Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 10006

Received: 29/07/2022

Respondent: Inspired Villages

Representation Summary:

We support Policy DM3(S) for seeking to providing a suitable mix of tenures for developments of 500 dwellings on more, which will include the provision of C2 uses with affordable housing provision being applicable to the C3 element only.

It is welcomed that Bedford Borough Council are able to acknowledge the increased requirement for specialist housing options for older people; however, the Plan should highlight the additional benefits of extra care housing outlined within the attached representation document particularly the health and wellbeing benefits such as savings to the NHS and social care, as well as reduced mental and physical health problems. Other evidenced benefits of specialist housing for older people include the freeing up of family homes as well as lower traffic generation resulting from such developments. Please refer to paragraphs 3.14 to 4.15 of the attached representation for further details.

Supporting document – Bedford Borough Local Housing Need Assessment – has identified that the majority of population growth within the borough will be within the over 65s demographic (64%). Furthermore, the draft local plan also sets a target for an additional 12,500 homes of which 5,000 have been identified as specialist homes for older persons. it is welcomed that the draft local plan identifies a housing target for specialist older persons housings as the PPG advises that plan-making authorities can “also provide indicative figure figures or a range for the number of units of specialist housing for older people needed across the plan area throughout the plan period” (Paragraph: 006 Reference ID: 63-006-20190626).

The Call for Sites is pending. It is important that specific allocations are made for specialist housing for older people within Policy 60. Allocation should be made for Use Class C2 outside of strategic development areas. Whilst Policy DM3(S) acknowledges for sites providing 500 or more dwellings provide ‘self-contained housing designed to meet the needs of older persons’ it does not specify the variety of tenures available and there is a danger that the land made available within larger development sites set aside for older persons housing risks a generic approach to provision as it does not ensure that all of the different typologies of specialist housing would be provided (e.g. age restricted, retirement housing, extra care (i.e. integrated retirement communities), and care homes) (please refer to paras. 2.13 - .14 of the attached document for the key considerations in the deliverability of one our developments). Finally, I would also draw your attention to the NPPG Paragraph 4 (Reference ID: 63-004-20190626) which states that the future need for specialist accommodation for older people should broken down by tenure and type. Each typology has different requirements in terms of site area, unit numbers, provision of on-site facilities and locational requirements. This must all be taken in to account in drafting policy.

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