Regulation 19 - Proposed Draft Local Plan Submission
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Regulation 19 - Proposed Draft Local Plan Submission
Policy HN01 Housing Need: Affordable Homes
Representation ID: 13774
Received: 02/05/2025
Respondent: Churchill Living and McCarthy Stone
Agent: Planning Issues
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The approach applied within the PWVS is somewhat confusing, with an emphasis on testing greenfield development over brownfield. older persons housing rarely, if ever, comes forward on greenfield land due to the lack of adjacent amenity and facilities, as well as a requirement to be less dependent upon use of a car.
The basis of testing the viability of older persons housing is therefore flawed in our opinion
The draft policy expects proposals of 10 or more homes to provide 40% affordable housing. No policy flexibility is proposed for older persons housing despite the viability testing outcomes.
The council’s viability testing has found that the target of 40% is not viable and specifically in relation to older person’s housing, the council may need to take a more flexible approach in terms of application of affordable housing policy.
HN01 confirms that the affordable housing policy will not apply to proposals for older persons housing. It should be acknowledged that affordable forms of older persons housing are more likely to come forward as part of developments by registered providers for the reasons set out above.
Table 11 of the plan shows that overall, the affordable housing needs for older people is closer to 15% of overall demand. On the basis of housing need alone, a 40% target is not justified.
See attached document for representation.
Object
Regulation 19 - Proposed Draft Local Plan Submission
Policy HN02 Housing Need: Mix of New Homes
Representation ID: 13776
Received: 02/05/2025
Respondent: Churchill Living and McCarthy Stone
Agent: Planning Issues
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The plan wide study has not shown the above requirements to be viable in respect of older persons housing. It also fails to address the additional size requirements of providing M4(3) accommodation which result in larger unit and communal area requirements.
The policy must be amended to allow for these standards to be applied subject to financial viability and evidence of need.
We would like to engage with officers to address the issues set out above and welcome the opportunity to take part in further consultation events going forward. Where the council propose to update and consult upon their plan wide viability assessment, we like to contribute to the stakeholder events
The plan wide study has not shown the above requirements to be viable in respect of older persons housing. It also fails to address the additional size requirements of providing M4(3) accommodation which result in larger unit and communal area requirements.
The policy must be amended to allow for these standards to be applied subject to financial viability and evidence of need.
See attached document for representation.
