Regulation 18 Draft Local Plan

Object

Representation ID: 1869

Received: 25/04/2024

Respondent: Inspired Villages

Chapter 2, and the wider draft Local Plan does not go far enough to address the identified need for targeted specialist or extra-care housing provision. Paragraph 2.7 and 2.8 need to include a separate housing target for specialist housing for older people (or extra-case housing), given the substantial need set out in Table 1. This significant need is reflected in the Council’s Local Housing Needs Assessment (Sept 2023), albeit we consider that this need is still underestimated and based on a flawed methodology.

Object

Representation ID: 1870

Received: 25/04/2024

Respondent: Inspired Villages

Support amendments to accord with national policy on climate change and biodiversity net gain, however considers Objective 10 needs to be amended to account for paragraph 63 of the NPPF (2023).
Amendments proposed to objection 10 include deleting text 'including the need for affordable and local-need housing in the District'.
Adding the following text: 'including those who require affordable housing; families with children; older people (including those who require retirement housing, housing-with-care and care homes); students; people with disabilities; service families; travellers; people who rent their homes and people wishing to commission or build their own homes'.

Object

Representation ID: 1871

Received: 25/04/2024

Respondent: Inspired Villages

We are supportive of the principles of Policy SD1 insofar as the wording has been strengthened to incorporate the Council’s commitment to reach net zero carbon by 2050. In particular, we support part (i) which seeks to meet the needs of present and future generations.
We would propose that part (c) of the policy is refined to expressly support proposals such as IRCs which provide services and facilities on-site, thereby significantly reducing the need of residents to travel and increasing the sustainable credentials of the site. We would therefore suggest amending the wording of part (c) by including ‘either on-site, or’ after text ‘facilities can be accessed’.

Object

Representation ID: 1872

Received: 25/04/2024

Respondent: Inspired Villages

This policy sets out a minimum requirement for 14,020 new dwellings over the plan period until 2041. We support the use of the Standard Method to reach this figure, however the Council’s evidence base is clear that there is an acute need for specialist accommodation for older people. Policy SP1 should therefore also specifically identify the housing requirement for specialist housing for older people, across the plan period.

Object

Representation ID: 1873

Received: 25/04/2024

Respondent: Inspired Villages

Supports Policy SP4 insofar as it sets out support for edge of settlement development in certain instances, based on a number of criteria.

Criteria (a) of the policy is not positively prepared, justified or effective. Criterion a. wording
is not positively prepared in that it adds a further requirement on developers which is not consistent with national policy. Whilst prior consultation with the community is fully justified and should be encouraged through policy, a requirement for the consultation to show ‘substantial support’ from specific groups is not effective policy wording. By its nature, even fully policy-compliant development may not receive support from the local community, and given the significant need for development, including specialist housing for older people, such a requirement represents an unnecessary and difficult barrier to development. As such, criteria (a) should be removed from the policy.

Object

Representation ID: 1874

Received: 25/04/2024

Respondent: Inspired Villages

Supports the LHNA for setting out the need for specialist homes for older people. However, we consider the methodologies referenced in the LHNA to calculate the need for older persons housing to be not ambitious enough in nature. Notwithstanding concerns in regard to the methodology used, the Council’s estimated housing need for older people is significant (3,923-4,053) and this figure will only increase when applying a more aspirational methodology.

However, despite this acknowledged significant need, there is no policy wording within the draft document which sets out minimum delivery targets for specialist housing for older people, along with mechanism to monitor its delivery. As such, the initial supporting text of Chapter 7 must include a target for such delivery, across all tenures of specialist housing for older people, and this should then be enshrined in policy, as set out in further detail below.

Object

Representation ID: 1875

Received: 25/04/2024

Respondent: Inspired Villages

The supporting text and policy should acknowledge the viability challenges and operational challenges faced by developers of C2 uses, including integrated retirement communities.
The policy should therefore state that affordable housing is not required for such developments. Alternatively, the Council should use evidence to justify a lower percentage requirement for C2 uses, which should be subject to viability testing.

Object

Representation ID: 1876

Received: 25/04/2024

Respondent: Inspired Villages

Supportive of a policy which specifically addresses the need for specialist homes for older people over the plan period. However, we have concern in regard to the approach as outlined in the proposed draft policy.

A requirement to simply consider the desirability of specialist housing for older people in new housing proposals is a low bar to meet, and is not strongly worded enough to meet the critical need identified both locally and nationally.

The policy suggests that the Council intends to meet their identified need for specialist housing for older people through providing a portion of specialist housing within standard C3 housing proposals. This approach is not effective as it is not realistic to disaggregate IRCs into smaller numbers of units.

The wording of the policy therefore needs to be ‘exceptions-based’, in order to meet the critical needs identified both locally and nationally, specifically it should support the provision of housing for older people in sustainable locations, where there is an identified need.

Object

Representation ID: 1877

Received: 25/04/2024

Respondent: Inspired Villages

Paragraphs 12.1-12.5 should be amended to include ‘and only relates to C3 housing development’ before text ‘The dwelling potential of sites included in the Local Plan is indicative only’.