Object

Draft Black Country Plan

Representation ID: 44843

Received: 11/10/2021

Respondent: Ruskin Properties

Representation Summary:

We object to the inclusion of a requirement to provide M4(2) wheelchair accessible housing given that the government has not yet responded to consultation on raising accessibility standards published in December 2020. On this basis, it is not possible to know whether the provision of M4 (2) homes will become a mandatory requirement through Building Regulations be or whether planning policy will be part of the mechanism to achieve it. Such homes will be land hungry and will reduce the net density on a site overall, which has the potential to conflict with Policy HOU2 as well as impact further upon viability. This policy is premature ahead of the results of the government’s formal consultation on the provision of M4 (2) housing as part of Approved Document M of the Building Regulations.
In terms of the draft policy, support is given to the reference to M4(2) homes not being sought where schemes are not viable. However, no reference is given to local need in relation to accessible homes. This should be evidenced to.