Comment

Representation ID: 22296

Received: 11/10/2021

Respondent: Investin PLC

Agent: Lichfields

3.6 Draft Policy HOU3 states “all developments 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 value zones: 20% affordable housing;
c. On all sites in higher value zones: 30% affordable housing.”
3.7 Investin support the BCA’s differentiated approach to the provision of affordable housing, which is justified by the Black Country Viability & Delivery Study. However, the proposed percentages set out in draft Policy HOU3 are marginally above the recommendations of the Black Country Viability & Delivery Study25.
3.8 Notwithstanding, it is noted that the Study recommends that the BCA “could therefore increase the affordable housing target to 10% in-line with national policy and consider other proactive interventions in the market to deliver the housing” (paragraph 10.24).
3.9 Additionally, the Study notes that the BCA:
“…has achieved 3.5% S106 affordable housing (as proportion of total net homes across the Black Country) over period 2010-20 - equivalent to approximately 5% on eligible sites of 10 homes or more.” (paragraph 10.52)
3.10 This further justifies the need for the BCA to provide for additional housing land supply in order to increase the provision of affordable housing. Such an approach is encouraged by the PPG26: “An increase in the total housing figures included in the plan may need to be considered where it could help deliver the required number of affordable homes.”
3.11 Draft Policies CSP1 and HOU1 should therefore be amended to provide additional housing land supply in order to increase the overall provision of affordable housing.