Black Country Core Strategy Issue and Option Report

We represent Rentplus, a company providing an innovative affordable housing model that delivers affordably rented homes to buy (a 'rent to buy' model) for people who aspire to own their own home, but are currently unable to save for a mortgage deposit.
Introduction
Enclosed with this consultation response is an Affordable Housing Statement by Tetlow King Planning setting out the model's compliance with the NPPF definition of affordable housing and how this should be incorporated into local plans to boost supply and meet local needs. We ask that this be read alongside our representation so that the Council's approach to negotiating housing takes into account this innovative model which has the capacity to improve delivery and meet high levels of local housing need and aspirations of home ownership.
Rentplus is delivering rent to buy housing that meets local peoples' needs and aspirations across England, in partnership with local planning authorities and Registered Providers, allocating housing through the local choice based lettings scheme and targeted lettings plans. Those developments provide homes at an affordable rent for those expecting to purchase in 5, 10, 15 or 20 years, with a 10% gifted deposit to assist purchase. Amending policies to be more flexible and pragmatic helps local families move out of inappropriate housing; one recently completed Rentplus scheme was 30% filled by households previously living in social and affordable rented properties, releasing those homes for families in need.
Rentplus schemes also enable people to leave housing in the private rented sector and parents' homes, gaining independence and security of tenure. With such a significant need for affordable rented properties, it is clear that there is a role for rent to buy housing to play in meeting that need, and also in enabling those households who can to achieve their aspiration to own their own home.
Flexible policies and pragmatic responses to individual applications elsewhere in England have helped people move out of inappropriate housing; 30% of those moving into a recent Rentplus scheme left existing social and affordable rented properties, releasing those homes for families in greater need. People have also been able to leave the private rented sector and parent's homes, gaining independence and security of tenure in an affordable rented home. With such difficulties delivering affordable housing in the Borough it is clear that assistance is needed to boost supply to meet local needs.
Question 1
We agree with the proposed approach to do a partial review of the adopted Core Strategy, seeking only to update those policies that require amendment in response to the emerging national planning policy framework which we expect to be formalised in an updated NPPF in late 2017 / early 2018. We recommend that the next stage of reviewing the policies take into account the Housing White Paper proposals, and the Government's response to that consultation which will form the basis for amendments to the NPPF.

As the Government is also expected to commence consultation at the end of September 2017 on a
new standardised methodology for calculating objectively assessed housing needs, it will be important
for the evidence base to be reviewed once more. This should take into account the full breadth of
tenures within the proposed affordable housing definition, though we emphasise that rent to buy
should not be considered an intermediate affordable housing tenure, but a hybrid sitting outside
affordable rent and intermediate. Need for each of the new tenures should be assessed, and
considered as part of the updated policies.
Question 39
We disagree with any approach that seeks to impose separate design and accessibility standards on
different housing tenures; this approach only serves to reduce the ability of affordable housing
providers to compete on the land market and reduces the density of housing that can be achieved on
sites where there is a difference in standards.
Question 40
As Rentplus works in partnership with locally active Registered Providers of affordable housing, there
is considerable local knowledge and experience which defines how land is bought and planning
applications brought forward. It is important to reflect this when negotiating on individual planning
applications as our experience with development plan documents that set house type targets is that
they tend to be treated too rigidly at application stage. This often causes unnecessary delay and
extended negotiation. We strongly suggest that any indication of house type mix be given in the
supporting text to the policies, and that such guidance seek house mixes that reflect the most up to
date evidence of housing need - and developer's knowledge of the local housing market.
Question 42
The Plan should continue to seek to maximise affordable housing delivery and we therefore agree
that the affordable housing target should be raised to reflect the latest SHMA findings. This is however
subject to our earlier comments seeking further review to reflect the full range of affordable housing
tenures set out in the 2017 Housing White Paper.
Questions 44a and 44b
The affordable housing threshold should be set at a level that maximises overall affordable housing
delivery across the lifetime of the Plan, ensuring that housing needs will continue to be met. It is only
possible to determine if a different percentage target figure will be appropriate when the Council has
undertaken a full viability assessment that considers all affordable housing tenures, including the
proposed requirement for 10% of delivery to be affordable home ownership tenures. We encourage
the Council to commission such a review, as this will provide the answer to the question of whether
changes in tenure mix will improve viability of housing development.

We represent Rentplus, a company providing an innovative affordable housing model that delivers affordably rented homes to buy (a 'rent to buy' model) for people who aspire to own their own home, but are currently unable to save for a mortgage deposit.
Introduction
Enclosed with this consultation response is an Affordable Housing Statement by Tetlow King Planning setting out the model's compliance with the NPPF definition of affordable housing and how this should be incorporated into local plans to boost supply and meet local needs. We ask that this be read alongside our representation so that the Council's approach to negotiating housing takes into account this innovative model which has the capacity to improve delivery and meet high levels of local housing need and aspirations of home ownership.
Rentplus is delivering rent to buy housing that meets local peoples' needs and aspirations across England, in partnership with local planning authorities and Registered Providers, allocating housing through the local choice based lettings scheme and targeted lettings plans. Those developments provide homes at an affordable rent for those expecting to purchase in 5, 10, 15 or 20 years, with a 10% gifted deposit to assist purchase. Amending policies to be more flexible and pragmatic helps local families move out of inappropriate housing; one recently completed Rentplus scheme was 30% filled by households previously living in social and affordable rented properties, releasing those homes for families in need.
Rentplus schemes also enable people to leave housing in the private rented sector and parents' homes, gaining independence and security of tenure. With such a significant need for affordable rented properties, it is clear that there is a role for rent to buy housing to play in meeting that need, and also in enabling those households who can to achieve their aspiration to own their own home.
Flexible policies and pragmatic responses to individual applications elsewhere in England have helped people move out of inappropriate housing; 30% of those moving into a recent Rentplus scheme left existing social and affordable rented properties, releasing those homes for families in greater need. People have also been able to leave the private rented sector and parent's homes, gaining independence and security of tenure in an affordable rented home. With such difficulties delivering affordable housing in the Borough it is clear that assistance is needed to boost supply to meet local needs.
Question 1
We agree with the proposed approach to do a partial review of the adopted Core Strategy, seeking only to update those policies that require amendment in response to the emerging national planning policy framework which we expect to be formalised in an updated NPPF in late 2017 / early 2018. We recommend that the next stage of reviewing the policies take into account the Housing White Paper proposals, and the Government's response to that consultation which will form the basis for amendments to the NPPF.

As the Government is also expected to commence consultation at the end of September 2017 on a
new standardised methodology for calculating objectively assessed housing needs, it will be important
for the evidence base to be reviewed once more. This should take into account the full breadth of
tenures within the proposed affordable housing definition, though we emphasise that rent to buy
should not be considered an intermediate affordable housing tenure, but a hybrid sitting outside
affordable rent and intermediate. Need for each of the new tenures should be assessed, and
considered as part of the updated policies.
Question 39
We disagree with any approach that seeks to impose separate design and accessibility standards on
different housing tenures; this approach only serves to reduce the ability of affordable housing
providers to compete on the land market and reduces the density of housing that can be achieved on
sites where there is a difference in standards.
Question 40
As Rentplus works in partnership with locally active Registered Providers of affordable housing, there
is considerable local knowledge and experience which defines how land is bought and planning
applications brought forward. It is important to reflect this when negotiating on individual planning
applications as our experience with development plan documents that set house type targets is that
they tend to be treated too rigidly at application stage. This often causes unnecessary delay and
extended negotiation. We strongly suggest that any indication of house type mix be given in the
supporting text to the policies, and that such guidance seek house mixes that reflect the most up to
date evidence of housing need - and developer's knowledge of the local housing market.
Question 42
The Plan should continue to seek to maximise affordable housing delivery and we therefore agree
that the affordable housing target should be raised to reflect the latest SHMA findings. This is however
subject to our earlier comments seeking further review to reflect the full range of affordable housing
tenures set out in the 2017 Housing White Paper.
Questions 44a and 44b
The affordable housing threshold should be set at a level that maximises overall affordable housing
delivery across the lifetime of the Plan, ensuring that housing needs will continue to be met. It is only
possible to determine if a different percentage target figure will be appropriate when the Council has
undertaken a full viability assessment that considers all affordable housing tenures, including the
proposed requirement for 10% of delivery to be affordable home ownership tenures. We encourage
the Council to commission such a review, as this will provide the answer to the question of whether
changes in tenure mix will improve viability of housing development.

We represent Rentplus, a company providing an innovative affordable housing model that delivers affordably rented homes to buy (a 'rent to buy' model) for people who aspire to own their own home, but are currently unable to save for a mortgage deposit.
Introduction
Enclosed with this consultation response is an Affordable Housing Statement by Tetlow King Planning setting out the model's compliance with the NPPF definition of affordable housing and how this should be incorporated into local plans to boost supply and meet local needs. We ask that this be read alongside our representation so that the Council's approach to negotiating housing takes into account this innovative model which has the capacity to improve delivery and meet high levels of local housing need and aspirations of home ownership.
Rentplus is delivering rent to buy housing that meets local peoples' needs and aspirations across England, in partnership with local planning authorities and Registered Providers, allocating housing through the local choice based lettings scheme and targeted lettings plans. Those developments provide homes at an affordable rent for those expecting to purchase in 5, 10, 15 or 20 years, with a 10% gifted deposit to assist purchase. Amending policies to be more flexible and pragmatic helps local families move out of inappropriate housing; one recently completed Rentplus scheme was 30% filled by households previously living in social and affordable rented properties, releasing those homes for families in need.
Rentplus schemes also enable people to leave housing in the private rented sector and parents' homes, gaining independence and security of tenure. With such a significant need for affordable rented properties, it is clear that there is a role for rent to buy housing to play in meeting that need, and also in enabling those households who can to achieve their aspiration to own their own home.
Flexible policies and pragmatic responses to individual applications elsewhere in England have helped people move out of inappropriate housing; 30% of those moving into a recent Rentplus scheme left existing social and affordable rented properties, releasing those homes for families in greater need. People have also been able to leave the private rented sector and parent's homes, gaining independence and security of tenure in an affordable rented home. With such difficulties delivering affordable housing in the Borough it is clear that assistance is needed to boost supply to meet local needs.
Question 1
We agree with the proposed approach to do a partial review of the adopted Core Strategy, seeking only to update those policies that require amendment in response to the emerging national planning policy framework which we expect to be formalised in an updated NPPF in late 2017 / early 2018. We recommend that the next stage of reviewing the policies take into account the Housing White Paper proposals, and the Government's response to that consultation which will form the basis for amendments to the NPPF.

As the Government is also expected to commence consultation at the end of September 2017 on a
new standardised methodology for calculating objectively assessed housing needs, it will be important
for the evidence base to be reviewed once more. This should take into account the full breadth of
tenures within the proposed affordable housing definition, though we emphasise that rent to buy
should not be considered an intermediate affordable housing tenure, but a hybrid sitting outside
affordable rent and intermediate. Need for each of the new tenures should be assessed, and
considered as part of the updated policies.
Question 39
We disagree with any approach that seeks to impose separate design and accessibility standards on
different housing tenures; this approach only serves to reduce the ability of affordable housing
providers to compete on the land market and reduces the density of housing that can be achieved on
sites where there is a difference in standards.
Question 40
As Rentplus works in partnership with locally active Registered Providers of affordable housing, there
is considerable local knowledge and experience which defines how land is bought and planning
applications brought forward. It is important to reflect this when negotiating on individual planning
applications as our experience with development plan documents that set house type targets is that
they tend to be treated too rigidly at application stage. This often causes unnecessary delay and
extended negotiation. We strongly suggest that any indication of house type mix be given in the
supporting text to the policies, and that such guidance seek house mixes that reflect the most up to
date evidence of housing need - and developer's knowledge of the local housing market.
Question 42
The Plan should continue to seek to maximise affordable housing delivery and we therefore agree
that the affordable housing target should be raised to reflect the latest SHMA findings. This is however
subject to our earlier comments seeking further review to reflect the full range of affordable housing
tenures set out in the 2017 Housing White Paper.
Questions 44a and 44b
The affordable housing threshold should be set at a level that maximises overall affordable housing
delivery across the lifetime of the Plan, ensuring that housing needs will continue to be met. It is only
possible to determine if a different percentage target figure will be appropriate when the Council has
undertaken a full viability assessment that considers all affordable housing tenures, including the
proposed requirement for 10% of delivery to be affordable home ownership tenures. We encourage
the Council to commission such a review, as this will provide the answer to the question of whether
changes in tenure mix will improve viability of housing development.

We represent Rentplus, a company providing an innovative affordable housing model that delivers affordably rented homes to buy (a 'rent to buy' model) for people who aspire to own their own home, but are currently unable to save for a mortgage deposit.
Introduction
Enclosed with this consultation response is an Affordable Housing Statement by Tetlow King Planning setting out the model's compliance with the NPPF definition of affordable housing and how this should be incorporated into local plans to boost supply and meet local needs. We ask that this be read alongside our representation so that the Council's approach to negotiating housing takes into account this innovative model which has the capacity to improve delivery and meet high levels of local housing need and aspirations of home ownership.
Rentplus is delivering rent to buy housing that meets local peoples' needs and aspirations across England, in partnership with local planning authorities and Registered Providers, allocating housing through the local choice based lettings scheme and targeted lettings plans. Those developments provide homes at an affordable rent for those expecting to purchase in 5, 10, 15 or 20 years, with a 10% gifted deposit to assist purchase. Amending policies to be more flexible and pragmatic helps local families move out of inappropriate housing; one recently completed Rentplus scheme was 30% filled by households previously living in social and affordable rented properties, releasing those homes for families in need.
Rentplus schemes also enable people to leave housing in the private rented sector and parents' homes, gaining independence and security of tenure. With such a significant need for affordable rented properties, it is clear that there is a role for rent to buy housing to play in meeting that need, and also in enabling those households who can to achieve their aspiration to own their own home.
Flexible policies and pragmatic responses to individual applications elsewhere in England have helped people move out of inappropriate housing; 30% of those moving into a recent Rentplus scheme left existing social and affordable rented properties, releasing those homes for families in greater need. People have also been able to leave the private rented sector and parent's homes, gaining independence and security of tenure in an affordable rented home. With such difficulties delivering affordable housing in the Borough it is clear that assistance is needed to boost supply to meet local needs.
Question 1
We agree with the proposed approach to do a partial review of the adopted Core Strategy, seeking only to update those policies that require amendment in response to the emerging national planning policy framework which we expect to be formalised in an updated NPPF in late 2017 / early 2018. We recommend that the next stage of reviewing the policies take into account the Housing White Paper proposals, and the Government's response to that consultation which will form the basis for amendments to the NPPF.

As the Government is also expected to commence consultation at the end of September 2017 on a
new standardised methodology for calculating objectively assessed housing needs, it will be important
for the evidence base to be reviewed once more. This should take into account the full breadth of
tenures within the proposed affordable housing definition, though we emphasise that rent to buy
should not be considered an intermediate affordable housing tenure, but a hybrid sitting outside
affordable rent and intermediate. Need for each of the new tenures should be assessed, and
considered as part of the updated policies.
Question 39
We disagree with any approach that seeks to impose separate design and accessibility standards on
different housing tenures; this approach only serves to reduce the ability of affordable housing
providers to compete on the land market and reduces the density of housing that can be achieved on
sites where there is a difference in standards.
Question 40
As Rentplus works in partnership with locally active Registered Providers of affordable housing, there
is considerable local knowledge and experience which defines how land is bought and planning
applications brought forward. It is important to reflect this when negotiating on individual planning
applications as our experience with development plan documents that set house type targets is that
they tend to be treated too rigidly at application stage. This often causes unnecessary delay and
extended negotiation. We strongly suggest that any indication of house type mix be given in the
supporting text to the policies, and that such guidance seek house mixes that reflect the most up to
date evidence of housing need - and developer's knowledge of the local housing market.
Question 42
The Plan should continue to seek to maximise affordable housing delivery and we therefore agree
that the affordable housing target should be raised to reflect the latest SHMA findings. This is however
subject to our earlier comments seeking further review to reflect the full range of affordable housing
tenures set out in the 2017 Housing White Paper.
Questions 44a and 44b
The affordable housing threshold should be set at a level that maximises overall affordable housing
delivery across the lifetime of the Plan, ensuring that housing needs will continue to be met. It is only
possible to determine if a different percentage target figure will be appropriate when the Council has
undertaken a full viability assessment that considers all affordable housing tenures, including the
proposed requirement for 10% of delivery to be affordable home ownership tenures. We encourage
the Council to commission such a review, as this will provide the answer to the question of whether
changes in tenure mix will improve viability of housing development.

We represent Rentplus, a company providing an innovative affordable housing model that delivers affordably rented homes to buy (a 'rent to buy' model) for people who aspire to own their own home, but are currently unable to save for a mortgage deposit.
Introduction
Enclosed with this consultation response is an Affordable Housing Statement by Tetlow King Planning setting out the model's compliance with the NPPF definition of affordable housing and how this should be incorporated into local plans to boost supply and meet local needs. We ask that this be read alongside our representation so that the Council's approach to negotiating housing takes into account this innovative model which has the capacity to improve delivery and meet high levels of local housing need and aspirations of home ownership.
Rentplus is delivering rent to buy housing that meets local peoples' needs and aspirations across England, in partnership with local planning authorities and Registered Providers, allocating housing through the local choice based lettings scheme and targeted lettings plans. Those developments provide homes at an affordable rent for those expecting to purchase in 5, 10, 15 or 20 years, with a 10% gifted deposit to assist purchase. Amending policies to be more flexible and pragmatic helps local families move out of inappropriate housing; one recently completed Rentplus scheme was 30% filled by households previously living in social and affordable rented properties, releasing those homes for families in need.
Rentplus schemes also enable people to leave housing in the private rented sector and parents' homes, gaining independence and security of tenure. With such a significant need for affordable rented properties, it is clear that there is a role for rent to buy housing to play in meeting that need, and also in enabling those households who can to achieve their aspiration to own their own home.
Flexible policies and pragmatic responses to individual applications elsewhere in England have helped people move out of inappropriate housing; 30% of those moving into a recent Rentplus scheme left existing social and affordable rented properties, releasing those homes for families in greater need. People have also been able to leave the private rented sector and parent's homes, gaining independence and security of tenure in an affordable rented home. With such difficulties delivering affordable housing in the Borough it is clear that assistance is needed to boost supply to meet local needs.
Question 1
We agree with the proposed approach to do a partial review of the adopted Core Strategy, seeking only to update those policies that require amendment in response to the emerging national planning policy framework which we expect to be formalised in an updated NPPF in late 2017 / early 2018. We recommend that the next stage of reviewing the policies take into account the Housing White Paper proposals, and the Government's response to that consultation which will form the basis for amendments to the NPPF.

As the Government is also expected to commence consultation at the end of September 2017 on a
new standardised methodology for calculating objectively assessed housing needs, it will be important
for the evidence base to be reviewed once more. This should take into account the full breadth of
tenures within the proposed affordable housing definition, though we emphasise that rent to buy
should not be considered an intermediate affordable housing tenure, but a hybrid sitting outside
affordable rent and intermediate. Need for each of the new tenures should be assessed, and
considered as part of the updated policies.
Question 39
We disagree with any approach that seeks to impose separate design and accessibility standards on
different housing tenures; this approach only serves to reduce the ability of affordable housing
providers to compete on the land market and reduces the density of housing that can be achieved on
sites where there is a difference in standards.
Question 40
As Rentplus works in partnership with locally active Registered Providers of affordable housing, there
is considerable local knowledge and experience which defines how land is bought and planning
applications brought forward. It is important to reflect this when negotiating on individual planning
applications as our experience with development plan documents that set house type targets is that
they tend to be treated too rigidly at application stage. This often causes unnecessary delay and
extended negotiation. We strongly suggest that any indication of house type mix be given in the
supporting text to the policies, and that such guidance seek house mixes that reflect the most up to
date evidence of housing need - and developer's knowledge of the local housing market.
Question 42
The Plan should continue to seek to maximise affordable housing delivery and we therefore agree
that the affordable housing target should be raised to reflect the latest SHMA findings. This is however
subject to our earlier comments seeking further review to reflect the full range of affordable housing
tenures set out in the 2017 Housing White Paper.
Questions 44a and 44b
The affordable housing threshold should be set at a level that maximises overall affordable housing
delivery across the lifetime of the Plan, ensuring that housing needs will continue to be met. It is only
possible to determine if a different percentage target figure will be appropriate when the Council has
undertaken a full viability assessment that considers all affordable housing tenures, including the
proposed requirement for 10% of delivery to be affordable home ownership tenures. We encourage
the Council to commission such a review, as this will provide the answer to the question of whether
changes in tenure mix will improve viability of housing development.

We represent Rentplus, a company providing an innovative affordable housing model that delivers affordably rented homes to buy (a 'rent to buy' model) for people who aspire to own their own home, but are currently unable to save for a mortgage deposit.
Introduction
Enclosed with this consultation response is an Affordable Housing Statement by Tetlow King Planning setting out the model's compliance with the NPPF definition of affordable housing and how this should be incorporated into local plans to boost supply and meet local needs. We ask that this be read alongside our representation so that the Council's approach to negotiating housing takes into account this innovative model which has the capacity to improve delivery and meet high levels of local housing need and aspirations of home ownership.
Rentplus is delivering rent to buy housing that meets local peoples' needs and aspirations across England, in partnership with local planning authorities and Registered Providers, allocating housing through the local choice based lettings scheme and targeted lettings plans. Those developments provide homes at an affordable rent for those expecting to purchase in 5, 10, 15 or 20 years, with a 10% gifted deposit to assist purchase. Amending policies to be more flexible and pragmatic helps local families move out of inappropriate housing; one recently completed Rentplus scheme was 30% filled by households previously living in social and affordable rented properties, releasing those homes for families in need.
Rentplus schemes also enable people to leave housing in the private rented sector and parents' homes, gaining independence and security of tenure. With such a significant need for affordable rented properties, it is clear that there is a role for rent to buy housing to play in meeting that need, and also in enabling those households who can to achieve their aspiration to own their own home.
Flexible policies and pragmatic responses to individual applications elsewhere in England have helped people move out of inappropriate housing; 30% of those moving into a recent Rentplus scheme left existing social and affordable rented properties, releasing those homes for families in greater need. People have also been able to leave the private rented sector and parent's homes, gaining independence and security of tenure in an affordable rented home. With such difficulties delivering affordable housing in the Borough it is clear that assistance is needed to boost supply to meet local needs.
Question 1
We agree with the proposed approach to do a partial review of the adopted Core Strategy, seeking only to update those policies that require amendment in response to the emerging national planning policy framework which we expect to be formalised in an updated NPPF in late 2017 / early 2018. We recommend that the next stage of reviewing the policies take into account the Housing White Paper proposals, and the Government's response to that consultation which will form the basis for amendments to the NPPF.

As the Government is also expected to commence consultation at the end of September 2017 on a
new standardised methodology for calculating objectively assessed housing needs, it will be important
for the evidence base to be reviewed once more. This should take into account the full breadth of
tenures within the proposed affordable housing definition, though we emphasise that rent to buy
should not be considered an intermediate affordable housing tenure, but a hybrid sitting outside
affordable rent and intermediate. Need for each of the new tenures should be assessed, and
considered as part of the updated policies.
Question 39
We disagree with any approach that seeks to impose separate design and accessibility standards on
different housing tenures; this approach only serves to reduce the ability of affordable housing
providers to compete on the land market and reduces the density of housing that can be achieved on
sites where there is a difference in standards.
Question 40
As Rentplus works in partnership with locally active Registered Providers of affordable housing, there
is considerable local knowledge and experience which defines how land is bought and planning
applications brought forward. It is important to reflect this when negotiating on individual planning
applications as our experience with development plan documents that set house type targets is that
they tend to be treated too rigidly at application stage. This often causes unnecessary delay and
extended negotiation. We strongly suggest that any indication of house type mix be given in the
supporting text to the policies, and that such guidance seek house mixes that reflect the most up to
date evidence of housing need - and developer's knowledge of the local housing market.
Question 42
The Plan should continue to seek to maximise affordable housing delivery and we therefore agree
that the affordable housing target should be raised to reflect the latest SHMA findings. This is however
subject to our earlier comments seeking further review to reflect the full range of affordable housing
tenures set out in the 2017 Housing White Paper.
Questions 44a and 44b
The affordable housing threshold should be set at a level that maximises overall affordable housing
delivery across the lifetime of the Plan, ensuring that housing needs will continue to be met. It is only
possible to determine if a different percentage target figure will be appropriate when the Council has
undertaken a full viability assessment that considers all affordable housing tenures, including the
proposed requirement for 10% of delivery to be affordable home ownership tenures. We encourage
the Council to commission such a review, as this will provide the answer to the question of whether
changes in tenure mix will improve viability of housing development.