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OBJECT Llywodraeth Cymru (Mr Mark Newey)
Further clarification is required to explain what costs, related to the obligations/ contributions have been taken on board. The viability work does include this aspect but the specific costs are unclear. It is for the authorities to demonstrate what other planning obligations/contributions will, or will not cover (see also comments in relation to deliverability). Challenging targets need to be grounded in evidence and applicable to the majority of applications, whilst allowing site specific negotiations to occur, if/ where necessary (on a limited number of sites). All components of the viability evidence need to be justified.
OBJECT Home Builders Federation Ltd (Mr Mark Harris)
HBF consider that the £5,000 allowance for S106 contributions in the viability testing is too low. The draft SPG on Developer Contributions due to be prepared for the inquiry should help to clarify this. The report also identifies that a high % of units are delivered on smaller sites, the HBF believe that a number of the assumption used in the testing are taken from National Builders figures and do not fully represent the type and range of development taking place in the borough. Reconsider figures used for S106 contributions in viability report. Liaise with small builders to understand viability on small sites better and feed results into viability testing.