Support

Representation ID: 44842

Received: 11/10/2021

Respondent: Ruskin Properties

Support is given in principle to draft Policy HOU3 reducing the provision of affordable housing on brownfield sites to 10%, where this is financially viable. Whilst the Black Country level work on viability provides a snapshot of the percentage of affordable housing that land can yield based upon land values, this work will not have been informed by intrusive site investigation work to quantify actual costs of redevelopment and therefore whether affordable housing can be delivered.
In our experience, none of our brownfield sites have been able to provide any planning obligations and this has been successfully negotiated at the planning application stage. To further incentivise the redevelopment of brownfield sites before greenfield and to support the regeneration agenda further, it would be preferable if this policy was amended so that affordable housing was exempt on brownfield sites with a greater burden placed on greenfield sites where abnormals costs will be less and sales values likely higher.