Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 11231

Received: 14/01/2021

Respondent: Eastcote Land Limited

Agent: Avison Young

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

C2 uses do not attract the requirement to deliver “affordable housing” under the adopted Plan. The current proposal is that any care related development which counts towards the Council’s supply of housing would be liable to deliver affordable housing.

Eastcote Land has significant concerns about this approach as a matter of principle. There are two elements to the cost of delivering care: the capital cost of buying land and building care accommodation and secondly the ongoing cost of providing care within that accommodation.
The requirement to deliver “affordable care” places an ongoing financial burden on care operators which has the potential to render the sector unviable. The Council has not provided any information on how affordable care provision would be delivered or what the obligations on the operators of care villages / extra care facilities would be. The requirement to deliver affordable care will provide a significant additional financial burden on care home developers and operators. This will make land in C2 use less valuable than land in C3 use. Developers and landowners will be financially disadvantaged by the delivery of C2 facilities and consequently will attempt to offer the minimum required to satisfy policy.

Eastcote Land’s development includes ancillary facilities which are used by all residents. These include provision of a restaurant/dining area, café, lounges, hair and beauty salon, wellness centre and a club room for activities to be held in. All of these amenities contribute to creating a community within the care village. This ensures that the facilities go beyond the delivery of accommodation and care. The ancillary facilities deliver very significant health and wellbeing benefits through both engagement in the activities provided and the sense of community created.

The cost providing ancillary community facilities within this type of care model is significant. This cost further widens the gap between the land values generated by C3 (including affordable housing) and C2 (including affordable care and ancillary facilities).

The effect of the above is that Eastcote Land and similar operators will be “priced out” of the market for land by C3 developers. In order to have any chance of being financially competitive they will not be able to deliver associated facilities. It will also be very difficult for operators to deliver care, because there will not be space in which to do so.

The Council’s current approach will create a “bare minimum” approach to the provision of care facilities, the impact of which will be a significant reduction in the amount of amenity space for residents to enjoy on sites and the exclusion of any ancillary facilities. This would be a retrograde step back to old style “age restricted retirement flats” which had no communal facilities and verify little, if any, care. The use of such units is C3. We don’t believe the Council intends to create such a situation, but we must point out what is likely to occur.

Eastcote Land maintains that this matter can be resolved easily through the allocation of sites specifically for C2 / assisted living uses. Such allocations would remove competition from C3 developers and would provide the financial flexibility needed to deliver exemplar healthcare schemes with associated health and wellbeing benefits. We appreciate that the Council has undertaken to test each scheme against policy on a site by site basis, through viability assessments to see what affordable housing of CIL could be delivered. However, this would be a failure of strategy and a waste of the local authority’s time and money when compared with simply allocating sites for C2 use only. Testing each site would slow down the delivery of accommodation with care provision against a background of exponential growth in the need for it. This would jeopardise the policy ambitions the local authority has in encouraging the expansion of provision in this area.

Change suggested by respondent:

The plan should include proposed allocations for sites in C2, extra care use only, including Eastcote Park, Barston Lane.

Full text:

See Reps form and full representation.

Eastcote Land is concerned that the approach to the delivery of care needs will not achieve the Council’s targets for the provision of specialist accommodation or the best outcomes for the occupiers of such accommodation

Attachments: