Policy H4 seeks the delivery of specialist housing, such as sheltered and extra care accommodation as an integral part of all residential developments of over 100 dwellings, at a rate of 10%, where the site offers a suitable location for the provision of specialist housing; and provision of specialist housing would not impact upon deliverability/viability.

Firstly, the relationship between this policy requirement and the proposed requirement for 4% Part M Category 2 in Policy H5 is unclear. If taken as separate requirements, and in combination with the proposed affordable housing requirements, this could have an impact upon the viability of residential schemes.

The HEDNA concludes that councils should also give consideration to the potential to identify sites in accessible locations for specialist housing. The supporting text states that no such sites were submitted via the SHLAA, however it is not clear if consultation with any extra care providers has taken place as part of the Local Plan preparation.

The February 2017 Housing White Paper highlights the issues faced by an ageing population in terms of housing and confirms it is committed to exploring this issue further with a wide range of stakeholders, including housebuilders (paragraph 4.43). The White Paper goes on to confirm that the government is committed to funding and developing supporting housing, including sheltered, step down and extra care housing. Any further government guidance on this issue should be taken into account during the Local Plan preparation process as it may impact upon the proposed requirements at part 1 b) of the Policy H4.