Comment

Draft Black Country Plan

Representation ID: 47040

Received: 13/09/2022

Respondent: HIMOR

Agent: Turley Associates

Representation Summary:

At the current time the majority of the Councils’ proposed supply (though we dispute the scale of it) will be on brownfield land, which based on draft HOU3 will only deliver 10% affordable housing.

Any development on land which is currently in the Green Belt will be expected to deliver the higher 30% affordable housing requirement. Sandwell is only proposing 171 new homes on land currently in the Green Belt – 2% of Sandwell’s proposed supply and 0.5% of its total need.

This is against a backdrop of chronic under delivery of affordable housing in Sandwell, as demonstrated by Tetlow King’s Affordable Housing Statement (July 2020) (Appendix 1).Between 2004/05 and 2018/19, despite gross completions of 3,309 affordable homes, there has been a net reduction in -454 affordable homes from the same period. This is an impact of Right to Buy and is an issue not unique to Sandwell.

Based on the above it is absolutely necessary for Sandwell to be identifying sites which can make a more significant contribution to its affordable housing shortfall – such as HIMOR’s site at Great Barr which proposes a policy compliant 30% affordable housing provision.