Policy DHG4: Accessible and Adaptable Homes (Objection)

Policy DHG4 states that "the Council adopts the Optional Buildings Regulations for Accessible and Adaptable Homes" and that "All dwellings are required to meet M4(2): Category 2 - Accessible and Adaptable Dwellings." "Only in circumstances where it can be robustly demonstrated by the applicant that it is not practicable or financially viable to deliver the provisions above or where the requirements are clearly incompatible with conserving and enhancing historic character, will new development be exempt from either or both of these policy requirements."

This policy is objected to. The DaSA and its associated evidence base have not provided sufficient evidence or justification in relation to the need for the adoption of these standards. Planning Practice Guidance Paragraph: 007 Reference ID: 56-007-20150327 sets out that the need for M4(2) and M4(3) must be demonstrated, as these are optional standards above the mandatory M4(1).

"There is a wide range of published official statistics and factors which local planning authorities can consider and take into account, including:

the likely future need for housing for older and disabled people (including wheelchair user dwellings).

Size, location, type and quality of dwellings needed to meet specifically evidenced needs (for example retirement homes, sheltered homes or care homes).

the accessibility and adaptability of existing housing stock.

how needs vary across different housing tenures.

the overall impact on viability.

An "Accessible and Adaptable Housing" Background Paper has been prepared by Rather District Council as part of the evidence base seeking to support the application of this policy. It provides evidence from a number of sources, including census data. Local Authority Housing Statistics, and household projection figures. However, the conclusions drawn from the supplied evidence amount to nothing more than conjecture.

The evidence provided shows an indication that the population across Rother will be an ageing one across the plan period, replicating the national trend. However, the implementation of the optional standards above and beyond the mandatory standard is an excessive step that does not account for the many older people who will find the higher accessibility standard that is detailed in M4(1) to be perfectly accommodative of their needs.

It is recognised that an assessment on the viability of the proposals has been conducted as part of the sustainability appraisal produced assessing the DaSA. However, there is a lack of supporting evidence, most notably a lack of evidence with regard to the existing housing stock and needs within different tenures that supports the other criteria set out in the PPG.

Therefore given the current supporting evidence base, policy requiring all new homes to be built to the requirements of M4(2) and 5% at M4(3) are insufficiently supported by the provided evidence. Therefore the Policy should be considered unsound and the requirement removed from policy.

Please see attached full representation for further information.