Policy H10 Accessible and Adaptable Homes

Showing comments and forms 1 to 9 of 9

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

Representation Summary:

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)

Change suggested by respondent:

Delete b or reword so that it comes into force when it is made statue or change to allow some exceptions

Full text:

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

Representation Summary:

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.

Change suggested by respondent:

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.

Full text:

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.

Attachments:

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

Representation Summary:

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.

Change suggested by respondent:

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.

Full text:

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.

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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

Representation Summary:

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.

Change suggested by respondent:

Policy should be amended to reflect changes to Building Regulations, ensure no unnecessary repetition of building regulations within planning policy.

Full text:

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

Representation Summary:

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.

Full text:

See attachment.

Attachments:

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

Representation Summary:

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.

Change suggested by respondent:

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.

Full text:

See attached representation.

Attachments:

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

Representation Summary:

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.

Full text:

See attachment.

Attachments:

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

Representation Summary:

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.

Change suggested by respondent:

Would recommend that the Council amend its policy to ensure no unnecessary repetition of Building Regulations within planning policy.

Full text:

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

Representation Summary:

Support in principle

Full text:

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.

Attachments: