Comment

Draft Black Country Plan

Representation ID: 23601

Received: 10/11/2021

Respondent: HIMOR Group

Agent: Emery Planning

Representation Summary:

Policy HOU3 — Affordable Housing
Please see our comment on affordable housing delivery in our response to Policy CSPI .
summary:
• The levels of affordable housing need in the Black Country and Walsall are very
significant. The Black Country Housing Market Assessment (BCHMA) identifies a net
need for 867 affordable homes per annum, including 154 per annum in Walsall. There
are 5,159 households on each individual Council's housing register.
• Neither the plan nor the evidence base grapples with how affordable housing needs
will be met. The evidence base should seek to identify how much affordable housing
will be delivered from the planned housing supply.
• Continued reliance upon existing sources of supply from the urban areas will deliver
levels of affordable housing that fall substantially below identified needs.
A step change in affordable housing delivery needed. This means allocating
additional sites which can viably deliver affordable housing in the plan period.