On 28 February 2018, the City of Johannesburg (the City) published an invitation for interested parties to comment on its draft inclusionary housing policy, entitled Draft Inclusionary Housing: Incentives, Regulations and Mechanisms. The draft policy, which was published in terms of the Spatial Planning and Land Use Management Act 16 of 2013 (SPLUMA), makes provision for various incentives, mechanisms and regulations associated with inclusionary housing in the City. In particular, the policy makes it mandatory for any property development in the City that consists of ten or more dwelling units to include at least 20% inclusionary housing.
The Socio-Economic Rights Institute of South Africa (SERI) has submitted written comments on the draft policy after reviewing it and attending a presentation and discussion workshop, hosted by the City of Johannesburg and the South African Research Chair on Spatial Analysis and City Planning (SA&CP), on the draft inclusionary housing policy at the University of the Witwatersrand on 20 April 2018.
SERI's submission welcomes the spirit of the draft policy, which clearly attempts to address the acute lack of rental housing that caters for poor and low-income households in the City in a manner that promotes spatial justice. However, the submission also raises a number of concerns with the policy. In particular, the policy fails to ensure that inclusionary housing units are made available to low-income households (households earning less than R3 200 a month); does not link the rental in inclusionary housing to household income; and lacks accountability or enforcement measures to ensure that property developers, social housing institutions and body corporates comply with the policy.