Policy P4E – Meeting Housing Needs - Housing for Older and Disabled People

Object

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.

Object

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

Object

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.

Object

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)

Object

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

Object

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 .

Object

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

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.
(Continue on a separate sheet /expand box if necessary)

Object

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.

Object

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.

Object

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.

Support

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.

Object

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.

Object

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.

Object

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.

Object

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.

Object

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.

Object

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.

Object

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.

Object

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.

Object

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.

Object

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.

Object

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.

Object

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

Object

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.

Support

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.

Object

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.

Support

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.

Support

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.

Object

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.