Solihull Local Plan (Draft Submission) 2020

Object

Representation ID: 11026

Received: 09/12/2020

Respondent: Inspired Villages

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Challenge B (p13-14) 1st bullet seeks “to ensure” the full OAHN for the Borough is met, however the 6th bullet in referring to housing for older people merely seeks to “wider the range of options”.

The Objective should similarly ensure the full needs for older persons housing need is met and this would then be consistent with Policy P4E(1) with the expectation that “new housing developments” “meeting the identified needs of older people”.

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.
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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.