If CDC do consider it necessary and justified to require a proportion of M4(2) housing to be delivered ahead of any Building Regulations changes, the policy should be made more flexible to make it clear that such provision is subject to technical feasibility and ideally a more realistic proportion.

Whilst supportive in principle of providing accessible and adaptive housing, Miller and Vistry have concerns about the implications and soundness of the policy requirement for all dwellings to meet the M4(2) accessibility and adaptability standards. The supporting text to the policy 5.53 highlights current national consideration of changes to Building Regulations in relation to M4(2) standards. It is through the national building regulations that such standards should be implemented, particularly where they are proposed to be mandatory for all dwellings. Such an approach also does not take account of the technical and financial implications of a blanket approach or potential implications on the land take required having regard to the need to make the most efficient use of land. It is also not clear how payment of a commuted sum (the calculation for which should form part of the plan) would meet the tests.