Comment

Representation ID: 10531

Received: 26/07/2022

Respondent: Barton Willmore

Draft Policy DM3 (Housing Mix) states that new housing developments will be expected to provide a mix of dwelling size and types to meet the identified needs of the community. The Council has produced a Local Housing Needs Assessment (April 2022 update) as part of the evidence for the policy, and refers to other current assessments of housing need including the Older Person’s Accommodation Strategy, the Learning Disabilities Accommodation Strategy, the Mental Health Accommodation Strategy (or their successor Strategies) and evidence in respect of the needs of other specialist groups.
It requires all developments of 100 dwellings or more in suitable locations, to “include specialist housing designed to meet the needs of those with a learning disability or mental health need in accordance with the Council’s most up to date statement of need:
(i) On sites of 3 or more dwellings 47% of all new residential development should meet Category 2 (Accessible and Adaptable dwellings) of approved Document M; Volume 1, and on sites of 20 or more dwellings a minimum of 4% of all market housing and 6% of affordable housing should meet Category 3 requirements,
(ii) All specialist housing for older people should meet Category 3 requirements”.
IM Land supports the principle of addressing the specific local housing needs of Bedford, and creating safe, accessible environments that promote inclusion and community cohesion.
In terms of ensuring that the policy is ‘sound’, footnote 49 of the NPPF sets out 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 (our emphasis added).
The PPG provides further clarification in terms of the necessary evidence to justify policies in relation to accessibility optional technical standards and makes reference to detailed information on the accessibility and adaptability of the existing stock and the size, how needs vary across different housing tenures and the location, type and quality of dwellings needed (Paragraph: 007 Reference ID: 56-007-20150327). Within the LHNA, an assessment of the need for accessible and adaptable dwellings is provided. However, details relating to the location, type and quality of dwellings needed should be incorporated into the Council’s supporting evidence to ensure that an appropriate evidence base is available to support any proposed policy requirements.
Whilst the LHNA and other current assessments of housing need provide a useful steer in relation to current / future demand, we consider that in order to be ‘sound’, the wording of the policy should be amended to allow for a flexible approach to the tenure requirements on a site-by-site basis e.g. to take into account specific factors which may make a site less suitable for accessible dwellings (PPG, Paragraph: 008 Reference ID: 56-008-20160519) as well as viability assessments where relevant (Paragraph 58 of the NPPF).