Policy P4E – Meeting Housing Needs - Housing for Older and Disabled People
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 10630
Received: 16/11/2020
Respondent: Edward Fraser
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
We already have a plethora of housing/apartments for elderly developments. It's time to build some affordable housing for first time buyers and young families. But we can't cope with the disproportionate amount of suggested development in and around Shirley.
The draft proposals for the housing developments still has far too many sites with large numbers in the Shirley Area.
We already have far too much traffic on roads due to people from Dickens Heath,Tidbury Green etc developments passing through our roads.
The Doctors surgeries are full to overflowing with the present population and the erosion of Green Belt land is not acceptable.
We already have a plethora of housing/apartments for elderly developments. It's time to build some affordable housing for first time buyers and young families. But we can't cope with the disproportionate amount of suggested development in and around Shirley.
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 10839
Received: 13/12/2020
Respondent: Mrs Jennifer Fearn
Legally compliant? No
Sound? No
Duty to co-operate? No
It's acknowledge Stratford Rd has high levels of thru traffic and congestion. Yet almost 600 units are currently being built or planned for aged retired people along this road. Where are the children from the families in these new homes going to School? Currently parents of children attending Shirley Heath Juniors and Woodlands Infants are challenged by the Stratford Road hazard. Increasing distance children and parents have to travel increase car travel and creates parking nuisance to residents close to Schools. This concentration excludes existing retirement properties in Shirley, focusses need for increased health care, denies equal access to NHS
More equal distribution across the borough for retirement and care units.
It's acknowledge Stratford Rd has high levels of thru traffic and congestion. Yet almost 600 units are currently being built or planned for aged retired people along this road. Where are the children from the families in these new homes going to School? Currently parents of children attending Shirley Heath Juniors and Woodlands Infants are challenged by the Stratford Road hazard. Increasing distance children and parents have to travel increase car travel and creates parking nuisance to residents close to Schools. This concentration excludes existing retirement properties in Shirley, focusses need for increased health care, denies equal access to NHS
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 11019
Received: 14/12/2020
Respondent: Knight Frank
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
Policy P4E relates to meeting housing needs for older and disabled people. As currently drafted, the policy does not meet the tests of being positively prepared, justified, effective or in accordance with national policy, as it will fail to meet the housing needs for older and disabled people.
The Plan should allocate specific sites for the housing of older people across all tenures, thereby enabling provision that cannot be achieved through open market competition for sites. This would provide
additional flexibility in policy that responds to the difficulty these schemes face in competing with conventional, policy compliant sites.
See attachment dated 9 November 2020
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 11021
Received: 14/12/2020
Respondent: McCarthy and Stone Retirement Lifestyles Ltd
Agent: The Planning Bureau
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy P4E (iv) states All specialist housing must meet the Category 2, Category 3(2a) or Category 3(2b) requirements of the Building Regulations, Approved Document M, Volume 1
This is not clear as it does not stipulate the proportion of each form of accommodation which is required and in any case should only relate to housing where the Council has nomination involvement (see other representations)
That Policy P4E be amended to specify the proportion of wheelchair accessible and adaptable housing required and that this is only required where the Council is responsible for allocating or nominating an individual
4 representations proposing amends to Policy 4E and supporting text
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 11022
Received: 14/12/2020
Respondent: McCarthy and Stone Retirement Lifestyles Ltd
Agent: The Planning Bureau
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Paragraph 172 states: The (affordable housing) policy applies to all development in the ‘C3’ use class. The policy will also apply to ‘C2’ development that provides individual self-contained units that can be counted as part of the Borough’s overall housing supply. Such C2 development will be Extra Care developments which are typically 50 units plus and with extensive communal and care facilities, will differ significantly from that form of retirement housing that has been viability tested.
No viability testing of Extra Care housing has been carried out
That Paragraph 172 be deleted
4 representations proposing amends to Policy 4E and supporting text
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 11023
Received: 14/12/2020
Respondent: McCarthy and Stone Retirement Lifestyles Ltd
Agent: The Planning Bureau
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Paragraph 214 states “Specialist housing will provide fully self-contained homes to people who may need care at the time that they take up occupation, or may develop a need for care over a period” and then goes onto consider how the Council defines such housing referring to levels of care that would be typically found in extra care accommodation. This fails to recognise that there are a wide range of housing types for older people in response to a wide range of varying needs. PPG guidance “housing for older and disabled people” at para 10 states that this extends from simple age restricted accommodation and retirement housing with little or no care, through to care and nursing homes. The benefits of all forms of such accommodation are well recognised and the HEDNA generally recognises a need for many forms of such housing. The paragraph in seeking to define older persons housing therefore takes a far too narrow approach .
That Para 214 be amended wholesale to recognise the wide range of specialised housing for older people, that this is not just restricted to housing “with care” and that all forms of such housing brings with it a range of benefits not least in addressing loneliness, isolation and assisting downsizing
4 representations proposing amends to Policy 4E and supporting text
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 11024
Received: 14/12/2020
Respondent: McCarthy and Stone Retirement Lifestyles Ltd
Agent: The Planning Bureau
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Paragraph 207 states that: Policy P4E requires ‘wheelchair adaptable’ as ‘wheelchair accessible’ only applies where the Council is responsible for allocating or nominating an individual. This is generally the correct approach given PPG/Bregs guidance. However (a) the use of the word “as” does not make statement clear and (b) this is not clearly stated in the policy as inferred by Para 207 and ought to be as the policy is quite wide ranging
That Policy P4E be amended to additionally state
Policy P4E requires ‘wheelchair adaptable’ (M4(3)a) and ‘wheelchair accessible’ (M4(3)b) only applies where the Council is responsible for allocating or nominating an individual
That Paragraph 207 be amended accordingly
4 representations proposing amends to Policy 4E and supporting text
Object
Solihull Local Plan (Draft Submission) 2020
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.
(Continue on a separate sheet /expand box if necessary)
1. The Local Plan Viability Study must be updated to properly assess and model the different typologies of older persons housing. The modelling should look at not just Retirement Housing, but also Retirement Communities (Extra Care / housing-with-care) and Care Homes on a range of site sizes and scales to inform the Local Plan policy and text.
2. With the updated evidence base we would expect this to recognise that it is not viable for a retirement community / extra care development to deliver 40% affordable housing. Furthermore, 40% is completely inappropriate given the tenure profile for older people is towards owner occupations.
3. The supporting text and policy will need to insert specific text for retirement community / extra care development to state that affordable housing is not required.
4. The policy should be specific to say that it only applies to ‘C3 residential’ and not development falling within the C2 use class in acknowledgement of the viability issues faced by C2 uses including extra care housing / retirement communities.
3 representations covering Challenge B, P4A and P4E - see attachment and Representations for detail
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 11028
Received: 09/12/2020
Respondent: Inspired Villages
Legally compliant? No
Sound? No
Duty to co-operate? No
The Plan recognises the importance of the growth of the older persons population and P4E(1) refers to meeting the identified needs of older people “in accordance with current assessments of housing need and evidence”. In this context therefore it would be expected that this should be a policy of the highest importance in the Local Plan.
1. The Evidence base commissioned by the Council is flawed.
(i) SHMA Part 2 used the @SHOP toolkit which is flawed and which was identified at a planning appeal (see West Malling appeal decision – attached – reference APP/H2265/W/18/3202040 para’s 26 to 40). The SHMA states the unrealistic suggestion that because there is no existing Market Extra Care Housing that this means a future requirement is also zero.
(ii) It is acknowledged that the evidence base has been updated in light of the Richmond Villages appeal at Catherine de Barnes where para 32 noted the appellant and the Council’s respective positions on shortfall of extra care and bed spaces and para 31 states that the Council gave the clear need for older people’s housing as of significant weight.
The HEDNA (para 9.30) seeks to suppress housing with care rates stating that 45 units per 1,000 population aged 75 and over “is quite a high figure in the context of current supply” – however the fact that nil / limited extra care has been delivered to date does not justify this position.
Furthermore, it seeks to apply the same tenure split as housing-with-support, which is 50% market housing in more deprived areas up to 67% in less deprived locations, however, this does not correspond with the tenure profile of over-70s which has significantly greater levels of owner occupation to that %. This position is therefore not justified nor based on the evidence and would make it difficult to provide sufficient owner-occupied homes for older persons meaning their needs will not be met in full over the plan period.
The HEDNA (para 9.34) identifies the shortfall of the various typologies of older persons housing, including 469 units of extra care by 2036 “of which 70% is in the market sector”. It asserts the current supply in this category (in both tenures) is sufficient with the shortfall emerging in the future. This is at odds with the position accepted by the Council at the Catherine de Barnes appeal and which the Inspector recognised the need was significant. This conclusion by GL Hearn arises from their unjustified position to downplay the prevalence for extra care housing (market) to reflect the actual market demand – historic under supply, ageing population and tenure profile of the borough.
(iii) Para 201 states “many will prefer to remain in their own homes”, and para 202 says that “an important part of meeting need for older people will be through general purpose new homes built to accessible standards” and “this will include age-restricted general market housing”. However, these are subjective statements and is unevidenced.
(iv) HEDNA (Oct 2020) lists the 4 definitions of different types of older persons’ accommodation from the PPG. P4E references specialist housing – with a cursory definition in the supporting text; age restricted general market housing (para 202); and care homes at P4E(5). However, the policy and supporting text is completely silent on extra care housing which includes retirement communities. There is a lack of extra-care housing in the Borough at present and there is a major need for its provision over the plan period yet this is hampered by an evidence base which has sought to downplay the need and a policy that omits to mention it. Having regard to the significant need for all forms of older persons housing the Council should give consideration to include a requirement for strategic site allocations to make provision for older persons housing.
2. P4E needs to be explicit on what is or isn’t C2 or C3 use class. P4E(5) references care homes as C2 but is silent in respect of other uses – and as already stated is wholly silent on extra-care. Inspired Villages delivers Retirement Communities across the UK. We have received Counsel Opinion on our development which confirms we fall within the C2 Use Class and this is what underpins our applications, including recent consents in Reigate & Banstead, Wealden, Bedford Borough, Central Bedfordshire, Maidstone, etc. It is not acceptable for the Council to be ambiguous on use class as this is not helpful to the sector.
The suggested modifications to the Local Plan are:
1. The 8 recommendations (p5) in the accompanying ‘Representation by Inspired Villages: To support the practical delivery of much-needed specialist accommodation to meet the needs of an ageing population (version 2)’ must be incorporated within the draft Local Plan, including a clear policy to address older person housing needs; setting figures for the amount of units required; how this will be monitored; inclusion of minimum numbers within the site allocations in the right circumstances; recognising the significant benefits of this form of accommodation (not properly acknowledged in policy or supporting text); and to reflect the use class fully.
2. The evidence base must be updated to properly reflect the ageing demographic and the application of the prevalence rates for all typologies of older persons housing, including extra care. We are prepared to engage with the Council to discuss the appropriate methodology to undertake a proper evidence-based test to ensure older persons housing needs are met over the plan period.
3. P4E should include a figure of how many older persons units are needed over the plan period to ensure that the Council are focussed on providing for this much needed form of accommodation and to recognise the different typologies (i.e. retirement housing; extra care / retirement communities; and care homes). This would ensure consistency with P4E(2) and (3) which express targets for units to be Category M4(2) or wheelchair user dwellings to M4(3).
4. Para 201 must delete the subjective comment which states ‘many people prefer to remain in their own home’. This is unevidenced. It is acknowledged that some people may wish to remain in their own home, however, clearly there is also a need to provide specialist accommodation for older people. Para 212 is vague and lacks certainty. This must be updated to reflect the specific housing numbers set out in the para above.
5. Add new paragraph after para 201 to reference extra care housing (which includes retirement communities) and to list what they entail – to ensure consistency with para 202 which talks about ‘age restricted general market housing’. Key with extra care (and in contract with age restricted housing) is that it does include communal and care facilities.
6. Para 213 is a vague statement. It fails to define what ‘specialist provision’ or ‘specialist housing’ means. This must be defined in the text or in a glossary. Reference to the PPG typologies should be made and as an expansion on para 214 which lacks precision relative to the PPG or ARCO definitions.
7. There is a lack of clarification on the use class. This creates uncertainty from an investor perspective. It is inadequate to express at para 219 that an applicant should seek clarification on use class at the pre-application stage. The Council should engage with ARCO and Retirement Community operators to enable a better understanding of the C2 use class.
8. The plan should make provision for strategic site allocations to include a specific target for older persons housing, e.g. ‘at least 10% provision’ or a specific minimum number of units, to ensure an adequate supply of potential sites to contribute to meeting older persons housing need over the plan period. As an example Policy KN2: South of Knowle (Arden Triangle) should be amended as follows:
Policy KN2
‘…2.
…viii. On site accommodation for older people in accordance with Policy P4E with at least 150 extra-care units (C2 use class);…’
The provision of 600 dwellings at point 1. Should be expressly related to ‘600 residential dwellings (C3 use class)…’
3 representations covering Challenge B, P4A and P4E - see attachment and Representations for detail
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 11055
Received: 14/12/2020
Respondent: The Dunleavy Family
Agent: DS Planning
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Plan fails to adequately address future need for specialist housing for older people. Whilst specialist housing or care bed spaces is required on sites over 300 units, there is no mechanism for delivery.
Depending on larger sites to deliver specialist housing will not address the current need and is likely to exacerbate need going forward, due to lead in times, build out rates and complex land ownership issues.
Specific suitable sites should be allocated rather than relying on larger sites address provision. These additional sites should be in addition to the allocations and numbers already identified within the Plan.
Allocation of specific sites for specialist housing in addition to the current allocations.
See attachments.
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 11118
Received: 14/12/2020
Respondent: Messrs G&A Coombs
Agent: Claremont Planning Consultancy
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Inappropriate to require a range of accommodation types and sizes to be provided within all developments. This is not feasible on many sites, where site size or constraints mean that only one model of care accommodation is possible to be provided.
Where operators are intending to provide Primary Care services within the development, this should be taken into account when requiring Primary Health Care services to be accessible to serve residents.
Policy will not secure an appropriate level of specialist accommodation across the plan period. HEDNA figures do not consider losses, closure and redevelopment accommodation.
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.
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;
See attached documents
Support
Solihull Local Plan (Draft Submission) 2020
Representation ID: 11121
Received: 14/12/2020
Respondent: Messrs G&A Coombs
Agent: Claremont Planning Consultancy
The Council’s requirement in Paragraph 216 for care homes and specialist housing to be provided in accessible locations is supported, as it is important that such developments are sustainably located.
N/A
See attached documents
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 11213
Received: 14/12/2020
Respondent: Knight Frank
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Policy P4E makes no reference to needs figures in the HEDNA or specific targets, nor is there any evidence provided to demonstrate the policy will provide a strategy which, as a minimum, will meet the identified needs for specialist older persons housing within the plan period. The plan therefore does not address specific housing requirements in accordance with para.56 of the NPPF.
See attachment dated 9 November 2020
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 11214
Received: 14/12/2020
Respondent: Knight Frank
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
It is unclear how the strategy of providing specialist housing for older people on larger residential sites has been selected, justified, or whether is more appropriate than reasonable alternatives such as making specific allocations for specialist housing for older people.
See attachment dated 9 November 2020
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 11218
Received: 14/12/2020
Respondent: Mr Mark Horgan
Agent: Savills
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy P4E must be supported by robust evidence. The PPG sets out the evidence necessary to justifying a policy requirement for optional standards. There is no evidence on the accessibility and adaptability of the existing housing stock which could be adapted to meet the needs of the older population.
Point 5 of Policy P4E fails to take into account site specific factors such as vulnerability to flooding, site topography and other circumstances.
Sufficient evidence has not been provided to justify the requirement that developments of 300+ dwellings provide specialist housing or care bed spaces.
All new homes should be built to Building Regulation Part M Category 1 standards. The requirement for all dwellings to be built to Category M4(2) standards should be removed and any proposed requirement should be based on an appropriate assessment of need.
Point 5 of Policy P4E should be amended to state “Site specific factors which may make step-free access unsuitable or unviable”.
The requirement for 300+ dwellings to deliver specialist housing or care bedspaces should be removed. Specific sites for specialist and senior living should be allocated to deliver this specialist provision.
Dear Sir / Madam,
On behalf of Mark Horgan, please find attached a response to the Draft Submission version of the Local Plan Review in regards to his land interests at Winterton Farm, Blythe Valley (SHELAA reference 173).
We have submitted the following:
• Covering letter;
• Five Consultation Response Forms;
o Policy P4C
o Policy P4D
o Policy P4E
o Policy P5
o Policy P17
• Promotion Document (January 2016).
Please contact me if you have any queries with the submission.
Kind regards
Jess
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 11229
Received: 14/12/2020
Respondent: Cinnamon Retirement Living Ltd
Agent: Avison Young
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The plan, as drafted, will not deliver extra care facilities in accordance with the Council’s aspirations. It fails to comply with test c) (effectiveness) of para 45 of the NPPF. See accompanying letter.
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.
Cinnamon 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.
Cinnamon'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 Cinnamon 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.
Cinnamon 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.
The Wyndley site is a perfect example of a site that could accommodate C2 / assisted living only,
hence our request that it be allocated specifically for C2 / assisted living use.
The plan should include proposed allocations for sites in C2, extra care use only, including the Wyndley Garden Centre land.
See Reps form and Cinnamon full representation
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 11230
Received: 14/01/2021
Respondent: Eastcote Land Limited
Agent: Avison Young
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The plan, as drafted, will not deliver extra care facilities in accordance with the Council’s aspirations. It fails to comply with test c) (effectiveness) of para 45 of the NPPF.
The emerging local plan includes a general “catch all” policy on the provision of care accommodation on sites delivering over 300 dwellings. It also suggests that some sites could be suitable for care uses.
However, in the absence of any sites that are allocated for C2 / extra care only, landowners / developers will always have to consider the land value generated by C3 housing (including the provision of affordable / social housing) and the land value generated by care development.
The plan should include proposed allocations for sites in C2, extra care use only, including Eastcote Park, Barston Lane.
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
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
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.
The plan should include proposed allocations for sites in C2, extra care use only, including Eastcote Park, Barston Lane.
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
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 11232
Received: 14/12/2020
Respondent: Cinnamon Retirement Living Ltd
Agent: Avison Young
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The plan, as drafted, will not deliver extra care facilities in accordance with the Council’s aspirations. It fails to comply with test c) (effectiveness) of para 45 of the NPPF.
The emerging local plan includes a general “catch all” policy on the provision of care accommodation on sites delivering over 300 dwellings. It also suggests that some sites could be suitable for care uses.
However, in the absence of any sites that are allocated for C2 / extra care only, landowners / developers will always have to consider the land value generated by C3 housing (including the provision of affordable / social housing) and the land value generated by care development.
See Reps form and Cinnamon full representation
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 11244
Received: 14/12/2020
Respondent: Mr T Khan
Agent: DS Planning
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Plan fails to adequately address future need for specialist housing for older people. Whilst specialist housing or care bed spaces is required on sites over 300 units, there is no mechanism for delivery.
Depending on larger sites to deliver specialist housing will not address the current need and is likely to exacerbate need going forward, due to lead in times, build out rates, and complex land ownership issues.
Specific suitable sites should be allocated rather than relying on larger sites address provision. These additional sites should be in addition to the allocations and numbers already identified within the Plan.
Allocation of specific sites for specialist housing in addition to the current allocations.
See attachments.
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 13720
Received: 10/12/2020
Respondent: Barwood Development Securities Ltd
Agent: stantec
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Whilst we support the principle of Policy P4E and its objective to provide a variety of homes to meet the needs of different groups in the community, we are concerned that it does not consider the particular locational requirements of older people and those with disabilities and special needs.
Policy P4E does not consider the location or which operators will be providing specialist care provision.
Given their land requirements, developments of 300 dwellings and more will typically be on the edge of existing settlements, rather than in more central, urban locations which are typically in closer proximity to local services and facilities. Older persons and specialised living accommodation usually needs to be in the most sustainable and accessible locations, in close proximity to a good range of services, facilities and transport links, given that residents tend to be less mobile and more reliant on public transport. Furthermore, the larger, mainstream housebuilders which typically build developments of 300 dwellings or more also tend to have less experience or expertise in operating specialist housing or care accommodation.
See attachment
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 13721
Received: 10/12/2020
Respondent: Barwood Development Securities Ltd
Agent: stantec
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The Council has provided insufficient evidence to justify policy P4E.
Criterion 4 should be removed and the draft Plan should instead identify site allocations across the borough which are most appropriate for such accommodation (typically in more urban areas of the borough) and include appropriate wording in the relevant policies for those sites.
Alternatively, criterion 4 could be reworded as follows: “All developments of 300 dwellings or more should include provision of specialist housing or care bedspaces if supported by evidence within an up to date Council statement of need for older person’s accommodation.”
See attachment
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 13754
Received: 14/12/2020
Respondent: Heyford Developments Ltd
Agent: Barton Willmore
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
It is unclear whether the evidence base supporting Policy P4E is robust, including around viability and deliverability. The Viability Study does not make reference to P4E in Round 2 testing. Specialist housing may be appropriate on some sites, this should be tested.
Policy P4E should reference supporting evidence, to ensure deliverability of development sites is not affected by the requirements of the policy.
Hello,
Please find attached forms and a letter of representations on behalf of Heyford Developments in relation to their site at Old Station Road, Hampton-in-Arden.
Regards,
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 13820
Received: 14/12/2020
Respondent: Mrs Joan Vale
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The plans to build and continue building homes and over 60’s schemes in around Shirley is very concerning. There is a concern for local services, including doctors and dentists.
The increased number of residents raises concern for emergency health provision, as Solihull does not currently have an A&E
Good evening
I am writing to say that the plans to build and continue building homes and over 60’s schemes in around Shirley is very concerning. Shirley is already a very congested village with so many people using doctors and dentist and other facilities, you generally have to spend 15 minutes on the phone in a queue just to speak to a doctors reception.
The roads too are busy and if you try to go anywhere around school times you might as well forget it as there are so many cars and huge buses crawling along, never mind parents sitting in their cars with engines running for 15-30 minutes before they collect their children.
We don’t have an A&E anymore which is really concerning with the increasing number of residents and the very poor state of Heartlands A&E, never mind the distance to get there.
The most concerning is the effect on the environment, and the animals and trees and land that they sit on. Our eco system is already stretched and to offer planting a few trees when lots of mature ones are slashed down is disgusting. It’s the animals that suffer at our hands.
Please don’t keep building on spare bits of land, there’s barely anywhere for nature to go and they were here long before humans arrived and decided they should do what they wish.
I am over 60 and have seen big, concerning changes throughout Solihull over the years and it’s only getting worse.
Regards
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 13821
Received: 14/12/2020
Respondent: William Davis Ltd
Agent: Define Planning & Design
Legally compliant? Yes
Sound? No
Duty to co-operate? Not specified
There is no sufficient evidence, including in the HEDNA, to suggest that 95% of dwellings should be provided to M4(2) standard. Policy requirement should not undermine the deliverability of sites in the Borough.
A requirement of 25% of housing to M4(2) standard, unless delivered to M4(3) standard (a requirement of 5%) should be adopted.
Dear Sir / Madam,
Please find attached representations submitted on behalf of William Davis Ltd (WDL) in relation to their site at Land off Old Station Road, Hampton in Arden in response to Solihull Metropolitan Borough Council’s Draft Submission Plan Consultation. This submission takes the form of the attached multiple submission response form (Document Ref. 'Solihull R19 Plan Representations - Define Planning and Design obo William Davis Ltd - Land off Old Station Road, Hampton in Arden (083 MR 141220)' that sets out WDL’s position in relation to the Draft Submission Plan and the policies set out within, as well as the associated Vision Document that is referred to within those representations (Document Ref. '083 Land off Station Road, Hampton in Arden Vision Document RS').
I would be most grateful if you could confirm safe receipt of this email and its attachments by return email.
Kind regards
Support
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14016
Received: 14/12/2020
Respondent: West Midlands HARP Consortium
Policy P4E – The policy states that all new build housing on major development sites must be built to Category M4(2). It is not clear if the viability study (October 2020) has assessed the impacts of these standards alongside all of the other policy requirements of the Draft Local Plan against affordable thresholds higher than 40%. It is quite common for housing associations to deliver up to 100% of housing on site as affordable and therefore this requirement should be subject to viability. Without these viability studies for these kinds of developments, implementing such technical standards is likely to threaten future delivery of affordable housing on schemes with developers having to negotiate its reduction to achieve viability on schemes.
See attached letter
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
Support
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14063
Received: 14/12/2020
Respondent: Taylor Wimpey
Agent: Turley
Welcome flexibility in the policy to take into account site specific factors when applying P4E to any planning application but would welcome an additional factor to be included within the list.
This should include:
‘Where the Council’s up to date statement on older person’s accommodation does not identify a local need in the local area of the proposed development’.
This would prevent the oversupply of older person’s accommodation within a specific local area.
Additional factor to point 5 of the policy as follows:
‘Where the Council’s up to date statement on older person’s accommodation does not identify a local need in the local area of the proposed development’
See attached documents.
Support
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14065
Received: 09/12/2020
Respondent: MACC Group
Agent: Claremont Planning Consultancy
P4E - The Council’s requirement in Paragraph 216 for care homes and specialist housing to be provided in accessible locations is supported, as it is important that such developments are sustainably located. However, it is noted that this may conflict with the requirement for specialist housing or care bedspaces to be provided on
all sites over 300 dwellings, as this may result in such developments being provided on the edge of developments isolated from any form of local facilities, public transport and other services.
See attachment
Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14110
Received: 14/12/2020
Respondent: IM Land - Land at Jacobean Lane, Knowle
Agent: Barton Willmore Planning
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The requirement for affordable provision for C2 development is held within the justification rather than within the policy.
It is not specifically defined what types of C2 development will require to provide affordable housing (either on-site or off-site). The reference to ‘self-contained units’ does not allow for any distinction between the types of C2 uses.
The Viability Study only tests one C2 typology which is a 30 (one and two bedroom) unit retirement apartment housing scheme and it is unclear the level of communal area that has been assumed. The viability study scenarios also show that this is not viable when CIL is also included.
The HEDNA does not justify that 40% affordable provision is required on C2 uses and that the affordable need is lower. This indicates that requiring a 40% affordable housing obligation would be unjustified. This point is further evidenced by the Older People’s Housing Need Report (January 2020) produced by Barton Willmore.
NPPG Paragraph 64 confirms that specialist accommodation is exempt from the requirement for 10% of homes (as part of the affordable housing contribution) are to be made available for affordable home ownership.
Deletion of Paragraph 172 and of the requirement for certain C2 development to provide for affordable housing.
See attachments. LAND AT JACOBEAN LANE, KNOWLE