Solihull Local Plan (Draft Submission) 2020

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: 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.