Object

Representation ID: 44763

Received: 03/10/2021

Respondent: Churchill Retirement Living and McCarthy Stone Retirement Lifestyles

Agent: Planning Issues

McCarthy Stone and Churchill Retirement Living are independent and competing housebuilders specializing in retirement living housing for older people. Together we are responsible for delivering approx. 90% of England’s specialist owner-occupied retirement housing. Para 1 of PPG states: “The need to provide…. Plan-making through to decision-taking”
The SHMA notes that there is a substantial need for retirement housing accommodation in the Black Country, with a particular need for owner occupied retirement accommodation, stating that: "To meet local demand rates in 2039, the model identifies a requirement for 4,907 additional units of Sheltered housing for older people and 604 additional Enhanced Sheltered/ Extracare units in the Black Country over the plan period (definitions set out in footnotes 66 and 67). Of the 4,907 new units of Sheltered housing for older people, almost two-thirds should be market accommodation, with the remainder affordable"
It is clear that that there is an existing tenure mismatch in specialist older persons' accommodation in the County that needs to be addressed through the Local Development Plan and, unless properly planned for, there is likely to be a serious shortfall in specialist accommodation for the older population, which will have a knock-on effect in meeting the housing needs of the whole Black Country area and wider policy objectives.
Policy HOU2 deals with Housing Density, Type and Accessibility. We were surprised that the local authority did not specify that specialist accommodation for older people should be promoted despite the need for such accommodation forming over 10% of the housing need over the BCP period. The BCP seems to address the need for older persons' accommodation within Policy HW1. While specialist accommodation for older people does provide many health benefits for older persons it is our view that given the critical need for specialist retirement accommodation that Policy HOU2 should be amended to support the delivery of this type of accommodation in this policy in addition to within policy HW1. In addition to this, due to the nature of this type of accommodation it should be made clear that sub section 3 of this policy does not apply to providers of specialist accommodation for older people as a mix of tenures and unit sizes would be inappropriate for this form of accommodation.
RECOMMENDATION
To address the concerns detailed in our representation we would suggest the following amendments to Policy HOU2:
- ADDITION OF SUBHEADER D TO PART 1 supporting the provision of specialist accommodation for older people.
- Addition of Asterix to part 3 to note that this part of the policy will not apply
to specialist accommodation for older people.
Policy HOU3 - Delivering Affordable. Wheelchair Accessible and Self Build / Custom Build Housing
The Black Country Plan (Regulation 18 Consultation) is one of an alarmingly limited number of emerging Local Plans that have set a differential affordable housing rate of between 10% and 30% which is dependent on the anticipated sales prices for housing (i.e. the `value zones') and whether the land is greenfield or brownfield. This is, of itself, highly commendable and suggests a greater focus on viability at the Plan making stage.
The affordable housing targets detailed in the above policy are informed by the Black Country Plan Viability and Delivery Study (BCVDS) undertaken by Aspinall Verdi.
In assessing the BCVDS we note that no viability appraisals were undertaken for specialist older persons' housing typologies - namely Sheltered Housing and Extra Care accommodation. This is disappointing and considered to be contrary to both best practice and the typology approach detailed in Paragraph: 004 (Reference ID:10-004-20190509) of the PPG which states that. "A typology approach is a process plan makers can follow to ensure that they are creating realistic, deliverable policies based on the type of sites that are likely to come forward for development over the plan period.
This is a surprising omission and contrary to industry best practice in our view. We respectfully request that viability appraisals are undertaken for these forms of development and that we are provided with the opportunity for comment prior to the Regulation 19 consultation.
The SHMA identifies a requirement for 4,907 additional units of sheltered housing and 604 units of extra care accommodation by 2039. The Local Plan makes it clear that viable sites bringing these forms over development forward will be required over the Plan period. In burdening these forms of development with an unrealistic planning obligations regime, the Local Plan is considered to be unsound as these obligations are not justified, effective and the Plan is not positively prepared correspondingly.
The BCVDS concludes that all housing development in the Lower Value Zones cannot
deliver 10% affordable housing viably. Flatted housing typologies, which it is
presumed includes retirement living and extra care housing, are generally not viable (paragraph 6.85) and this is most pronounced in lower value areas and previously developed land. Specialist older persons' housing is even more finely balanced than `general needs' flatted developments given the longer sales period, higher build costs and cost of providing communal facilities.
Given the substantial weight attributed to the use of brownfield land within settlements for homes in paragraph 118 of the NPPF and the Council's emphasis on sustainability in Local Plan, it is both surprising and disappointing that it should look to impose an unrealistic planning obligations burden on development in the most sustainable locations.
The PPG makes it clear that `Different requirements may be set for different types or location of site or types of development' (Paragraph: 001 Reference ID: 10-001¬20190509). We are strongly of the view that it would be more appropriate to set a lower, potentially nil, affordable housing target for flatted development in urban areas.
The Local Plan is therefore considered to be unsound on the grounds the affordable housing targets are not justified, positively prepared or effective.
RECOMMENDATION:
McCarthy Stone and Churchill Retirement Living consider that the Black Country Plan Viability and Delivery Study does not provide a credible basis for seeking affordable housing contributions from Retirement Living and Extra Care Housing as unusually, and contrary to best practice, viability appraisals were not undertaken for specialist older persons' housing typologies.
This is particularly concerning as that the viability of flatted development in the Black Country is acknowledged as being finely balanced and specialist older persons' housing have higher build costs and a slower sales rate than `general needs' flats.
In light of the above, we respectfully request that viability appraisals are undertaken for these forms of development and that we are provided with the opportunity for comment prior to the Regulation 19 consultation.