Comment

Representation ID: 22562

Received: 06/10/2021

Respondent: DNA Investment Holdings Ltd

Agent: Lavata Group Ltd

Policy HOU3 – Delivering Affordable Housing, Wheelchair Accessibility

The provision of affordable housing as well as housing built for wheelchair users is critical for the Black Country to provide adequate homes for all. We support the requirement for different levels of affordable housing based on the values of the area in which development is located. It is wholly appropriate for those areas of low value to provide a lower amount, as well as brownfield sites with low to medium values to provide the same lower amount. We note that Figure 5 shows the location of the various value zones in the Black Country. The majority of the Black Country is low to medium value. Walsall has a mix of all three zones, which seem to be fairly evenly split. Viability has always been a challenge in the Black Country and the need to differentiate land values across such a large area is a welcomed move and demonstrates that this policy has been prepared positively and with deliverability of sites in mind. We also acknowledge that flexible arrangements will be sought, thought planning agreements (S106), wherever possible to allow for changing market conditions in the future, and agree this flexible approach is appropriate as this works when markets fall as well as rise.

We are also supportive of the need for wheelchair accessible units to be based on the viability of a development rather than a blanket requirement across the Black Country.