Comment

Representation ID: 23291

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

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. This approach has been adopted for viability reasons. That being the case, only the sites in the higher value areas deliver more than 21.6% affordable housing. It is appreciated that affordable housing will be provided on sites allocated for development outside of the Plan area allocated for development to support the growth of the Black Country. However, as these sites are not known there is no certainty as to how much affordable housing they will deliver. This is not, therefore, a consideration at this time.

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 the majority of the sites will provide either 10% or 20% affordable housing (if this is viable). 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 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.

Drawing these matters together, it is our view that the housing requirement within the draft 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 or affordability grounds.