Policy HOU3 – Delivering Affordable, Wheelchair Accessible and Self Build / Custom Build Housing

Comment

Representation ID: 10861

Received: 16/09/2021

Respondent: Ms Leanne Bood

The planning permission system needs an overhaul so that it is easier for those with disabilities who own their own home to seek planning permission in a timely manner to modify their property to support their care needs

Comment

Representation ID: 10867

Received: 16/09/2021

Respondent: Mr Paul Rogers

Whilst the policy appears balanced and reasonable, I object to inclusion of sites DUH-206, DUH-207, DUH-208, and DUH-209 on the grounds that this combined site does not readily fulfil the accessibility criteria and encroaches unnecessarily on green belt land. Brownfield land should be redeveloped first.

Comment

Representation ID: 11098

Received: 14/09/2021

Respondent: Miss Anne Nicholls

As a disabled resident, I am aware of how residential dwellings are truly accessible. Where ever new builds are built they must be as accessible as possible and a percentage of them must include level access, wet rooms, low level counters and lifts etc.

The same must happen with any new build employment facilities as disabled people have a right to work in an accessible environment.

Consideration must be given to the surrounding infrastructure as well including dropped kerbs, crossing points and sufficient disabled parking.

Object

Representation ID: 11193

Received: 26/09/2021

Respondent: Mr Morgan Brookes

Affordable houses are already there no need to develop new sites for these. Wheel chair accessible property should be provided in schemes.

Comment

Representation ID: 11815

Received: 09/10/2021

Respondent: Mr Jack Richards

A revision of self and custom-build policy to include strategic allocations (not just 100 homes or more), be monitored in line with Authority Monitoring Report and provide affordable homes too.

Comment

Representation ID: 12304

Received: 07/10/2021

Respondent: Access in Dudley

• A big percentage, if not all new builds should be disabled friendly e.g, wider doors for wheelchair access particularly for ground floor flats/apartments or bungalows.
• Level entry access to all premises whatever they are shops, schools, Doctors, any public buildings and homes.
• There should be a variety of ‘older peoples’ or disabled people accommodation including warden supervised flats and housing complexes for those who want to live independently but required some support within their own front doors.
• Hotels should have more disabled rooms available with wet rooms and room for wheelchairs to access and get around as well as connecting rooms for those who need a carer to stay with them.
• Started homes are needed again considered people with disabilities in mind.
• More rental properties are required and again suitable housing suitable for disabilities in this sector.

Comment

Representation ID: 12641

Received: 15/10/2021

Respondent: Ms Joanne James

I wish to make you aware of a number of strong objections I have with regards to the above Black Country Plan WAL242 and the proposed development of Green Belt land.

AFFORDABLE HOUSING BCCS states that the proposed development supports the council's objective with regard to affordable housing. The proposed housing has to take into account the surrounding characteristics of each site so I would ask what the definition of affordable housing is. House prices in the area are typically anywhere between 450,000 and 800,000. I'm not sure this, on average, would be considered affordable housing.

Comment

Representation ID: 12738

Received: 06/10/2021

Respondent: Dr Gill Pearce

Allow more distance participation in council issues by email
Disabled housebound people can’t get to council meetings.

Comment

Representation ID: 13366

Received: 11/10/2021

Respondent: Mr and Mrs Margaret and William Potter

Number of people: 2

Will there be any restriction on who can purchase or rent these new homes? Some local authorities have already placed a restriction on the sale of new homes to people who already reside in the area. Otherwise there will be a chain reaction and potential purchasers are likely to appear from areas of the country where housing needs are not so crucial but the lure of the city foreshortens their daily commute.

To ask what percentage of the new homes will be allocated to Social housing and also to Aspirational housing in each Neighbourhood Area.

Support

Representation ID: 13840

Received: 11/10/2021

Respondent: Living Space Housing Ltd

Under draft Policy HOU 3, the Councils set out the minimum proportion of affordable housing as follows:
• 10% on all sites in lower value zones and brownfield sites in medium value zones;
• 20% on greenfield sites in medium value zones; and
• 30% on all sites in higher value zones.

The proposed approach towards the provision of affordable is supported, as put forward in the Black Country Viability and Delivery Study.

Object

Representation ID: 13841

Received: 11/10/2021

Respondent: Living Space Housing Ltd

However, the Councils will be aware of the national affordability crisis that exists within the housing sector and measures should be incorporate to provide better policy support for schemes proposing 100% affordable units. The Plan is currently silent in Policy terms on schemes which propose 100% affordable units.

Object

Representation ID: 13842

Received: 11/10/2021

Respondent: Living Space Housing Ltd

The draft Policy proposes the following on Wheelchair Accessibility as a minimum:
a. On all brownfield sites, and on greenfield sites in lower value zones: 20% of homes to meet the optional Building Regulations Requirement M4(2): Accessible and Adaptable Dwellings.
b. On greenfield sites in medium or higher value zones: 15% of homes to meet the optional Building Regulations Requirement M4(3): Wheelchair User Dwellings16 and all remaining homes to meet the optional Building Regulations Requirement M4(2): Accessible and Adaptable Dwellings.

Living Space would remind the Councils of the need to adequately evidence policy proposals, and no such evidence has been presented to justify the proposed requirement for M4(2) and M4(3) units. The supporting Black Country Strategic Housing Market Assessment (2021) does not evidence a local need for M4(2) and M4(3) standard units. Therefore, requesting such a high proportion of dwellings as a Policy minimum is unsound. If the Councils wish to include a policy on these standard, the policy should be more flexible and based on evidenced local need.

Object

Representation ID: 13843

Received: 11/10/2021

Respondent: Living Space Housing Ltd

Draft Policy HOU3 proposes that on all sites of 100 dwellings or more, at least 5% of plots should be made available for self-build or custom build, where there is currently an identified need. The onus of identifying areas for self and custom build is on the Council, who are required keep a register of those seeking to acquire a plot for self/custom build and give enough development permissions to meet the identified demand 2. The use of land should not be restricted by policy to deliver self and custom build, as this is not a suitable approach to the best use of land. Rather, the provision of self/custom build should only be negotiated on a demand basis as part of a planning application.

2 Under section 1 of the Self Build and Custom Housebuilding Act 2015

Comment

Representation ID: 17461

Received: 08/10/2021

Respondent: Mr Peter Orme

All housing development should be diverse with a mix of social housing and home ownership with a cost base that is reflective of the Black Country population profile. The design needs of single occupants, first time buyers through the full spectrum of life expectancy to those in elderly persons care homes. The intention that being that a fully integrated cross section community is created.

Object

Representation ID: 18562

Received: 11/10/2021

Respondent: Councillor Tim Crumpton

I am well aware that we need housing within our ward for local people to continue living in close proximity as extended families providing the care and support so vitally needed. I do however find the whole concept of ‘affordable housing’ within this consultation as being completely unable to meet our residents needs. The structure which provides for a small discount on the market price and the lack of good quality social housing is disgraceful. The chance to develop areas and take out some of the, frankly, appalling housing that this plan should be used for is sadly not being taken.

Object

Representation ID: 18573

Received: 11/10/2021

Respondent: Dudley Labour Group

Agent: Councillor Qadar Zada

Affordable Housing


The purpose of the plan is to ensure that there is a sufficient number of homes to meet housing need in Dudley. However, just as the Labour Group is not convinced that the projected need for total housing is accurate, in the absence of any transparent formula, we are also not convinced that the figures determining the percentage of affordable housing required is accurate or sufficient and we are very concerned about the lack of affordable housing identified for a borough with overall low levels of income, and for people whose economic status and employment prospects are and will continue to be affected by such factors as the pandemic and the rising cost of living. If it is accurate that
32.7% of housing needs to be affordable over the plan period under the Black Country Housing Market Assessment, we are concerned that the plan sets a minimum requirement for affordable housing on sites between 10% and 30%, which risks not meeting that target. We are concerned that these proposed homes will lead to accommodation that will attract buyers from outside of the Borough and therefore Dudley residents will be making sacrifices from which they nor their families will receive any benefit.


Furthermore, the Council is offering it’s own land for sale. So far, there has been no satisfactory response to requests to the Council to explain why land is being sold off to developers when the Council itself could borrow to build its own affordable housing for sale or rent to help achieve what we consider to be the under-estimated targets it has been set.

Support

Representation ID: 19390

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 6.8 - The approach to affordable housing provision is supported.

Object

Representation ID: 19391

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 6.10 - The 15% requirement for wheelchair user homes is too high and would result in an excess in provision, the figures for which are only accounted for by BCP allocated sites and do not take account of development outside of these allocations.

Object

Representation ID: 19392

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 6.11 - The requirement of 5% custom or self build housing for sites with 100 houses or more is too high, as demonstrated in paragraph 6.29 which references the self build and custom build registers which indicate low demand in the area for such development.

Object

Representation ID: 20041

Received: 11/10/2021

Respondent: Rt Hon Valerie Vaz

2 Evidence

The draft Plan indicates that the Government have provided the figures for housing need and yet this has not been broken down into the types of household.

The need in Walsall South is for family homes which are affordable and for social housing.
Currently there is provision for single household dwellings at Tameway Tower a large development in the Town Centre. However, there is no mention of social housing or working with Housing Associations.

Object

Representation ID: 20983

Received: 11/10/2021

Respondent: Dr Baljit Bhandal

Agent: Harris Lamb

Policy HOU3 – Delivering Affordable Housing, Wheelchair Accessibility and Self Build/Custom Build Housing, advises that 10% affordable housing will be sought on sites in lower value areas and brownfield sites in medium value zones. 20% affordable housing will be sought on greenfield sites and in medium value area. On all sites in higher value areas 30% affordable housing will be sought. That being the case, only the sites in the higher value areas deliver more than 21.6% affordable housing.
The draft Plan does not identify what proportion of the housing requirement is expected to take place in each of these zones. However, paragraph 6.4 of the Plan advises that 81% of the housing requirement is expected to be provided on brownfield land, and 19% on greenfield land. That being the case, this strongly suggests that the affordable housing policy within the Plan will be incapable of delivering a sufficient quantum of affordable housing to meet their identified need.
We are not aware of any assessment that seeks to establish the relationship between the quantum of affordable housing required by the BCHMA, and the likely level of affordable housing that it is expected by Policy HOU3 of the Plan will deliver. This is a key piece of evidence that is missing from the emerging Plan. An increase to the minimum housing requirement may be required to ensure that a sufficiently supply of affordable housing is provided.

Comment

Representation ID: 21205

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Avison Young

Policy HOU3 – Delivering Affordable, Wheelchair Accessible and Self Build / Custom Build Housing

We note that this policy requires all developments of ten homes or more to provide a proportion of affordable housing, ranging from 10% to 30% depending on (i) if the site is located in a lower or higher value zone and (ii) if the site is greenfield or brownfield. The policy goes on to say that the tenure and type of affordable homes sought will be determined on a site-by-site basis, based on national planning policy and best available information regarding local housing needs, site surroundings and viability considerations.

Our Client supports the Draft Plan’s desire to see appropriate levels of affordable housing delivered in the Black Country, as well as it’s recognition that the tenure and type of affordable dwelling will vary according to market conditions. This is a critical factor which ensures sites are able to be delivered. However, it considers that it will be important to maintain the same type of flexibility when it comes to the proportion of affordable housing a development will be required to deliver, to allow for changing local market circumstances. It is recommended that this is reflected in the policy wording.

Comment

Representation ID: 21263

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy HOU3 – Delivering Affordable, Wheelchair Accessible and Self Build/ Custom Build Housing
Policy HOU3 requires 20% affordable housing to be delivered on major greenfield sites in medium value zones. We support reference to viability within the policy and that the tenure and type of affordable homes sought will be determined on a site by site basis.

The Policy requires greenfield sites in medium value zones to deliver 15% of their homes in accordance with M4(3) regulations and all remaining homes should meet M4(2) regulations. The PPG states that Councils have the option to “set additional technical requirements exceeding the minimum standards required by Building Regulations in respect of access” where there is a justified need for this requirement (Reference ID: 56-002-20160519). The NPPF also requires all policies to underpinned by relevant and up to date evidence which should be adequate, proportionate and focused on supporting and justifying planning policies (paragraph 31). The PPG (Reference ID: 56-005- 20150327 to 56-011-20150327) sets out the evidence necessary to justifying a policy requirement for optional standards which includes:
• the likely future need;
• the size, location, type and quality of dwellings needed;
• the accessibility and adaptability of the existing stock;
• variations in needs across different housing tenures: and
• viability.

The PPG does not state what level of requirement should be required within Local Plan policies. It is considered that in requiring all new dwellings to be built to the Category M4(2) standards, it will result in larger dwellings and in turn less dwellings being delivered on sites. The NPPF is clear that planning policies should support development that makes efficient use of land (Paragraph 124). Furthermore, the BCA is constrained by Green Belt with limited brownfield redevelopment opportunities (Urban Capacity Report 2021) and the BCA is claiming that it cannot meet its own housing needs (NPPF Paragraph 125). The Council should be making the most efficient use of land on the Green Belt sites proposed to be released in order to avoid significant Green Belt release in future Local Plan Reviews. We therefore consider that the requirement to build all dwellings to Category M4(2) standards is not consistent with national planning policy.

The Policy also requires that on sites of 100+ dwellings, where there is a need for self-build and custom build plots on the Council’s register, at least 5% of plots should be made available for self-build or custom build or sufficient to match the current number on the register if lower. We object to this requirement and do not consider that the Council has provided sufficient evidence to support this approach or requirement. The Planning Practice Guidance (PPG) (Reference ID: 57-025-201760728) sets out ways in which the Council should consider supporting self and custom build which includes: developing policies in their Local Plan for self-build and custom housebuilding and “engaging with landowners who own sites that are suitable for housing and encouraging them to consider self-build and custom housebuilding” [Savills emphasis]. There is no requirement in the PPG for self or custom build plots to be provided as part of allocations and landowners should only be ‘encouraged to consider’ promoting their land for self and custom build housing.

Paragraph 6.29 states that there is a total of 32 individuals registered on Walsall’s self-build register. The register may provide an indication of the level of interest, but this needs to be analysed in further detail to uncover the specific requirements of respondents (e.g. type of property and location desired). Additionally, if all strategic sites proposed in Walsall are delivered (5,418 dwellings) and they all provide 5% self-build plots, this would equate to 271 self-build plots which is significantly greater than the number on Walsall’s housing register.

Furthermore, this register does not test whether people have the means to acquire the land and privately construct their own property. Furthermore, there are also practical issues to consider in providing self and custom building housing plots on an allocated site. For example, the day to day operation of such sites and consideration of potential health and safety issues of having multiple individual construction sites within one development. Other considerations are where a site being brought forward by a national housebuilder is the subject of a design code, what approach in the Council expecting self-build projects to take?

The provision of self or custom build plots should be the subject of discussion with those who have expressed an interest, and once the Council has an understanding of the type and range of sites that are sought allocations (for example in the form of clusters) should be identified and allocated as self and custom build opportunities around the BCA. Further clarity is request on whether the Council in its call for sites exercise sought to identify landowners willing to bring their land forward for small scale development (e.g. less than 10 dwellings) where bespoke self and custom build housing could be better delivered than simply sought through a blanket 5% request from major sites.

Comment

Representation ID: 21292

Received: 11/10/2021

Respondent: Owl Homes

Agent: Barton Willmore

Draft Policy HOU3 – Delivering Affordable, Wheelchair Accessible and Self Build / Custom Build Housing

Draft Policy HOU3 seeks to deliver a sufficient proportion of affordable and wheelchair accessible homes. It also includes provision for self-build and custom build housing.

The principle of the policy to address the specific local housing needs of the Black Country via individual developments is supported, and is considered to be consistent with National Policy (NPPF, paragraph 62). Nevertheless, in line with the NPPF and NPPG (NPPF, paragraph 34 and the NPPG ‘Viability’ see Paragraph 001 Reference ID: 10-001-20190509 and Paragraph 002 Reference ID: 10-002-20190509) the draft Policy should be fully evidenced by the supporting assessment work, particularly the Viability Assessment (May 2021) to ensure the cumulative requirements of the BCP policies do not undermine the deliverability of the Local Plan overall. Whilst the Viability Assessment appears to reflect these considerations (in Appendix 1) it notes the need for the assessment to be kept under review, particularly in light of the COVID-19 pandemic. It is recognised that viability is now to be considered ‘up front’ as part of the Local Plan process; nevertheless as the Viability Assessment still represents primarily a typology based approach, the Council’s policies should continue to offer site and scheme specific flexibility (in line with the NPPF, paragraph 57).

We therefore support the references within the draft Policy to making provision for affordable and accessible housing in line with the policy “where this is financially viable”, and to the use of financial viability assessments.

Object

Representation ID: 21347

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

POLICY HOU3 – DELIVERING AFFORDABLE, WHEELCHAIR ACCESSIBLE AND SELF BUILD / CUSTOM BUILD HOUSING
WDH notes the requirement for 30% of dwellings to be delivered as affordable houses within the Higher Value Zone “where this is financially viable.” In addition, WDH welcomes the flexibility afforded by the policy in relation to tenure splits and types of affordable houses delivered, which Policy HOU3 states will be “determined on a site by site basis, based on national planning policy and best available information regarding local housing needs, site surroundings and viability considerations.” With that said, it is important for the plan’s viability assessment to consider a range of tenure splits to ensure that they are viable on all site typologies.

In relation to accessible dwellings, Policy HOU3 requires a minimum of 15% of dwellings to be delivered to M4(3) standard, with the remainder to meet M4(2) standards within higher value zones. However, that policy requirement is not justified based on proportionate evidence as required by NPPF paragraph 35b. Rather, the SHMA suggests that there is a need for just 23% M4(2) delivery, with evidence of only limited M4(3) need. As such, the requirement for accessible housing should reflect this need, rather than being artificially boosted without any evidence or justification.

Furthermore, the level of accessible housing delivery that is defined (once justified by evidence) must be considered within a viability assessment that must demonstrate that the cumulative cost impact of all policy requirements in the plan does not render the plan unviable and thus undeliverable. However, with that said, the reference that any provision being more flexible to account for viability and site characteristics is supported.

Policy HOU3 also requires at least 5% of plots on sites of 100 dwellings or more to be made available for self-build or custom build “where there is currently a need for self-build and custom build plots identified in the self-build and custom build register for the local authority where the site is located”, “or sufficient to match the current number on the register if lower.” WDH has concerns in relation to that requirement, noting that custom and self-build (CSB) registers are not means tested, meaning an individual’s registration seldom equates to a genuine desire and ability to develop a CSB plot. Rather, registrations on CSB registers often relate to a desire for CSB housing in a specific location, rather than within estate-like housing developments. As such, to require CSB delivery when registrations are, by the BCPs own admission, “modest” when compared to neighbouring authorities does not seem to be a justified approach.

Moreover, the delivery of CSB housing is subject to practical difficulties, and is often dependent on the ability for sites to provide independent construction access and infrastructure, and deal with difficult health and safety issues. Furthermore, CSB housing has the potential to undermine the realisation of consistent design principles across a scheme, and can also negatively impact on delivery timescales. Thus, it would be more suitable for the BCAs only to support CSB housing on specific CSB housing sites, and to remove the blanket requirement of 5% CSB delivery on sites of 100+ dwellings.

Despite the above concerns, however, WDH welcomes the allowance made for financial viability assessments and the variation of actual housing delivery from the requirements set out in Policy HOU3 to a viable level. Indeed, that is an entirely appropriate and justified approach.

Comment

Representation ID: 21623

Received: 11/01/2022

Respondent: Pall Mall Investments

Agent: Highgate Land and Development

Policy HOU3: Delivering Affordable, Wheelchair Accessible and Self-Build/Custom Build Housing
Limb 1 of draft Policy HOU3 states that development sites that have ten homes or more should, where
financially viable provide a range of tenures that will meet the accommodation needs of both existing and future residents, in line with the most recently available information.
The qualification that tenure provision should be subject to the ‘viability test’ is welcomed by my client.
Limb 2 of draft Policy HOU3 states:
‘All development 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:
a. On all sites in lower value zones and brownfield sites* in medium value zones: 10% affordable housing;
b. On greenfield sites* in medium values zones: 20% affordable housing;
c. On all sites in higher values zones: 30% affordable housing.’

Limb three also states that: ‘the tenure and type of affordable housing will be determined on a site by site basis, based upon amongst other things, viability considerations.’

The requirement for viability to be considered is welcomed by my client, as the nature of sites across the Black Country will mean that there are varying degrees of viability and deliverability.
This is acknowledged at Paragraph 6.27 of the justification text to the draft policy, which states
that:
‘However, viability issues can vary significantly from site to site and are often caused by poor ground conditions, the extent of which cannot be accurately assessed until planning application stage. Therefore, to maximise delivery of affordable housing over the Plan period, it is important that affordable housing is sought on all eligible sites, that viability is assessed on a site by site basis where required, and that a flexible approach is employed wherever possible to allow for changing market conditions’.

Therefore, the findings of the draft BCP evidence base in respect of viability and the supporting policy justification text suggests that in some cases, site specific circumstances will mean that the minimum percentages in the sliding scale proposed in Limb 2 of draft Policy HOU1 will need to be ‘flexed’. Limb 2 of the draft policy should therefore be updated to make this clear, be rewording it to state that: ‘the target proportion of viability of affordable housing (subject to viability) is:’.
This refinement will ensure that the findings of the Aspinall Verdi viability study, which forms part of the evidence base of the BCP, are adequately reflected in the draft policy. This will be important particularly for sites in the Higher Value Zone areas, where the
affordable requirement is 30%.

Comment

Representation ID: 21767

Received: 11/10/2021

Respondent: St Philips

Agent: Lichfields

3.6 Draft Policy HOU3 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:
a On all sites in lower value zones and brownfield sites* in medium value zones: 10%
affordable housing;

b On greenfield sites in medium value zones: 20% affordable housing;

c On all sites in higher value zones: 30% affordable housing.”

3.7 St Philips support the BCA’s differentiated approach to the provision of affordable housing, which is justified by the Black Country Viability & Delivery Study. However, the proposed percentages set out in draft Policy HOU3 are marginally above the recommendations of the Black Country Viability & Delivery Study26.

3.8 Notwithstanding, it is noted that the Study recommends that the BCA “could therefore increase the affordable housing target to 10% in-line with national policy and consider other proactive interventions in the market to deliver the housing” (paragraph 10.24).

3.9 Additionally, the Study notes that the BCA:
“…has achieved 3.5% S106 affordable housing (as proportion of total net homes across the Black Country) over period 2010-20 - equivalent to approximately 5% on eligible sites of 10 homes or more.” (paragraph 10.52)

3.10 This further justifies the need for the BCA to provide for additional housing land supply in order to increase the provision of affordable housing. Such an approach is encouraged by the PPG27:

“An increase in the total housing figures included in the plan may need to be considered where
it could help deliver the required number of affordable homes.”

3.11 Draft Policies CSP1 and HOU1 should therefore be amended to provide additional housing land supply in order to increase the overall provision of affordable housing.

Comment

Representation ID: 21824

Received: 11/10/2021

Respondent: Dr Osman Dervish

Agent: RCA Regeneration Ltd

2.10. We are broadly supportive of the affordable housing policy but would suggest the policy is slightly reworded to make it absolutely clear that those minimum proportions should only be required where viability demonstrates it is deliverable. Setting minimum levels are laudable, but unlikely to make a difference in reality if viability is an issue (as is the case on many BC sites).
2.11. We are broadly supportive of the requirements to make more homes accessible for disabled people.
2.12. The 5% self-build requirement does raise some concerns, however - related to maintaining health and safety on large housing sites, as well as in relation to the ultimate control over phasing. Given the council's strong reliance on windfall sites - many of which are likely to be self or custom build, we cannot see why the council can justify requesting a proportion of self-build on large housing developments that are proposed for allocation.

Support

Representation ID: 21825

Received: 11/10/2021

Respondent: Dr Osman Dervish

Agent: RCA Regeneration Ltd

2.10. We are broadly supportive of the affordable housing policy but would suggest the policy is slightly reworded to make it absolutely clear that those minimum proportions should only be required where viability demonstrates it is deliverable. Setting minimum levels are laudable, but unlikely to make a difference in reality if viability is an issue (as is the case on many BC sites).
2.11. We are broadly supportive of the requirements to make more homes accessible for disabled people.
2.12. The 5% self-build requirement does raise some concerns, however - related to maintaining health and safety on large housing sites, as well as in relation to the ultimate control over phasing. Given the council's strong reliance on windfall sites - many of which are likely to be self or custom build, we cannot see why the council can justify requesting a proportion of self-build on large housing developments that are proposed for allocation.

Support

Representation ID: 22163

Received: 06/10/2021

Respondent: Marlie Civils

Agent: RCA Regeneration Ltd

We are broadly supportive of the affordable housing policy but would suggest the policy is slightly reworded to make it absolutely clear that those minimum proportions should only be required where viability demonstrates it is deliverable. Setting minimum levels are laudable, but unlikely to make a difference in reality if viability is an issue (as is the case on many BC sites).

2.23. We are broadly supportive of the requirements to make more homes accessible for disabled people.

2.24. The 5% self-build requirement does raise some concerns, however - related to maintaining health and safety on large housing sites, as well as in relation to the ultimate control over phasing. Given the council's strong reliance on windfall sites - many of which are likely to be self or custom build, we cannot see why the council can justify requesting a proportion of self-build on large housing developments that are proposed for allocation.