Object

Representation ID: 13842

Received: 11/10/2021

Respondent: Living Space Housing Ltd

The draft Policy proposes the following on Wheelchair Accessibility as a minimum:
a. On all brownfield sites, and on greenfield sites in lower value zones: 20% of homes to meet the optional Building Regulations Requirement M4(2): Accessible and Adaptable Dwellings.
b. On greenfield sites in medium or higher value zones: 15% of homes to meet the optional Building Regulations Requirement M4(3): Wheelchair User Dwellings16 and all remaining homes to meet the optional Building Regulations Requirement M4(2): Accessible and Adaptable Dwellings.

Living Space would remind the Councils of the need to adequately evidence policy proposals, and no such evidence has been presented to justify the proposed requirement for M4(2) and M4(3) units. The supporting Black Country Strategic Housing Market Assessment (2021) does not evidence a local need for M4(2) and M4(3) standard units. Therefore, requesting such a high proportion of dwellings as a Policy minimum is unsound. If the Councils wish to include a policy on these standard, the policy should be more flexible and based on evidenced local need.