Local Government, Environmental Affairs and Development Planning

1. What progress has been made to date with the finalisation of the Inclusionary Housing Policy as developed by his Department?

The draft Western Cape Inclusionary Housing Policy Framework is being finalised for submission to Cabinet for approval, in March/ April 2022. The draft Policy Framework has been revised based on input received from the public, during the sixty day public comment period.

2. What has been the response of stakeholders to the draft policy published for comments and input?

The Department received 34 written submissions, most of which were substantial in content. Comments were received from a broad cross-section of society:

Figure 1: Comments received on the draft Western Cape Inclusionary Hosing Policy Framework by sector of society.

The majority of comments received were positive or neutral in tone, the latter offering constructive inputs towards the improvement of the draft Policy Framework:

 

Figure 2: The tone of comments received from different sectors of society

The nature of the comments can be summarised by themes relating to supporting the need for spatial transformation, the legal basis for inclusionary housing, inter-governmental relations, distrust in government’s ability to implement inclusionary housing policy, feasibility concerns and general affirmation for the need for and importance of such a policy and the proposed approach contained in the draft Western Cape Inclusionary Housing Policy Framework made available for public comment.

 

Figure 3: Comments by Sector of Society and Theme

 

3. How important it is for all local governments in the province to adopt this policy or to develop similar policies in line with the principles contained in the provincial policy?

 

Inclusionary housing, as a mechanism, works with active property markets where there is demand for open market residential units, an appetite in the private sector to develop, and a demand for, and shortage of, affordable or “gap housing”. For this reason, not all municipalities may have sufficiently active property markets where such a mechanism can work.

 

The Policy Framework proposes that municipalities undertake a housing market study for their primary city/ town in order to understand the opportunity and need for an inclusionary housing policy. Municipalities are also advised to undertake feasibility studies to understand whether land and property values and the costs of development are such that it is feasible to require privately-led development to develop inclusionary housing units, without compromising developer’s return on investment to the point that they are disincentivized from developing at all. This evidence will determine the feasibility of an inclusionary housing policy for that municipality.

At the same time, all municipalities (and all spheres of government) are required to pursue spatial justice and spatial sustainability and efficiency in their planning and land use management. Specifically, all municipalities must:

• include provisions to promote the inclusion of affordable housing in residential land development;
• include land use and development incentives to promote the effective implementation of the spatial development framework and other development policies;
• include land use and development provisions specifically to promote the effective implementation of national and provincial policies;
• give effect to municipal spatial development frameworks and integrated development plans. (SPLUMA, 2013)

Therefore, while inclusionary housing is a mechanism to implement these requirements, all municipalities must pursue creating better located affordable housing. The Policy Framework identifies different ways in which municipalities can do this.

4. How will local authorities be lobbied in order for this policy to be rolled out to local governments in the province?

The Western Cape Government (Department of Environmental Affairs & Development Planning and the Department of Human Settlements) is already partnering with four municipalities to support them to consider the scope for introducing an inclusionary housing policy, by commissioning housing market studies for each of the towns within these municipalities. It is hoped that it will be possible to continue this support in other towns and give further support to the initial four municipalities depending on the findings of the housing market studies.

The DEA&DP plays a support, monitoring and oversight role in spatial planning and land use management. This role is brought to bear in the role the DEA&DP plays in assisting municipalities with their Municipal Spatial Development Frameworks and overseeing compliance of these Frameworks to SPLUMA which requires them to designate areas where a national or provincial inclusionary housing policy may apply (SPLUMA, 2013 section 21 (i)) and supporting ongoing efforts to realise the expectations of land use management systems set out in SPLUMA. It also uses standing forums it convenes to encourage municipalities and share information.

The draft Western Cape Inclusionary Housing Policy Framework identifies a programme of activities where the WCG will support municipalities to develop inclusionary housing policies and there are resources external to the WCG that have been made available to at least two municipalities in the Western Cape through partnerships with the NGO sector and National Treasury’s Cities Support Programme. 

With the introduction of the Western Cape Inclusionary Housing Policy Framework, this also becomes the basis for broader society to lobby municipalities for policies that enable better located affordable housing.