Object

Representation ID: 8876

Received: 30/09/2021

Respondent: Bedfordia Developments Ltd and Bedfordshire Charitable Trust Ltd

Agent: DLP Planning Limited

3.6 (Housing Needs of Different Groups / Older People)– Object
2.30 Paragraph 3.6 of the Council’s Consultation Document sets out:
“The LHNA also provides the evidence base to update the policies of the Local Plan 2030 on these matters. Policy 58S Affordable housing and 59S Housing mix will be updated once the viability of the Local Plan as a whole has been tested.”
2.31 Without prejudice to any further evidence our client may submit at future stages of consultation, these representations highlight that the Council’s own emerging evidence indicates an urgent and pressing requirement to address the needs of specialist housing for older people. The Council has failed to incorporate its own evidence of an urgent and substantial level of need into its own testing of strategy options and has further ignored other important material considerations regarding the importance of the sector. Failure to take account of this important element of the Plan’s objectives renders the overall approach to plan preparation unsound: not effective and not consistent with national policy.
Reasoning
2.32 The evidence base generated by the LP2030 on the housing needs for older people is substantially out-of-date and pre-dates the latest version of the NPPF and specific guidance in the NPPG. This reflects the impact of a foreshortened plan period and the Council’s reliance on an objective assessment of housing need substantially below that resulting from the government’s Standard Method. Furthermore, the LP2030 makes no specific provision or allocations to provide sites to deliver the requirements for specialist accommodation.
2.33 The strategic policies of the Plan, with which Neighbourhood Plans under preparation must be in general conformity, provide no specific direction on how the housing needs of older people should be addressed. Neighbourhood Plans ‘made’ or currently under preparation in the Borough have generally not made any specific provision to address this important component of housing need.
2.34 The Local Housing Needs Assessment (LHNA) (Figures 10 and 67), prepared to inform the Council’s draft strategy and policy options, identifies a net need for over 1,500 units of Extra Care accommodation to 2040 (872 ‘owned’ and 632 ‘rented’ units). This level of need is derived from the Housing Learning and Improvement Network (Housing LIN) SHOP resource pack methodology (2012) referred to in Planning Practice Guidance. This level of need is principally a function of low levels of existing supply and very limited recent development of Extra Care for sale within the Borough (contrasting with an oversupply of traditional ‘sheltered’ accommodation).
2.35 Recent Appeal Decisions have reinforced that the notional prevalence rates applied through relevant toolkits should be treated with caution and are likely to provide a minimum starting point. In respect of the 45 units of Extra Care accommodation per 1,000 residents aged 75+ set out within the SHOP toolkit Inspector Stephens opined at Paragraph 40 of the Appeal Decision at Little Sparrows, Sonning Common, South Oxfordshire (PINS Ref: 3265861) that this:
“should be far more ambitious given not only the true tenure split in the District but also what it could mean for the ability to contribute towards addressing the housing crisis”
2.36 This reflects international comparisons with regards the rate of provision for specialist housing for older people and the potential additional benefits associated with freeing up family housing.
2.37 The House of Commons Housing, Communities and Local Government Committee also focuses upon the housing needs of older people in assessing the government’s proposals for ‘The Future of the Planning System in England’ (First Report of Session 2021-221). Paragraph 136 of that Report states:
“There should also be support and encouragement for local authorities to deliver specialist housing, particularly for elderly and people with disabilities. The Government should create a C2R class for retirement communities to ensure clarity in the planning process. There should be a statutory obligation that Local Plans identify sites for specialist housing”
2.38 This recommendation seeks to build upon the existing direction of travel in national policy and guidance. It should, however, be noted that the current Planning Practice Guidance
1 https://committees.parliament.uk/publications/6180/documents/68915/default/
(updated in June 2019) identifies that Plans should consider the allocation of sites in circumstances where an unmet need is identified (ID: 63-013-20190626) and reinforce this with a positive approach towards decision-taking (ID: ID: 63-016-20190626).
2.39 Planning Practice Guidance also provides a non-exhaustive list of considerations for the development of age-friendly places (ID: 63-018-20190626). In terms of the specific locational and scheme requirements for retirement village schemes (including Extra Care) it is important that the site is of a sufficient size to secure a critical mass of services, facilities, and opportunities for care provision. Such schemes typically provide substantial benefits to the wider community in terms of access to social spaces and shared facilities.
2.40 The considerations set out in the relevant PPG can be sustainably addressed as part of one option for a scheme on our client’s land at Green End, which would also enable easy access to services and facilities in the urban area (including pedestrian links and potential arrangements such as lift-sharing and community transport).
Suggested Approach / Remedy
2.41 There is an urgent requirement to update the provision for specialist accommodation for older people set out in Policies 59S and 60 of the Local Plan 2030, which are significantly out-of-date. These pre-date the latest iteration of national policy and guidance and are based upon an indication of a requirement for only 1,400 units of specialist accommodation to 2030 (see paragraph 10.18) as opposed to over 5,000 units to 2040 in the emerging evidence. The current policy position also fails to capture the broad range of provision possible to meet the requirements for specialist accommodation, including the retirement village concept, and thus present an outdated interpretation of the Use Classes Order.
2.42 These factors, taken together, also indicate a significant and urgent requirement to allocate specific sites to meet the specialist housing needs for older people as part of site selection to inform the submission draft Plan. For the reasons set out in these representations a ‘general’ approach that defers opportunities to large-scale strategic sites with long development timeframes will not be effective or consistent with national policy. Additionally, the deferral of site allocations to Neighbourhood Plans is likely to remain ineffective unless very clear direction of the requirement to make provision towards housing for older people is set out in the strategic policies in the Plan.
2.43 As such, our client’s land at Green End, Kempston, represents an appropriate location to satisfy parts of the Council’s substantial need for specialist housing for older people and should be assessed in detail as part of options for the site to be tested in detail at the next stage of plan-making.