Policy H10 Accessible and Adaptable Homes
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Representation ID: 4367
Received: 16/03/2023
Respondent: Mr Stephen Jupp
Legally compliant? No
Sound? No
Duty to co-operate? No
Criterion b is pre-empting the government bringing forward into statute its responses to the consultation document.
If that is not followed through then there is no sound basis to require EVERY new dwelling to met M4(2)
Delete b or reword so that it comes into force when it is made statue or change to allow some exceptions
Criterion b is pre-empting the government bringing forward into statute its responses to the consultation document.
If that is not followed through then there is no sound basis to require EVERY new dwelling to met M4(2)
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Representation ID: 4809
Received: 17/03/2023
Respondent: Miller Homes and Vistry Group
Agent: Mr Nick Billington
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
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.
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.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Representation ID: 4980
Received: 17/03/2023
Respondent: The Planning Bureau on behalf of McCarthy Stone
Agent: Miss Natasha Styles
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Ensuring that older residents have the ability to stay in their homes for longer through the provision of wheelchair housing, is not, in itself, an appropriate manner of meeting the housing needs of older people.
A supportive local planning policy framework will be crucial in increasing the delivery of specialist older persons’ housing. Although adaptable housing can assist it does not remove the need for specific older person’s housing.
Housing built to M4(3) standard may serve to institutionalise an older person’s scheme reducing independence.
M4 (2) is to be incorporated into the Building Regulations - there is no need for the plan to repeat this element.
M43b relates to wheelchair accessible housing which can only be required on affordable housing where the Council has nomination rights. This should be clarified.
Recommendation:
The policy should be amended to reflect the building regulations so it reads as follows:
Policy H10 Accessible and Adaptable Homes
On all residential development sites:
a. 5% of affordable housing must meet wheelchair accessibility standards M4(3)((2)(b)) where there is an identified need on the Housing Register and the Council will have nomination rights.
Policy H10 Accessible and Adaptable Homes
The Council should note that ensuring that older residents have the ability to stay in their homes for longer through the provision of wheelchair housing, is not, in itself, an appropriate manner of meeting the housing needs of older people. Adaptable houses do not provide the on-site support, care and companionship of specialist older persons’ housing developments nor do they provide the wider community benefits such as releasing under occupied family housing as well as savings to the public purse by reducing the stress of health and social care budgets. The recently published Healthier and Happier Report by WPI Strategy (September 2019) calculated that the average person living in specialist housing for older people saves the NHS and social services £3,490 per year. A supportive local planning policy framework will be crucial in increasing the delivery of specialist older persons’ housing and it should be acknowledged that although adaptable housing can assist it does not remove the need for specific older person’s housing. Housing particularly built to M4(3) standard may serve to institutionalise an older person’s scheme reducing independence contrary to the ethos of older persons and particularly extra care housing.
The Council should note that M4 (2) is to be incorporated into the Building Regulations and therefore there is no need for the plan to repeat this element and this element should be removed form the plan so as not to repeat other government requirements. The Council should also note that M43b relates to wheelchair accessible housing which can only be required on affordable housing where the Council has nomination rights and this should be clarified so that this is clear to the reader.
.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Representation ID: 5150
Received: 16/03/2023
Respondent: Home Builders Federation
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Policy should be amended to reflect changes to Building Regulations
19. Last year the Government published its response to the consultation on the building regulations governing accessibility - Part M . This response states that the Government will make part M4(2) the mandatory standard. Whilst this is still to be introduced, given the likelihood that the Government will make M4(2) the mandatory standard we would recommend that the Council amend its policy accordingly to ensure no unnecessary repetition of building regulations within planning policy.
Policy should be amended to reflect changes to Building Regulations, ensure no unnecessary repetition of building regulations within planning policy.
See attachment.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Representation ID: 5414
Received: 17/03/2023
Respondent: Bellway Homes (Wessex) Ltd
Agent: Chapman Lily Planning
Legally compliant? Yes
Sound? Not specified
Duty to co-operate? Yes
Have significant reservations in terms of policy's practicality - compliance with M4(2) typically results in a 10% increase in floorspace over and above standard market house types, with a commensurate increase in build costs - seldom reciprocated in an increase in GDV. Will be important to test implications of requirement on whole plan viability, isn’t clear whether this has been modelled. Consider would be more appropriate for only a proportion of dwellings to be M4(2) see draft Gosport Local Plan and Havant Housing Delivery Position Statement. Should M4(2) compliance be enforced through Part M of building regulations, would be inappropriate to duplicate matters covered (paragraph 16f of the NPPF) in National Policy.
See attachment.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Representation ID: 5620
Received: 17/03/2023
Respondent: Thakeham Homes
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Part b is too onerous for developers. Majority of other Local Planning Authorities in the South only require a percentage of the development to be to M4(2) standards and this is commonly over a threshold for development size for example on developments larger than 20 or 50 dwellings. Requiring dwellings to be constructed to M4(2) standards requires plots to have a larger footprint and therefore impacts the number of houses and the viability of developments.
Part b of the policy should be re-worded to allow for 10% percent of dwellings on developments over 20 dwellings to accord to M4(2) standards.
See attached representation.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Representation ID: 5660
Received: 17/03/2023
Respondent: Countryside Properties
Agent: Turley
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
We note the Government has published its response to the consultation on the building regulations governing accessibility - Part M . This response states that the Government will make part M4(2) the mandatory standard. Whilst this is still to be introduced, given the likelihood that the Government will make M4(2) the mandatory standard we would recommend that the Council amend its policy accordingly to ensure no unnecessary repetition of building regulations within planning policy.
See attachment.
Object
Chichester Local Plan 2021 - 2039: Proposed Submission
Representation ID: 5734
Received: 17/03/2023
Respondent: Metis Homes
Agent: Nova Planning
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The Government has published its response to the consultation on Building Regulations - Part M. This response states that the Government intends to make part M4(2) the mandatory standard.
Would recommend that the Council amend its policy to ensure no unnecessary repetition of Building Regulations within planning policy.
See attachments.
Support
Chichester Local Plan 2021 - 2039: Proposed Submission
Representation ID: 6039
Received: 17/03/2023
Respondent: Miller Homes and Vistry Group
Agent: Mr Nick Billington
Support in principle
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.