Comment

Representation ID: 23581

Received: 08/10/2021

Respondent: Urban Remediation Ltd

Agent: Bright & Associates

1.4. POLICY HOU3 DELIVERING AFFORDABLE, WHEELCHAIR ACCESSIBLE AND SELF BUILD/CUSTOM BUILD HOUSING
1.4.1. Clarification is required concerning the phrasing of Policy HOU3 Delivering Affordable, Wheelchair Accessible and Self Build/Custom Build Housing regarding the approach to affordable housing percentages and exceptions that apply. Furthermore, the evidence for the proportion of affordable housing contributions appears to be without merit.
1.4.2. We wish to highlight the following paragraphs of Policy HOU3.
1.4.3. Affordable Housing, Paragraph 2 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:' [etc].
1.4.4. The clarification of wording relates to the emphasis of 'financially viable' and the suggested phrasing is as follows 'All developments of ten homes or more should provide a proportion of affordable housing. The minimum proportion of affordable housing that should be provided where this is financially viable is:' [etc].
1.4.5. Affordable Housing, Paragraph 2c notes that for higher value zones, it is 30% affordable housing.
1.4.6. The evidence base seems to be contrary to this. The Black Country Housing Market Assessment (Final Report) (March 2021) states at paragraph 8.7
'The total annual affordable housing need in the Black Country of 867 per year (as set out in Chapter 6) represents 21.6% of the annual dwelling growth of 4,019 in the housing market area as assessed using the revised Standard Method. It would be reasonable to expect this proportion of new housing as affordable to be delivered on a large housing site in the Black Country, where a figure of 25% would be plausible (subject to viability). The Councils can therefore be confident that the affordable housing need identified in the model will be addressed by the dwelling growth identified by the Standard Method and no adjustment is required to this figure'.
1.4.7. Accordingly, there should be a presumption to retain 25% as set out for Dudley Borough Development Strategy (Adopted March 2017). Policy L3 Affordable Housing in New Developments of which notes a 25% value of the total units. Any proportionality of affordable housing contribution should not be based on the land value mapping which at best can only be regarded as a general rule of thumb. It should be taken from the financial viability report specific to each development site which will in any event, take account of market forces and recognised land values.
1.4.8. Financial Viability Assessments, Paragraph 7 states 'On sites where applying the affordable housing or wheelchair accessibility requirements can be demonstrated to make the development unviable, the maximum proportion of such housing will be sought that will not undermine the viability of the development, subject to achieving optimum tenure mix and securing other planning obligations necessary for the development to gain planning permission'.
1.4.9. The Policy is inclusive of affordable housing, wheel chair and self build/custom build. Therefore, the wording should be altered (bold type indicates additional text) as follows: On sites where applying the affordable housing or wheelchair accessibility requirements or self build and custom build plots can be demonstrated to make the development unviable, the maximum proportion of such housing will be sought that will not undermine the viability of the development, subject to achieving optimum tenure mix and securing other planning obligations necessary for the development to gain planning permission