Object

Representation ID: 43865

Received: 05/10/2021

Respondent: Taylor Wimpey

Agent: Pegasus

7.8 Policy HOU3 deals with affordable, wheelchair accessible and self-build/custom-build housing. It indicates that developments of 10 or more homes should provide for affordable housing and makes clear that the tenure and type of affordable homes will be determined on a site-by-site basis, based on national planning policy and best available information regarding housing needs, site surroundings and viability considerations. Taylor Wimpey supports this approach.
7.9 The Policy goes on to indicate that all developments of 10 or more homes should provide a proportion of wheelchair accessible housing equating to 20% of homes on all brownfield sites and on greenfield sites in lower value zones. In other locations greenfield sites should provide a minimum of 15% of homes to meet the optional Building Regulations Requirement M4(3): Wheelchair User Dwellings and all remaining homes to meet the optional Buildings Regulations Requirement M4(2): Accessible and Adaptable Dwellings. The supporting text sets out that the Black Country SHMA concludes that 17,866 accessible and adaptable homes, including 1,674 wheelchair user homes, will be required by 2039. The text also indicates the provision of new homes meeting the standards would reduce the need for adaptations to be retrofitted to existing stock and would make the housing stock more responsive to the evolving needs of the local population.
7.10 However, the identified demand for wheelchair user homes (1,674 dwellings) would be significantly exceeded due to the application of the policy. If 15% of homes on the housing allocations identified in the Plan were delivered in accordance with this part of the policy, it would equate to 2,196 dwellings (assuming the overall supply would consist of 14,641 dwellings allocated in the Plan). This demonstrates that the policy approach would deliver significantly in excess of the requirement based on just specifically allocated sites and to the exclusion of housing delivered via windfalls, core regeneration areas and strategic centres and development on occupied employment land. This demonstrates that the approach goes beyond what is necessary and places an additional cost burden on all new housing development, thus increasing the cost of new homes, which is not appropriate based on the clear viability difficulties associated with certain locations in the Black Country to deliver new homes. Similarly, the requirement for all dwellings to meet the M4(2) standard is unsupported by evidence of need for such accommodation at the scale indicated in the Policy.