Bloor Homes has no objection to the principle of sheltered and extra care accommodation being provided in appropriate locations, but questions the basis and associated evidence upon which at least 10% of housing is required for this purpose as part of developments over 100 dwellings in size. This prescriptive approach does not take account of local need or the site and location specific constraints to delivery of specialist housing of this type. Conversely, the policy text (para 5.7.5) recognises the significance of providing properties suitable for older people within the District's villages, reflecting a generally higher age profile in these locations, and a more significant contribution may therefore be appropriate in these locations rather than on larger sites. Moreover, the imposition of a blanket requirement adds a further unnecessary layer of complexity that will only delay the delivery of the much needed housing in the District.

Consequently, the Submission Plan should seek to identify and allocate specific development sites to address these needs where they are required. Whilst it may then be appropriate to encourage the specialist housing provision in general housing developments, provision must be based on robust and credible evidence that identifies an up to date local need, including the monitoring of market activity over the plan period to identify the ability of developers to deliver specialist housing across the differing locations within the District.

Moreover, whilst the reference in Part 1b to taking account of the impact on deliverability and/or viability of developments is welcomed, the provision of specialist housing may have a critical affect on the viability of new housing developments in the District, and the deliverability of sustainable development cannot be compromised by unduly onerous policy requirements. The Council must, therefore, demonstrate that the policy and infrastructure requirements in the Local Plan (cumulatively) in terms of financial contributions are achievable and do not render development unviable (NPPF paragraphs 158, 173-174). That must be considered at this stage. There is no evidence to that effect at this point in time as these policy requirements have not been robustly considered Local Plan's Viability Report.

Soundness:
For the reasons set out above, Bloor Homes object to Policy H4, which is considered unsound on the basis that it:
- is not justified in that it is not the most appropriate strategy and has not properly considered reasonable alternative strategies; and
- is inconsistent with national guidance in that it does not fully reflect the Government's objective to ensure the housing requirements are not prohibitive to the delivery of development.

Proposed Changes:
To remedy the flaws in the soundness of the plan the evidence required to support the imposition of the housing requirements must be provided and the cumulative impact on the viability of sustainable development examined.