Solihull Local Plan (Draft Submission) 2020

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