Object

Representation ID: 23214

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

Affordable Housing

In addition, the demand for affordable housing is a significant factor that should be considered in establishing the housing requirement. Paragraph 6.6 of the BCHMA advises that there is a requirement for 867 affordable properties per year in the Black Country. This is the equivalent of approximately 21.6% of the annualised housing requirement (including the proportion of the housing requirement that will be directed outside of the Plan area). It is expected that the principal way of delivering this affordable housing would be via Section 106 agreements.


Policy HOU3 – Delivering Affordable Housing, Wheelchair Accessibility and Self Build/Custom Build Housing, advises that 10% affordable housing will be sought on sites in lower value areas and brownfield sites in medium value zones. 20% affordable housing will be sought on greenfield sites and in medium value area. On all sites in higher value areas 30% affordable housing will be sought. That being the case, only the sites in the higher value areas deliver more than 21.6% affordable housing.

The draft Plan does not identify what proportion of the housing requirement is expected to take place in each of these zones. However, paragraph 6.4 of the Plan advises that 81% of the housing requirement is expected to be provided on brownfield land, and 19% on greenfield land. That being the case, this strongly suggests that the affordable housing policy within the Plan will be incapable of delivering a sufficient quantum of affordable housing to meet their identified need.

We are not aware of any assessment that seeks to establish the relationship between the quantum of affordable housing required by the BCHMA, and the likely level of affordable housing that it is expected by Policy HOU3 of the Plan will deliver. This is a key piece of evidence that is missing from the emerging Plan. An increase to the minimum housing requirement may be required to ensure that a sufficiently supply of affordable housing is provided.

Summary

Drawing these matters together, it is our view that the housing requirement within the plan is not justified given that it is below the minimum Standard Method requirement, and there appears to have been no supporting work undertaken to establish if there is a requirement for an uplift to the minimum Standard Method Housing target on economic of affordability grounds.