Comment

Representation ID: 21292

Received: 11/10/2021

Respondent: Owl Homes

Agent: Barton Willmore

Draft Policy HOU3 – Delivering Affordable, Wheelchair Accessible and Self Build / Custom Build Housing

Draft Policy HOU3 seeks to deliver a sufficient proportion of affordable and wheelchair accessible homes. It also includes provision for self-build and custom build housing.

The principle of the policy to address the specific local housing needs of the Black Country via individual developments is supported, and is considered to be consistent with National Policy (NPPF, paragraph 62). Nevertheless, in line with the NPPF and NPPG (NPPF, paragraph 34 and the NPPG ‘Viability’ see Paragraph 001 Reference ID: 10-001-20190509 and Paragraph 002 Reference ID: 10-002-20190509) the draft Policy should be fully evidenced by the supporting assessment work, particularly the Viability Assessment (May 2021) to ensure the cumulative requirements of the BCP policies do not undermine the deliverability of the Local Plan overall. Whilst the Viability Assessment appears to reflect these considerations (in Appendix 1) it notes the need for the assessment to be kept under review, particularly in light of the COVID-19 pandemic. It is recognised that viability is now to be considered ‘up front’ as part of the Local Plan process; nevertheless as the Viability Assessment still represents primarily a typology based approach, the Council’s policies should continue to offer site and scheme specific flexibility (in line with the NPPF, paragraph 57).

We therefore support the references within the draft Policy to making provision for affordable and accessible housing in line with the policy “where this is financially viable”, and to the use of financial viability assessments.