Given that the evidence base for the First Proposals consultation does not cite designated rural areas as reasons to apply the lower threshold the maximum number of dwellings that has been imposed on Group Villages should be lifted to allow for sites to be viewed on their individual merits and allow for the provision of affordable housing in all areas of the district. This also complies with Chapter 11 (Making effective use of land) of the Framework which supports the 8 dwelling limit being lifted to allow for the sites to make best use of available land rather than be limited.