Comment

Representation ID: 23330

Received: 11/10/2021

Respondent: Bloor Homes

BHL recognise the importance of providing an appropriate mix and amount of affordable housing as
part of meeting BCA’s identified housing needs, and in particular recognise the significance of meeting the housing needs of specific groups within society in accordance with NPPF paragraph 61. Although BHL supports BCA’s differentiated approach, it is noted that the proposed percentages are in excess of the recommendations of the Black Country Viability and Delivery Study. Further clarification on this is requested.

Additionally, in accordance with paragraph 16(d) of NPPF 2021, policies should be unambiguous and
clearly written, so it is evident how a decision maker should react to development proposals. BHL considers that the type and tenure of affordable housing sought is ambiguous: BCA should provide further clarification of its requirements which should be justified by supporting evidence.

Notwithstanding the above points, the requirements in relation to affordable housing delivery and mix, will need to be tested alongside the other policy requirement set out in the plan through a full Viability Assessment that should seek to ensure that the total cumulative cost of all relevant policies will not undermine deliverability of the plan.