Regulation 19 - Proposed Draft Local Plan Submission

The requirement for 10% of specialist housing for older people on all residential developments of 100 dwellings or more is unsound and should be deleted in favour of a combination of specialist site allocations and flexible policies promoting windfall delivery.

Manor Oak Homes is concerned that the implications of the proposed policy requirement for 10% specialist housing for older people on all residential developments of 100 dwellings or more has not been properly thought through. Table 11 identifies a need for c.800 units of specialist housing for older people by 2041 and the Council has simply determined that the easiest way for this need to be met on paper is to require 10% provision on larger residential developments. No consideration has been given to the appropriateness and effectiveness of this strategy in terms of its impact on the delivery of residential sites or whether it will actually deliver the required number of units of specialist housing.

To take the impact on residential delivery first. The types of specialist housing for the elderly listed in Table 11 show that the Council is referring to specialist retirement/sheltered housing as a minimum in terms of the level of residential support required. Bungalows and accessible ground floor apartments would not be counted towards the requirement. The types of specialist housing required are therefore of the type that are developed and operated by specialist providers. This means that for every site of over 100 dwellings, there will be a requirement to design and integrate a dedicated area for specialist housing into the scheme. This area will then need to be marketed separately to specialist providers and in many instances the number of units to be provided (e.g. just 10 for a scheme of 100 dwellings) will mean that there is little demand from providers who typically need many more units in order to cost effectively provide suitable levels of support to residents. All this will simply serve to delay the delivery of much needed housing without necessarily improving the delivery of specialist units.

The simple introduction of a requirement for every large residential development to provide specialist elderly housing units does not produce an effective strategy for their delivery. This is especially true when one considers the numbers involved. The identified specialist housing need to 2041 is for c.800 units which will need to be delivered on new allocations of over 100 dwellings which are only forecast to deliver c.5,500 dwellings by 2041. 10% of these dwellings would therefore only provide c.550 units and likely far fewer given the above concerns. This further highlights that this is an unjustified and inappropriate strategy which must be considered to be unsound in the context of far more appropriate alternative solutions to meeting specialist housing needs. For example, allocating specific sites for specialist housing and introducing flexible policies allowing the delivery of such schemes on exception sites in certain appropriate areas.

The requirement for 10% of self and custom build plots on all developments of 40 dwellings or more is unsound and should be deleted in favour of a flexible policy allowing windfall delivery.

The requirement for 10% self and custom build plots on all developments of 40 dwellings or more is not justified by the Council’s evidence of need. Local Plan paragraph 6.24 states that there is currently a demand for 298 plots as at 30 October 2024, and that there is typically an average of 36 entries onto the registry a year. Very simply this indicates a requirement for c.800 plots which would be met by the 10% requirement, but there are a couple of issues with how this information is presented:

• Self-Build Register: The Council has not published a detailed summary of the self-build register as part of the evidence base for the plan. This is important in terms of assessing the type, size and location of plots sought and whether this demand would be met by the provision of building plots on largescale developments. From the statement at paragraph 6.24 that “the strongest demand is for 4-bed properties and plots over 500 sqm” there is a strong indication the self-builders are not looking for serviced plots on residential developments.

• Existing Delivery: The requirement to keep a self-build register was introduced in 2016 and LPAs are required to grant sufficient planning permissions for entries on the register within a rolling 3 year period. On this basis, assuming that the current demand of 298 plots is simply the cumulative number of entries on the register since 2016, then planning permissions should already have been granted to meet a significant proportion of this need. Without data on existing permissions and completions, it is not possible to accurately assess current demand. We would also expect the Council to undertake a regular review of the register to ensure that any entrants that have not secured a plot are still seeking one.

In the absence of more detailed evidence to confirm the current demand for self-build plots and whether this demand would be suitably met by serviced plots on large-scale housing allocations, Policy HN05 must be considered unsound. A far more appropriate alternative solution to meeting the demand for self-build plots, which would truly serve the needs of people seeking to build their own homes would be to introduce a flexible policy allowing the delivery of self-build dwellings on exception sites in certain appropriate areas.