Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9418

Received: 29/07/2022

Respondent: McCarthy & Stone Retirement Lifestyles Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The approach of requiring 100% M4(3) accessibility from older persons housing is misguided and will have a negative impact on meeting the housing need of older people and limit the options that they have.

Full text:



The Councils approach in requiring 100% M4(3) from specialised housing for older people is wholly misguided . Such housing also places a burden on specialised housing for older people in two ways (1) the actual cost of additional works, which in the absence of a Viability Appraisal has not been assessed (2) in its additional space requirements will result n a reduction in number of apartments than can be acheived affecting financial viability and operational viability (ie too few residential units will not be able to support the communal facilities required) and something which has not been considered in the Whole Plan Viability Assessment

Additional floorspace and fittings will also push up sales and rentals values making a 100% M4(3) wholly unaffordable to more people, who would otherwise benefit from the other facilities that it provides

Moreover, such an approach is totally misguided. Key points in this respect are firstly that the purpose of specialised housing for older people such as retirement and Extra Care Acomodation is to promote independence in old age thereby improving health and well being. 100% M4(3) compliance also serves to institutionalise apartments and communal spaces having a negative impact on a sense of independence. Secondly, if anything the opposite approach to “loading” specialised housing and not burdening conventional housing should be taken. This will help promote housing choice with specialised schemes being able to offer more affordable accommodation possibly with a small and justified element of M4(3) housing whilst providing housing choice in mainstream housing developments such as urban extensions for those older persons who would prefer to live in such locations and not in specialised developments.

An Appeal decision in respect of a Specialsed Older persons housing scheme in Lymington Hants APP/B1740/W/20/3265937 dated 8th June 2021, where New Forest District Council have adopted a 100% M4(3) requirement is also instructive. In allowing the Appeal, the Inspector determined

I am mindful also that the design of the appeal scheme seeks to achieve the M4(2) Optional Building Regulations standard for accessible and adaptable dwellings49 – albeit that without a condition specifying this, I accept that the Council could not enforce this standard. In any event, the proposed development would cater for a range of occupants, and not only those with impaired mobility. Consequently, I am not persuaded that a requirement for the higher optional standards to be deployed in all of the proposed dwellings would be either reasonable or necessary in this case.

The PPG also states
Local Plan policies for wheelchair accessible homes should be applied only to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling.
Paragraph: 009 Reference ID: 56-009-20150327
This is not reflected in the Councils approach