8. Do you agree with Policy P21. If not why not and what alternative would you suggest?
8.1 Policy P21 sets out the Council's intention to seek either on site delivery of financial contributions through planning obligation delivery of physical, social, green and digital infrastructure. The Infrastructure Delivery Plan (IDP) 2012 provides a baseline of the infrastructure needs of the Borough,
8.2 Whilst BDW and Gallagher Estates Ltd are supportive of the need for new development to deliver appropriate infrastructure and facilities to meet the needs of new residents, the implementation of Policy P21 must also take into account development viability.
8.3 In this respect, paragraph 173 of the NPPF is clear that;
"Plans should be deliverable. Therefore the sites and scale of development identified in the plan should not be subject to such a scale of obligations and policy burdens that their ability to be delivered viably is threatened"
8.4 The needs for effective assessment of the impact of such obligation is set out at paragraph 174, which advises that;
"They should assess the likely cumulative impact on development in their area of all existing and proposed local standards, supplementary planning documents and policies that support the development plan, when added to nationally required standards. In order to be appropriate, the cumulative impact of these standards and policies should not put implementation of the plan at serious risk"
8.5 The would appear to be no specific evidence base document to test the impact of infrastructure provision or the requirements of the IDP upon the viability of residential development in the Borough.
8.6 Whilst the Council's CIL Charging Schedule has been through EiP and has been subject to viability modelling, it is not clear that this is the case with regard to potential obligations in relation to site specific proposals.
8.7 In the absence of viability modelling, policy 21 is unsound as it is not justified or based upon an appropriate evidence base and is not in compliance with national policy.
Actions required to achieve soundness
8.8 Policy 21 should be amended to state;
"Where it is viable to do so, new development will be expected to provide or contribute towards provision of;"