Policy DM3(S) Housing mix

Support

Representation ID: 9381

Received: 29/07/2022

Respondent: Gareth Adam, Homes England

Agent: Stantec

Homes England is responding in its capacity as the Government’s housing accelerator and as landowner of the former Driver and Vehicle Standards Agency (DVSA) site, Shortstown, Bedford.

Homes England is generally supportive of Policy DM3(S); the proposed development at Shortstown will reflect the requirements of Policy DM3(S).

Object

Representation ID: 9418

Received: 29/07/2022

Respondent: McCarthy & Stone Retirement Lifestyles Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The approach of requiring 100% M4(3) accessibility from older persons housing is misguided and will have a negative impact on meeting the housing need of older people and limit the options that they have.

Comment

Representation ID: 9577

Received: 20/07/2022

Respondent: L&Q Estates Limited

Draft Policy DM3(S) (Housing mix) requires new housing developments to provide a mix of
dwelling size and type to meet the identified needs of the community including families with
children, older people, people wishing to build their own homes and people with disabilities
and special needs in accordance with the Council’s current Local Housing
Needs Assessment. Clearly each scheme should be considered on its own merits and it is
unrealistic that all of these unit types could be applied to all development proposals. Whilst it
is recognised that the subsequent paragraphs provide additional detail, it would be helpful to
add ‘as appropriate’ to the paragraph, as this could be considered ambiguous as currently
worded. Referring back to our earlier comments about optimising housing delivery to meet
housing need and the inherent design constraints associated with urban, brownfield
redevelopment, flexibility on housing mix policies is important.
Draft Policy DM3(S) goes on to state that ‘All developments of 500 dwellings or more in
suitable locations, will be required to include self-contained housing designed to meet the
needs of older persons, and / or supported living accommodation in accordance with the
Council’s most up to date statement of need on older person’s accommodation.’
L&Q has an extra care and support arm, L&Q Living, which manages homes for our most
vulnerable residents. In our experience, extra care and sheltered accommodation is typically
brought forward as independent developments i.e. not part of a wider scheme with private,
intermediate and other affordable tenures. Whilst we do not object in principle to Policy
DM3(S) we would ask for flexibility in discussions around this requirement to ensure that extra
care and sheltered accommodation is being delivered in the right locations and for the right
end users. Also, we feel it is important that the Council’s preferred market and affordable unit
mix (and older persons, and / or supported living accommodation as a proportion of overall
housing need) need for is clearly set out. In L&Q’s view the Bedford Borough Local Housing
Needs Assessment (April 2022 Update) does not present this information in a clear way.
Draft Policy DM3(S) goes on to state ‘All developments of 100 dwellings or more in suitable
locations, will be required to include specialist housing designed to meet the needs of those
with a learning disability or mental health need in accordance with the Council’s most up to
date statement of need.’
Whilst there is no objection to the aspirations of this policy, it is important that the Council’s
requirement for specialist housing need (as a proportion of overall housing) for is clearly set
out. In L&Q’s view the Bedford Borough Local Housing Needs Assessment (April 2022
Update) does not present this information in a clear way. We would also query what constitutes
a design that meets the needs of those with learning disability or mental health need and would
welcome some guidance on this. As we have mentioned earlier in this letter, flexibility is
required around competing design and space demands to ensure schemes are deliverable
and viable.

Comment

Representation ID: 9629

Received: 26/07/2022

Respondent: Clapham Parish Council

Given the increasing numbers of older persons living within our communities, the need for specific provision is becoming more important. This is particularly important with the opportunities for independent living with support. Consequently CPC supports this policy.
CPC has some concerns that the threshold of 500 dwellings is too high and suggest a lower thresholder of 350 or less.

Comment

Representation ID: 9655

Received: 29/07/2022

Respondent: Verve Developments Ltd

Agent: DLP Planning Limited

Draft Policy DM3(S) is supported with reservations regarding the soundness of the policy. It is noted that the policy varies only minimally from the existing Local Plan Policy 59S Housing Mix.

The proposed development upon the Land at Bedford Heights (HOU10) is for 36 units of affordable housing (one-bedroom apartment units) therefore providing a 100% affordable development. Through the proposed development, the Land at Bedford Heights will form an important part of the Council’s housing pipeline to address substantial shortfalls in the supply of affordable housing including 1no. bed rented affordable homes.

Verve Developments Ltd acquired the wider Bedford Heights site in 2014. Verve Developments Ltd have a long-standing objective of providing housing for those with specific housing needs as part of a longer-term legacy. A partnership has been formed with IMPAKT Housing and Support to provide a small-scale development aimed at providing semi-independent housing with arm’s length support, along with some on-site communal facilities for those with housing needs and to tie this with opportunities for training and employment.

Draft Policy DM3(S) references the current Local Housing Needs Assessment amongst other current assessments of specific housing need and makes reference to evidence in respect of the needs of other specialist groups. Flexibility should be incorporated into the draft policy to allow for a more limited provision of size and type of affordable housing when the specific need can be evidenced. For this reason, the draft policy is not positively prepared and not effective.
As set out within the draft policy DM3(S), the Council anticipates all of its housing needs of different groups being met through all new housing development. In practice this will necessitate substantial elements of the needs of different groups being provided as a proportion of large-scale strategic developments outside of the urban area and outside of existing settlements (including proposed new settlements) where delivery is deferred until later in the plan period. The proposed development for the site is of 36, 1-bed affordable units and will address a substantial current need as outlined below.

The Council’s Interim Housing Monitoring Report (2020-21) shows that a net total of 192 affordable housing units have been completed during this time. These figures are not broken down into dwelling size and bedroom numbers.

Proposed development schemes seeking to meet an identified specialist housing need should be supported in principle. Where the mix of size and type is meeting a specific and evidenced need this should be supported and the policy should reflect this to allow the plan to positively respond to future proposals. As currently drafted it is not positively prepared in this regard.

The inclusion of accessible and adaptable dwellings provision through meeting M4(2) and (3) requirements drafted in Policy DM3(S) is supported. The proposed development will look to meet these requirements.

The proposed development would contribute towards the Bedford Borough Local Housing Needs Assessment Addendum – April 2022 Update, which in Figure 9 sets out a total affordable housing requirement for 1 bedroom affordable dwellings of 1,218.

The Council’s Housing Strategy 2021-2026 refers to identifying other vulnerable groups of people’s housing needs (8.3.2) and refers to facilitating opportunities to deliver supported housing needs although it does not identify a specific figure for the needs of these groups. As such, this is an important component of housing need not acknowledged in the first paragraph of Policy DM3(S) and a corresponding reference should be provided in the supporting text of the policy.

New specialist housing is referred to in the Council’s Local Housing Needs Assessment which includes supported housing. The glossary to this document refers to the Homes England identification of broad client groups for this type of housing - Capital Funding Guide – 3. Specialist Homes – Guidance – GOV.UK (www.gov.uk) Section 2.3.4 of this document is repeated below : -
1. Purpose-designed supported housing for disabled and vulnerable people
Buildings that are purpose-designed or remodelled to enable residents to adjust to independent living or to enable them to live independently and which require specific design features. There must be support services provided by the landlord or another organisation. As a minimum, a building or scheme must have the following:
Facilities: The scheme or main building must have basic facilities of a laundry for residents or washing machines in living units provided by the landlord and must also have a communal lounge
Design features: The entrance area into the building, communal areas and some living units must be designed to wheelchair user standards
2. Purpose-designed housing for disabled and vulnerable people with access to support
Buildings that are purpose-designed or remodelled to enable residents to adjust to independent living or to enable them to live independently and which require specific design features, as per definition 1 above, but without the requirement for support services to be provided on site. Tenants must instead have access to support and a process be in place to assist in accessing and/or signposting them to the support services that they need.
The proposed development would assist in meeting the needs of vulnerable people who have and are on a journey to independent living with arm’s length support provided, which is a well understood component of housing need that meets specific design requirements.

There is, however, no need figure set out within the LHNA document or within the draft Policy and this presents a clear limitation on how proposals to meet this important component of housing need should be assessed. In practice, as demonstrated by our client’s proposals and the expected profile of future occupiers, the majority of requirements for such accommodation are for one-bed properties.

Draft Policy DM3(S) does not make specific reference or recognise that development may come forward, as proposed at Bedford Heights, that require specific design features and access to support services in response to these needs and should accordingly be assessed favourably in-line with meeting the housing needs of different groups.

Object

Representation ID: 9787

Received: 23/07/2022

Respondent: Mr George Davies

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DM3(S) Housing mix is a good start but completely misses the need to focus on the need, in rural areas, for housing for older people. Retaining downsizing older people in their rural communities is essential.
You have Policy 67 Affordable housing to meet local needs in the rural area and Policy 68 Accommodation for rural workers. These policies support younger people and we need an additional policy in place, to support housing for older people in rural areas.

Comment

Representation ID: 9816

Received: 25/07/2022

Respondent: Pertenhall & Swineshead Parish Council

Policy DM3(S) Housing Mix – no objection.

Comment

Representation ID: 9949

Received: 25/07/2022

Respondent: Barton Willmore

Draft Policy DM3 (Housing Mix) states that new housing developments will be expected to provide a mix of dwelling size and types to meet the identified needs of the community. The Council has produced a Local Housing Needs Assessment (April 2022 update) as part of the evidence for the policy, and refers to other current assessments of housing need including the Older Person’s Accommodation Strategy, the Learning Disabilities Accommodation Strategy, the Mental Health Accommodation Strategy (or their successor Strategies) and evidence in respect of the needs of other specialist groups.
It requires all developments of 100 dwellings or more in suitable locations, to “include specialist housing designed to meet the needs of those with a learning disability or mental health need in accordance with the Council’s most up to date statement of need:
(i) On sites of 3 or more dwellings 47% of all new residential development should meet Category 2 (Accessible and Adaptable dwellings) of approved Document M; Volume 1, and on sites of 20 or more dwellings a minimum of 4% of all market housing and 6% of affordable housing should meet Category 3 requirements,
(ii) All specialist housing for older people should meet Category 3 requirements”.
IM Land supports the principle of addressing the specific local housing needs of Bedford, and creating safe, accessible environments that promote inclusion and community cohesion.
In terms of ensuring that the policy is ‘sound’, footnote 49 of the NPPF sets out that planning policies for housing should make use of the Government’s optional technical standards for accessible and adaptable housing, where this would address an identified need (our emphasis added).
The PPG provides further clarification in terms of the necessary evidence to justify policies in relation to accessibility optional technical standards and makes reference to detailed information on the accessibility and adaptability of the existing stock and the size, how needs vary across different housing tenures and the location, type and quality of dwellings needed (Paragraph: 007 Reference ID: 56-007-20150327). Within the LHNA, an assessment of the need for accessible and adaptable dwellings is provided. However, details relating to the location, type and quality of dwellings needed should be incorporated into the Council’s supporting evidence to ensure that an appropriate evidence base is available to support any proposed policy requirements.
Whilst the LHNA and other current assessments of housing need provide a useful steer in relation to current / future demand, we consider that in order to be ‘sound’, the wording of the policy should be amended to allow for a flexible approach to the tenure requirements on a site-by-site basis e.g. to take into account specific factors which may make a site less suitable for accessible dwellings (PPG, Paragraph: 008 Reference ID: 56-008-20160519) as well as viability assessments where relevant (Paragraph 58 of the NPPF).

Object

Representation ID: 9993

Received: 27/07/2022

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Parts of this policy are unsound as they are unjustified.
25. This policy sets out that affordable housing will be required from all C3 developments for specialist accommodation despite the Viability Study stating in paragraph 6.25 that the viability of such schemes can be challenging except on sites with high sales values and lower existing use values. However, it is notable that the testing in appendix 5 indicates that even on lower value greenfield sites older people’s housing is not viable with a 30% affordable housing contribution and all the other costs arising from policies in the local plan. Therefore, to require contributions from such schemes is not justified by the Council’s evidence.
26. With regard to accessible housing the Council will need to provide clarity as to the category 3 requirements as these are split into two separate categories – wheel chair adaptable and wheelchair accessible – with paragraph 56-010 stating that wheelchair accessible homes can only be required where the council is responsible for nominating the person who lives in that house. The Council should therefore make it clear that for market housing the Council can only requires homes to be built to the wheelchair adaptable optional technical standard.

Comment

Representation ID: 10006

Received: 29/07/2022

Respondent: Inspired Villages

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.

Comment

Representation ID: 10035

Received: 28/07/2022

Respondent: The Southill Estate

Agent: Carter Jonas LLP

Policy DM3(S) seeks to ensure that a mix of house types and sizes are delivered at developments to meet identified needs. The Southill Estate owns land at the Abbey Field West of Elstow site that is a draft allocation for residential development (Policy HOU 5). Criteria ii of Policy HOU 5 also requires that a mix of house types are sizes are provided from this allocation. The promoted development would provide a mix of house types and sizes. As set out in the Southill Estate’s representations to Policy DM1(S), there is potential for a proportion of the housing within this promoted development to be retained specifically for employees at the science and innovation park allocation at Pear Tree Farm. This approach would provide an additional type of housing not mentioned in Policy DM3(S). The housing mix for the promoted development at Abbey Fields West of Elstow would be determined at masterplan and planning application stage.

Comment

Representation ID: 10086

Received: 28/07/2022

Respondent: Churchill Retirement Living

Agent: Ziyad Thomas

Churchill Retirement Living are independent housebuilders specialising in sheltered housing for older people

Paragraph 1 of the PPG Housing for Older and Disabled people states

"The need to provide housing for older people is critical. People are living longer lives and the proportion of older people in the population is increasing ....... Offering older people, a better choice of accommodation to suit their changing needs can help them live independently for longer, feel more connected to their communities and help reduce costs to the social care and health systems. Therefore, an understanding of how the ageing population affects housing needs is something to be considered from the early stages of plan-making through to decision-taking".
Paragraph: 001 Reference ID: 63-001-20190626

In the first instance, we commend the Council for taking active steps to increase the delivery of specialist older persons' housing We note the supporting text to this policy and the requirement for all developments of 500 units and above to provide self-contained housing to meet the needs of older people.

We note however that the accessibility standards for specialist older persons' housing are higher than those for 'general needs' housing, with the policy advising all units must be M4(3).

Footnote 49 of the Framework clearly sets out that planning policies for housing should make use of the Government's optional technical standards for accessible and adaptable housing, where this would address an identified need for such properties

Paragraph 002 (Reference ID 56-002-20160519) of the Planning Practice Guidance (PPG) reiterates that local planning authorities have the option to set additional technical requirements for accessibility and adaptability, however, they will need to gather evidence to determine whether there is a need for additional standards in their area, and justify setting appropriate policies in their Local Plans.

The supporting text for this policy advises that

6.32 Around 35% of the growth in households during the Plan period comprises households aged 75 or over. It is likely that many of these households would also be identified as needing specialist housing for older persons The analysis of the needs of older people identified a need for almost 5,000 specialist older person housing units for households aged 75 or over, whilst the analysis 76 ID: 63-009-20790626 updated on 26 June 2079 707 of disability and mobility housing needs identifies an increase in need of around 720 wheelchair adapted dwellings for households in the same age group

6.33 Whilst not all households aged 75 or over needing wheelchair adapted housing will live in specialist older person housing, at any point in time it is likely that up to a third of those living in specialist housing may need wheelchair adapted homes. However, it is important to recognise that as individual household circumstances change, it is likely that some households will start using a wheelchair whilst living in specialist housing if their health deteriorates. On this basis, a higher proportion of specialist older person housing units will need to be wheelchair adapted The evidence in the LHNA supports the need for a target for all specialist housing for older people to meet Category 3 requirements

The Bedford Borough Local Housing Needs Assessment (2022) does not provide evidence of the need for older person's housing or the need for wheelchair accessibility housing.

7.52 Earlier analysis of housing for older people identified a need for 5,000 specialist older person housing units for households aged 75 or over in Bedford Borough. Whilst not all over 75 households needing wheelchair adapted housing will live in specialist older person housing, it is likely that at a proportion of those living in specialist older housing will need wheelchair adapted homes. The dwelling-led household projection based on 7,305 dwellings per annum (the LHN) that underpins the calculations in this chapter indicates that there will be approximately 72,200 households aged over 75 in 2040. Therefore, the 7,600 75+ households requiring wheelchair adaptations (Figure 76) form 73% of the total 75+ households in 2040. However, given that it is also likely that some older households will progress to using a wheelchair whilst living in specialist housing due to a deterioration in their health, there is a strong case for the percentage of specialist older persons housing that is wheelchair adapted to be at a higher level.

It is the respondent's view that a requirement for wheelchair adaptions in 13% of households aged 75 and over is insufficient justification for 100% of specialist older persons' housing to be built to M4(3) While the policy was written with good intentions, we are strongly of the view that the presumption that just because an individual is over 75 they will require a wheelchair is an inappropriate generalisation.

Churchill Retirement Living have been building retirement living apartments since 1994 and have accrued significant expertise in building specialist housing that enables older people to live independently Recent research into existing Churchill Retirement Living developments has resoundingly demonstrated that there is no need for our apartments to meet M4(3) requirements with less than 1% of our occupiers using a wheelchair full time.

People with long term mobility disabilities would be in a different setting and as such would not occupy an independent living retirement development. Given the lack of demand for the requirement for M4(3) in this form of accommodation it would simply be a cost to development and ultimately an increased purchase cost whilst serving no identified need.

Building to M4(2) provides sufficient accessibility and adaptability for all our current users and future users and is very much in keeping with the product of providing an independent retirement living lifestyle for those aged 60 and over.

Additionally, Paragraph 009 (Reference ID. 56-009-20750327) of the PPG sets out that local plan policies for wheelchair accessible homes should be applied only to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling.

There is no policy requirement or control that the LPA can impose over open market private apartments that could mandate that they must be sold to a wheelchair user.

To that end, I refer the Council to Paragraph 67-69 of the attached appeal decision at Stanford Hill, Lymington (APP/B1740/W /20/3265937) This sets out a view on Optional Technical Standards and in particular a Local Plan policy requirement for 100% of specialist older persons' accommodation to be built to M4(3) dwellings, with the Appeal Inspector concluding

I am mindful also that the design of the appeal scheme seeks to achieve the f'v14(2) Optional Building Regulations standard for accessible and adaptable dwellings - albeit that without a condition specifying this, I accept that the Council could not enforce this standard In any event, the proposed development would cater for a range of occupants, and not only those with impaired mobility. Consequently, I am not persuaded that a requirement for the higher optional standards to be deployed in all of the proposed dwellings would be either reasonable or necessary in this case.

It is clear from this decision that, despite having an adopted policy, the Inspector considered the provision of M4(2) sufficient to cater for a range of occupants and that this technical breach of the policy was not so significant to outweigh the very significant benefits of the scheme.

We are aware that a small number of emerging and adopted Local Plans have introduced policies requiring 100% of specialist older persons' accommodation to be built to M4(3). There may, accordingly, be the mistaken assumption that such policies constitute best practice however for the reasons set out in this representation, we strongly advise the Council that this is not the case. The specialist older persons' housing sector is increasingly challenging such policies at Examination in Public and, in the rare instances they have been adopted, at Appeal

Finally, we would respectfully remind the Council that the PPG states 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" (Paragraph: 002 Reference ID: 10-002- 20190509)

We have reviewed the Bedford Local Plan 2040 - Borough-Wide Viability Study (2022) undertaken by BNP Paribas in which they test the viability of specialist older persons' housing in the Borough

In our response to Policy Df'v17(S) Affordable Housing we detail fully how the viability testing for sheltered housing typologies in the Local Plan Viability Study clearly show that the proposed planning policy regime in Bedford will render this form of accommodation unviable. These conclusions should have prompted the Council to revisit the policy requirement for this form of accommodation so as to not jeopardise its delivery of the Local Plan period.

Conversely however, the planning policy requirements for older persons' housing are higher than for other forms of housing. Policy Df'v13(S) Housing Mix stipulates a requirement for all units of specialist older persons housing to be built to M4(3). The Local Plan Viability Study advises the cost of flats to meet M4(3) is fll,000 per flat (which the respondent considers to be a conservative figure) resulting in an increase to the build cost of a typical SO-unit scheme of £550,000

As such I would respectfully highlight that imposing a 100% M4(3) requirement for all specialist older persons' housing would be unlawful and would not meet the tests of soundness in the NPPF accordingly

In the event the Council does not make the necessary amendments to the above policy then the respondent would like to present their case at Examination in Public.

Comment

Representation ID: 10531

Received: 26/07/2022

Respondent: Barton Willmore

Draft Policy DM3 (Housing Mix) states that new housing developments will be expected to provide a mix of dwelling size and types to meet the identified needs of the community. The Council has produced a Local Housing Needs Assessment (April 2022 update) as part of the evidence for the policy, and refers to other current assessments of housing need including the Older Person’s Accommodation Strategy, the Learning Disabilities Accommodation Strategy, the Mental Health Accommodation Strategy (or their successor Strategies) and evidence in respect of the needs of other specialist groups.
It requires all developments of 100 dwellings or more in suitable locations, to “include specialist housing designed to meet the needs of those with a learning disability or mental health need in accordance with the Council’s most up to date statement of need:
(i) On sites of 3 or more dwellings 47% of all new residential development should meet Category 2 (Accessible and Adaptable dwellings) of approved Document M; Volume 1, and on sites of 20 or more dwellings a minimum of 4% of all market housing and 6% of affordable housing should meet Category 3 requirements,
(ii) All specialist housing for older people should meet Category 3 requirements”.
IM Land supports the principle of addressing the specific local housing needs of Bedford, and creating safe, accessible environments that promote inclusion and community cohesion.
In terms of ensuring that the policy is ‘sound’, footnote 49 of the NPPF sets out that planning policies for housing should make use of the Government’s optional technical standards for accessible and adaptable housing, where this would address an identified need (our emphasis added).
The PPG provides further clarification in terms of the necessary evidence to justify policies in relation to accessibility optional technical standards and makes reference to detailed information on the accessibility and adaptability of the existing stock and the size, how needs vary across different housing tenures and the location, type and quality of dwellings needed (Paragraph: 007 Reference ID: 56-007-20150327). Within the LHNA, an assessment of the need for accessible and adaptable dwellings is provided. However, details relating to the location, type and quality of dwellings needed should be incorporated into the Council’s supporting evidence to ensure that an appropriate evidence base is available to support any proposed policy requirements.
Whilst the LHNA and other current assessments of housing need provide a useful steer in relation to current / future demand, we consider that in order to be ‘sound’, the wording of the policy should be amended to allow for a flexible approach to the tenure requirements on a site-by-site basis e.g. to take into account specific factors which may make a site less suitable for accessible dwellings (PPG, Paragraph: 008 Reference ID: 56-008-20160519) as well as viability assessments where relevant (Paragraph 58 of the NPPF).