Object

Representation ID: 11027

Received: 09/12/2020

Respondent: Inspired Villages

Legally compliant? No

Sound? No

Duty to co-operate? No

P4A. Para 172 says Policy P4A also applies to C2 development that provides individual self-contained units. However, the SHMA Part 2 (Nov 2016) identifies accommodation required for pensioner households in 2033 is 76.6% owner occupation; 13.6% social rent/affordable rent (& similar figures in the HEDNA October 2020).

SHMA Part 1 (Nov 2016) para 6.5 has a lack of understanding of the Use Classes Order, citing “in terms of specialist dwellings for older persons (Use Class C3b), it is evidenced that in Solihull an additional 355 affordable and 870 market sheltered and extra care housing units should be provided over the plan period within the identified OAN.” There is no recognition in the evidence base that retirement communities / extra care falls within the C2 Use Class.

The HEDNA has made some unjustified assumptions in calculating market extra care housing which suppresses the needs over the plan period.

The Local Plan Viability Study (14 Oct 2020) lacks understanding of extra care developments, other than para 7.1 which includes “additional typologies” tested including “Typical Retirement Housing Scheme (e.g. McCarthy & Stone type) on previously developed land, for 30 units.”

The evidence base is flawed. A retirement community (extra care), such as that provided by Inspired Villages falls within the C2 use class and due to the minimum scale of development required / land take the evidence base has failed to model this. An Inspired Villages retirement community ranges from 130 to 280 units of accommodation plus communal and care facilities and because of the scale are typically on edge of settlement locations.

The Viability Study has modelled a Retirement Housing development on brownfield land with very few units and few facilities. This is not comparable with an Inspired Villages development which falls under extra care / housing-with-care and the evidence base must be updated to reflect this. To assist the Council with this modelling, they are referred to the ARCO website (Associated Retirement Community Operators) https://www.arcouk.org/what-retirement-community to understand the different typologies of housing for older people (and their HEDNA Oct 2020 which does acknowledge these).

In contrast to the Local Plan Viability Study, the HEDNA (Oct 2020) recognises viability as an issue to extra care (para 9.60 to 9.64). The Council must review the HEDNA to note that the Local Plan Viability Study is flawed in respect of the extra care model, is contradictory to the HEDNA which recognises the key issues to the sector including: non-saleable space, higher construction and fit-out costs, sales rates slower and struggle to compete with mainstream housebuilders (see para’s 9.60 and 9.92) and para 9.61 says “it may well be that a differential and lower affordable housing policy is justified for housing with care” yet this has been ignored in draft policy P4A.

The Council is referred to the accompanying Inspired Villages Local Plan representations document which explains the use classes order / extra care and the recommendations at page 5 of what a Local Plan should include.

P4A seeks 40% affordable dwelling for C3 residential but based on para 172 this would also apply to C2 extra care. However, this is completely at odds with the tenure profile for older people where over three-quarters of homes are owner occupied. It would be unlikely that an owner occupier would be able to qualify for an affordable property and a 40% affordable housing provision is excessive and would result in imbalanced tenure.
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