H4 clause 1

CPRE Leicestershire supports this policy

Policy H4 1B requires a minimum level of specialist housing to be provided on all residential development proposals of over 100 dwellings. Within the 2016 Viability Study commissioned by Harborough Council, there has been no assessment of the effect of this provision. This is clarified at paragraph ES7 of the Executive Summary. Therefore, the Policy has not been viability tested and is inconsistent with national policy. Paragraph 173 of the NPPF, states "the scale of development in the plan should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened."

Notwithstanding the above objection even if the policy requirement could be shown to be viable it is considered that the size of specialist housing scheme being contemplated (10 units on the basis of 10% of a 100 dwelling scheme) is too small and therefore unlikely to be delivered. In our experience, most providers of specialist schemes for the elderly would only contemplate delivery of 40-50 units as a minimum in any single scheme. This would mean that the Policy should be focussing on a site threshold of 400-500 units rather than 100; assuming that the requirement remains at 10%.

Essential to consider the needs of residents who need/will need specialist housing in the District.

Thurnby and Bushby Parish Council supports as sound.

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.

Refer to attached document.

See attachment for full representation.
We would like to express our support, in general terms, for Policy H4 'Specialist housing' which incorporates support for 'Sheltered and Extra Care Accommodation' within both residential areas and within residential developments of over 100 dwellings.
Notwithstanding the above, we do have some concerns over some aspects of the wording of the supporting text to the aforementioned policy.
The Harborough District Local Plan Proposed Submission confirms that Harborough District has an ageing population, and states that this is more so than the national average. The document identifies the need for specialist housing over the plan period to be 51 dwellings per annum or 1,267 dwellings over the plan period. We commend the Council for taking a proactive approach in assessing the housing needs of its ageing population.
In line with the rest of the country, the document identifies Key Issue 2: Meeting Housing Needs which demonstrates an acceptance that the demographic profile of the Authority is projected to age. The largest proportional increases in the older population are expected to be of the 'frail' elderly, those aged 85 and over, who are more likely to require specialist care and accommodation provided by Extra Care accommodation. It is therefore clear that the provision of adequate support and accommodation for the increasingly ageing demographic profile of the Borough is a significant challenge.
Unless properly planned for, there is likely to be a serious shortfall in specialist accommodation for the older population in the district, which will have a knock on effect in meeting the housing needs of the whole area and wider policy objectives. Specialist accommodation for the elderly, such as that provided by McCarthy and Stone, will therefore have a vital role in meeting the areas housing needs.
We would advocate that the Council continues in taking a positive approach in seeking to provide appropriate accommodation to meet the needs of its ageing population within the Local Plan. We consider that the best approach towards meeting the diverse housing needs of older people is one that encourages both the delivery of specialist forms of accommodation such as sheltered / retirement housing and Extra Care accommodation. While we commend the council for the inclusion of Policy H4 'Specialist Housing which seeks to meet the need for accommodation for the elderly population we believe that the supporting text should be amended to reflect that most forms of extra care accommodation should be classified as Use Class C2.
We also note that Para 5.3.10 of the Proposed Submission Local Plan states: "it is recognized that provision of affordable housing may be particularly difficult to achieve in relation to extra care schemes and other types of supported living schemes. In such circumstances, the policy will be implemented on a case by case basis, and the individual viability assessment and its review will be used to demonstrate an appropriate affordable housing requirement / commuted sum." We welcome this approach, however it should be stressed where Extra Care accommodation falls under use class C2 it should not be liable for affordable housing.
Extra Care accommodation, provides a valuable form of specialised accommodation, which meets a specific housing need. In so doing, it gives rise to significant planning and social benefits which realise other planning objectives that national and regional policy give priority to. It provides purpose-built, specifically designed accommodation in a safe and secure environment including companionship whilst allowing an independent lifestyle. Safety, security and companionship reduces anxieties and maintains health and general wellbeing. It also provides a form of housing which meets better the on-set and increasing problems of mobility/frailty while maintaining an independent lifestyle.
One of the main distinguishing features between a residential use (C3) and a care/residential institutional use (C2) is the degree of personal care for the person living in the accommodation. Care needs are assessed prior to entry and residents select the most appropriate level of care for their needs and the level of care provided can be modified in response to the changing needs of the residents. Staff provide 24 hour cover for the benefit of the residents, and typically consist of a Manager, assisted by a team of Deputy Managers and support staff, who provide assistance with daily activities and care to residents, as well as a chef and grounds management. In a typical 50 unit scheme, there is a mix of full and part time positions which broadly equates to between 14-17 full time equivalent posts. It should be noted that some personnel take on a dual role providing both care as well as other duties and a rota system is operated.
We would like to highlight the advice provide in the Housing in Later Life: Planning Ahead for Specialist Housing for Older People toolkit. This toolkit was developed by a consortium of private and public organisations with an interest in housing for the elderly and encourages a joined up approach to planning, housing and social care policy both in the collection of evidence and the development of specialist accommodation for the elderly. A copy of this document has been appended for your convenience. Whilst we appreciate that no one planning approach will be appropriate for all areas, an example policy is provided that, we hope, will provide a useful reference for the Council (see attached document).
Specialist accommodation for the elderly also usually provides an element of care and communal facilities at an additional cost to the developer. This requires a critical mass of residents in order to be feasible and small scale developments of specialist housing for the elderly could not be realistically asked to provide or maintain such facilities. It is therefore unlikely to expect the provision of specialist accommodation for the elderly to be met piecemeal in general needs housing developments.
Well located and designed specialist housing for older home owners is a highly sustainable form of housing. Given the critical need for older persons accommodation in Harborough District there should be a presumption in favour of sustainable housing and in particular specialist housing which is being proposed on suitable sites. This accommodation will come from a number of sources both public and private and with varying levels of care and shelter provision enabling individual people to remain in their own home with independence and security.