Unsound: (i) not consistent with national policy (ii) not justified: not found on a robust evidence base, and (iii) not effective; not deliverable/flexible.

We are pleased to see that the policy includes the ability for the possible relaxation of the proposed minimum percentage requirements for affordable housing where a viability review/economic viability calculations justifies this. This is particularly pertinent in the current economic climate. Affordable housing is just one of potentially a large range of planning obligation or infrastructure requirements for larger development sites, and the combined cost implications of such requirements need to be taken into account to ensure that a site does not become unviable.

However, national planning policy set out in PPS 3 paragraph 29 requires that local authorities take account of economic viability when setting affordable housing targets in their Local development documents. The target of at least 35% affordable housing for developments of 15 or more units must therefore be based upon/justified by a robust and up-to date local viability appraisal undertaken by the council.

The council do not seem to have undertaken its own Affordable Housing Economic Viability Assessment. It seems that you are relying on the East of England figure which in itself suggests no understanding of viability issues locally, and The Thames Gateway South Essex Strategic Housing market Assessment which is not a viability appraisal document (see paragraph 4.30 of the Core Strategy).

With no viability assessment the policy is unsound and does not comply with the requirements of PPS 3. An Affordable Housing Economic Viability Assessment must be undertaken to inform the appropriate percentage requirement of affordable housing.

Furthermore, the wording on viability in the policy should be objective, and we submit that it should be amended so that subjective wording is deleted.

The following amendments should be made:

• Delete at the beginning of the policy the words "at least"
• Delete within the first sentence of the third paragraph the word "highly", and in the same sentence (third line of the paragraph), the word "definitely"
• Delete the words "rendering the site undeliverable" from the same sentence (4th line of that paragraph)

We also consider that the balance of affordable housing specified as "80% social housing and 20% intermediate" is too high (no shared ownership), but that in any case, should not be specified in this policy. Affordable housing need changes over time. Therefore we suggest that the policy should state that the make up of affordable housing should be determined at the time at which a detailed masterplan or planning application is considered for a site (certainly for larger sites), based on identified affordable housing needs at that time.

We would also comment that the insistence on a minimum level of affordable housing for a site should not be used to hold up delivery of those housing requirements set within the East of England Plan (the importance of delivering RSS housing requirements often seems to get forgotten in debates about affordable housing percentages). Housing delivery is an equally important national issue.