Comment

Representation ID: 23331

Received: 11/10/2021

Respondent: Bloor Homes

Wheelchair Accessible Housing
Proposed Policy HOU3 requires that all developments of 10 or more dwellings should provide a proportion of wheelchair accessible housing, where this is financially viable. The minimum proportion that should be provided is 20% of dwellings to meet M4(2) on all brownfield sites and on greenfield sites in lower value zones; and 15% of dwellings to meet M4(3) and all remaining dwellings to meet M4(2) on greenfield sites in medium or higher value zones. Other than reasons of financial viability, these requirements will only be reduced where it is not practically achievable given the site’s physical characteristics; site specific factors meaning that step-free access cannot be achieved; and dwellings
that are located on the first floor or above of a non-lift serviced multi-storey development.

Whilst BHL support the provision of high-quality, well-designed and accessible housing as an integral part of housing development to meet the area’s identified housing needs, the inclusion of requirements for M4(2) and M4(3) standard dwellings within Local Plans must be robustly justified with credible evidence. BHL considers that upon review of the Black Country SHMA (2021), the evidence does not justify BCA’s proposed policy approach in relation to M4(2) and M4(3) properties. The SHMA does not demonstrate that the needs of the Black Country differ substantially to those
across the West Midlands or England.

Furthermore, BHL wish to emphasise that M4(2) and M4(3) dwellings are currently ‘optional standards’. Indeed, if the Government had intended that the evidence of an ageing population alone justified the adoption of optional standards, this would be mandatory in the Building Regulations. BHL consider that if BCA wish to impose a policy requirement for accessible and adaptable
dwellings, this should be done in accordance with paragraph 130(f) of the NPPF 2021 and Footnote 49
of the latest iteration of the NPPG. Footnote 49 states "that planning policies for housing should make use of the Government’s optional technical standards for accessible and adaptable housing where this would
address an identified need for such properties”.
Moreover, BHL has concerns that the provision of a substantial level of M4(2) and M4(3) dwellings,
particularly in development sites that deliver earlier on in the plan period, will result in such units being occupied by those who do not require housing of this kind, or will remain empty until an end user is identified. It is BHL’s position that the requirement for M4(2) and M4(3) should be based on the specific demand for housing of that kind at the time of an application’s determination. The provision of specialist housing of this nature may also make it difficult to achieve the BCA’s yield and density aspirations for allocated and windfall housing sites.