Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14053
Received: 09/12/2020
Respondent: MACC Group
Agent: Claremont Planning Consultancy
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy P4E suggests that new housing developments will be expected to provide a mix of dwelling size and type to meet the identified needs of older people and those with disabilities and special needs, this is unlikely to be feasible on many sites, where site size or constraints mean that only one model of care accommodation is possible to be provided.
The Policy requires all developments greater than 300 dwellings to provide specialist housing, instead, the Council should focus on providing care specific developments in appropriate locations. It is considered that this policy as currently drafted will be ineffective at ensuring the appropriate level of provision of specialist accommodation is achieved in the Borough across the plan period.
This policy also requires applications for specialist housing and care homes to demonstrate that Primary Health Care services will be accessible to serve residents. Whilst this is important for certain types of specialist housing such as sheltered housing, for proposals such as Care Homes it is anticipated that care will be provided by the operator, and will often work alongside rather than utilising the local Primary
Care services and can often support Primary Care services by reducing the level of care required for an individual. Where operators are intending to provide Primary Care services within the development, this should be taken into consideration.
It is considered that this policy as currently drafted will be ineffective at ensuring the appropriate level of provision of specialist accommodation is achieved in the Borough across the plan period.
It is suggested that clause 1 should be deleted, or otherwise modified in order to acknowledge that provision of a range of housing types may not always be feasible.
Clause 4 should be modified to the following:
'4. All developments of 300 dwellings or more, where feasible and appropriate, should must provide specialist housing or care bedspaces in accordance with the Council’s most up to date statement of need on older person’s accommodation'.
Within Clause 6 and 7 of the policy relating to specialist housing and care homes respectively, references to access to Primary Health Care services sub-clauses should be modified to recognise the potential for on-site provision.
6 (ii) It can be demonstrated that satisfactory Primary Health Care services will be accessible to serve the residents of the development unless on-site provision is proposed;
7 (iii) There are satisfactory Primary Health Care services to serve the residents of the
development within reasonable proximity unless on-site provision is proposed;
(NB, The numbering within Policy P4E appears to be incorrect with two clause 5s.
Clause 7 referred to above is the clause relating to Care Homes.)
See attachment