REPRESENTATIONS ON BEHALF OF RED ELK HOLDINGS
The draft Local Plan sets out an objective (Challenge B) to widen the range of housing options for older people through the provision of accommodation which is designed to meet their needs. It highlights that there is a Borough-wide shortage of homes which are suitable for older people (paragraph 182). The Strategic Housing Market Assessment (2016) published with the draft Local Plan says that, in addition to the objectively assessed need for housing there will be a requirement for residential care home accommodation for the elderly of additional 737 spaces over the next 19 years (paragraph 6.14). The document recommends that the Council plan separately for this accommodation and set out a separate target for new bedspaces within this accommodation. However neither a target nor any provision has been set out in the draft Local Plan and therefore this requirement seems to have been ignored.
It is important that housing provision is made for elderly people, not least to meet the needs of elderly people in society, but also because elderly people currently occupying large homes may wish to move but may not have the option of alternative accommodation within their community. By making provision for elderly people to downsize or move to accommodation which better meets their care needs, this releases large homes back to the market for younger families. This in turn reduces the pressure to build more new homes.
The Draft Local Plan recognises this at paragraph 181 where it states that 'the number of households represented by the over 75s is projected to increase by 7,000 between 2014 and 2033 to comprise 22% of all the Borough's households. This leads to market demand for specialist and supported housing together with homes which can provide opportunities for households to 'downsize', thereby releasing family housing for resale and re-letting'. However the Local Plan does not do anything in terms of making provision to address this requirement.
The National Planning Policy Framework says at paragraph 159 that local planning authorities should, through their Strategic Housing Market Assessment, identify the need for all types of housing, including the needs of older people, and then cater for housing demand and the scale of housing supply necessary to meet this demand. This is a clear national policy expectation that the needs of older people will be both understood and met.
The Planning Practice Guidance paragraph 021 says that the need to provide housing for older people is critical given the projected increase in the number of households aged 65 and over accounts for over half of the new households. Plan makers will need to consider the size, location and quality of dwellings needed in the future for older people in order to allow them to live independently and safely in their own home for as long as possible, or to move to more suitable accommodation if they so wish. The future need for specialist accommodation for older people broken down by tenure and type (e.g. sheltered, enhanced sheltered, extra care, registered care) should be assessed. The assessment should set out the level of need for residential institutions (Use Class C2). Local authorities should also identify particular types of general housing as part of their assessment.
Whilst the Strategic Housing Market Assessment identifies a requirement for residential care home accommodation for the elderly of additional 737 spaces over the next 19 years, the Draft Local Plan does not meet this need. The Draft Local Plan is therefore considered unsound, due to it not being positively prepared. The Draft Local Plan could be made sound by making provision to meet the identified housing needs of older people through specific site allocations for C2 residential care and other types of housing designed to meet the needs of older people.