Where there is an identifiable affordable housing need then Richborough Estates Limited does not object to the principle of delivering affordable housing as part of an inclusive residential development. Accordingly, the principle of Policy P4 is supported. However, Richborough Estates has some constructive comments about the drafting of Policy P4.

By reason of the publication of the White Paper Fixing our broken housing market, the Borough Council will need to reconsider its approach to affordable housing provision, including the 'target' for such homes to be delivered on sites and the provision of starter homes. Based upon Richborough Estate's review of the White Paper it is now likely that the definition of affordable housing may need to change and the overall target reduced to 40%.

On the basis that the affordable housing provision can be the subject of some flexibility, it would be appropriate to express the requirement as 'Contributions will be expected to be made in the form of up-to [40%] of the proposed dwellings being for affordable housing purposes on each development site and this will take into account: ...'

Richborough Estates welcome the realism that some developments, particularly larger scale schemes, either have a higher cost of implementation or are required to deliver other benefits/infrastructure which can affect viability (criteria (iii) and (iv)). These criteria have a direct link to the 'Likely Infrastructure Requirements' column associated with the Potential Housing Allocations listed at Appendix C in the Local Plan Review document (e.g. delivery of new roads or major new community facilities). For reasons of clarity, the flexibility which might be given to the percentage of affordable housing and the precise type and tenure mix provided as part of a development should be included in Policy P4 rather than the supporting text (i.e. incorporate paragraph 194 into policy).

Although not part of the policy, paragraph 200 refers to rental housing for specific sectors of the community, namely aged and disabled people. The inclusion of such specialist types of dwellings as part of the affordable housing provision is supported by Richborough Estates. However, delivery will be dependent upon the registered providers being willing to develop and manage such homes and this needs to be recognised in Policy P4.