The BNP Whole Plan Viability study states:

"older persons’ accommodation demonstrate that the viability of retirement / sheltered housing schemes in the borough can be challenging (, except where schemes come forward at higher sales values and on sites with lower existing use values. The Council’s policy allows for the consideration of viability when determining residential schemes. We consider that this flexibility will ensure that such development continues to come forward over the life of the plan and will deliver the
maximum reasonable amount of affordable accommodation".

Given the need to be centrally located, sites (usually brownfield) are often of a high value, indeed the prospect of a low EUV site with high sales values is very highly unlikely , bringing into question the ability of those sites to meet requirments that do come forward. This is concerning given the level of need that the Local Plan establishes for older persons housing particularly for market housing. Moreover the approach seemingly taken here that as it is proven to be non viable at the local plan stage so can be tested at the application stage runs wholly contrary to PPG advice that

"The role for viability assessment is primarily at the plan making stage. Viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the plan"

and a misapplication of the Para 7 advice

"Such circumstances could include, for example where development is proposed on unallocated sites of a wholly different type to those used in viability assessment that informed the plan; where further information on infrastructure or site costs is required; where particular types of development are proposed which may significantly vary from standard models of development for sale (for example build to rent or housing for older people)"

Policy should be amended to reflect the lower level of viability associated with development of housing for older people so as to ensure that such development is able to come forward and not compromised by unrealistic policy and innappropriate review mechanisms