Comment

Representation ID: 21624

Received: 11/01/2022

Respondent: Pall Mall Investments

Agent: Highgate Land and Development

Policy HOU3: Delivering Affordable, Wheelchair Accessible and Self-Build/Custom Build Housing
Limb 1 of draft Policy HOU3 states that development sites that have ten homes or more should, where
financially viable provide a range of tenures that will meet the accommodation needs of both existing and future residents, in line with the most recently available information.
The qualification that tenure provision should be subject to the ‘viability test’ is welcomed by my client.
Limb 2 of draft Policy HOU3 states:
‘All development of ten homes or more should provide a proportion of affordable housing, where this is financially viable. The minimum proportion of affordable housing that should be provided is:
a. On all sites in lower value zones and brownfield sites* in medium value zones: 10% affordable housing;
b. On greenfield sites* in medium values zones: 20% affordable housing;
c. On all sites in higher values zones: 30% affordable housing.’

Limb three also states that: ‘the tenure and type of affordable housing will be determined on a site by site basis, based upon amongst other things, viability considerations.’

The requirement for viability to be considered is welcomed by my client, as the nature of sites across the Black Country will mean that there are varying degrees of viability and deliverability.
This is acknowledged at Paragraph 6.27 of the justification text to the draft policy, which states
that:
‘However, viability issues can vary significantly from site to site and are often caused by poor ground conditions, the extent of which cannot be accurately assessed until planning application stage. Therefore, to maximise delivery of affordable housing over the Plan period, it is important that affordable housing is sought on all eligible sites, that viability is assessed on a site by site basis where required, and that a flexible approach is employed wherever possible to allow for changing market conditions’.

Therefore, the findings of the draft BCP evidence base in respect of viability and the supporting policy justification text suggests that in some cases, site specific circumstances will mean that the minimum percentages in the sliding scale proposed in Limb 2 of draft Policy HOU1 will need to be ‘flexed’. Limb 2 of the draft policy should therefore be updated to make this clear, be rewording it to state that: ‘the target proportion of viability of affordable housing (subject to viability) is:’.
This refinement will ensure that the findings of the Aspinall Verdi viability study, which forms part of the evidence base of the BCP, are adequately reflected in the draft policy. This will be important particularly for sites in the Higher Value Zone areas, where the
affordable requirement is 30%.