Sevenoaks District Draft Local Plan Consultation July 2018

Document Section Draft Local Plan July 2018 Providing for Housing Choices Market and Affordable Housing Mix Policy 8 - Market and affordable housing mix [View all comments on this section]
Comment ID DLPP812
Respondent HBF (Mark Behrendt ID-2007) [View all comments by this respondent]
Response Date 19 Sep 2018
Current Status Accepted

Paragraph 56-007 of PPG requires local authorities to demonstrate the need for the
optional technical standards to be applied to new homes. This evidence should include
the likely future need for housing for older and disabled people, the accessibility and
adaptability of existing stock, the different needs across tenure and the overall impact on
viability. We can find no clear analysis within the Council’s evidence base as to whether
they have considered the full range of evidence required by PPG to justify this policy. We
recognise that the viability study is still to be produced and it is essential that these, and
indeed all other policy costs, are considered within this study to ensure their cumulative
impact does not make development unviable.
When seeking to apply the optional standards for accessibility it must also be
remembered that the Government have not made this standard mandatory. They clearly
do not consider it necessary for all homes to be built to part M4(2). Therefore there would
need to be very strong evidence from the Council to justify their position. It cannot be
sufficient to state that there is an ageing population who are more likely to require such

homes. Our aging population is a national concern and one faced by all areas. If this were
sufficient justification then the Government would have made the standard mandatory.
Therefore we do not consider the Council to have provided the evidence required by
national policy to justify all new homes being built to the optional standard M4(2). Without
this evidence it is not possible to determine an appropriate level at which to set this
The proposal to require 5% of all homes on sites above 20 units as being built to part
M4(3) is contrary to national policy. PPG sets out in paragraph 56-009 that the standard
for wheelchair accessible homes only to properties where the local authority is
responsible for allocating or nominating a person to live in that dwelling. This means that
M4(3) can only be applied to affordable homes and the policy should be amended to
reflect this position.