Richborough agrees with the assertion that sites in the urban core area are likely to have greater viability constraints due to costs associated with demolition and site remediation as well as the usual obligations relating to the provision of affordable housing and infrastructure requirements. A Viability Assessment which considers the whole plan, including the ability of sites to meet requirements in respect of sustainable construction, accessibility and dwellings standards should be undertaken.
Whilst urban regeneration schemes help deliver housing in sustainable locations and at higher densities, the lead-in times for urban sites where there are technical or ownership challenges to overcome can impact the rate of housing delivery. Too much reliance on urban sites in the Local Plan trajectory should be avoided, as much needed housing may be slow to be delivered.
Richborough also questions the suggested capacity of sites in the urban area given the Council’s clarification that 109 of the housing sites in this area have not been proposed by landowners or promoters and cannot therefore be classed as available (paragraph 3.1.5 of the LAA Interim Report). These sites have most likely been available for several years without development coming forward despite Development Briefs being prepared and rising house prices in the areas generally. Many of these sites also currently appear to be in alternative uses with no certainty they will come forward at all. There does not appear to have been any consideration of implications for current uses. The Stage 2 Assessment will clearly need to rigorously assess the urban sites given the breadth of constraints in respect of suitability, availability and viability concerns.