Draft Black Country Plan

Object

Representation ID: 44761

Received: 03/10/2021

Respondent: Churchill Retirement Living and McCarthy Stone Retirement Lifestyles

Agent: Planning Issues

Policy HW1: Health & Wellbeing
We welcome the Council's commitment to the health and wellbeing of its residents. As detailed in our representation to Policy HOU 2 the demographic profile of the Black Country is ageing with the SHMA identifying a requirement for 4,907 additional units of sheltered housing and 604 units of extra care accommodation by 2039.
An ageing population inevitably results in an increase in frail individuals and persons with long term health issues. There is a commensurate pressure on care and health services accordingly with many local authorities spending over a third of their budgets on adult social care currently.
It is well established that poor housing can exacerbate health problems in old age, with enormous resultant costs to the NHS and social care. For example:
Falls - Public Health England statistics show that in 2017/18 falls accounted for 335,000 hospital admissions in England of people aged 65 and over.
Cold Homes - Millions of older people in the UK are living in homes that are too cold. A cold home can cause chronic and acute illnesses and lead to reduced mobility, falls and depression.
Social Isolation - 1.5 million people aged 50 and over are always or often lonely, researchers have calculated. Loneliness makes it harder for people to regulate behaviours such as drinking, smoking, and over-eating, which in turn have their own significant negative outcomes.
Specialist older persons' housing has been developed with the needs of the elderly in mind, enabling them to remain independent for longer. These homes are designed to be warm and with features to alleviate the physical impact of ageing (such as level access throughout) and offer opportunities for residents to access support, care, and companionship. The recently published Healthier and Happier Report by WPI Strategy (September 2019) calculated that the average person living in specialist housing for older people saves the NHS and social services £3,490 per year.
The respondents commend the Council for recognizing the key role that specialist older persons' housing plays in the health and well being of the Black Country within sub-clause c) of this Policy. We are however concerned that the housing needs of the elderly are not considered within the housing policies which is addressed in our representations to Policy HOU2.

Object

Representation ID: 44762

Received: 03/10/2021

Respondent: Churchill Retirement Living and McCarthy Stone Retirement Lifestyles

Agent: Planning Issues

This policy stipulates that some development proposals will need to demonstrate how they address any adcerse health impacts through the submission of a HIA, although the thresholds for doing so are not defined. HIA should be limited to:
1) Forms of development that result in acknowledged adverse impacts on health and well-being, such as hot food takeaways, betting shops and payday loan shops, should be required to submit a HIA.
2) B) Most of the questions in the Health Urban Planning Checklist which is in our experience the most frequently cited template by Las seeking HIA are only relevant to strategic development proposals and have little relevance to small and mid-sized developments.

We would advocate that the threshold for a HIA should be residential development in excess of 100 unit or forms of development in which there are clear issues of health and well-being, such as hot food takeaways and payday loan shops.
Recommendation:
Additional clarity on the thresholds for HIA should be provided in the Black Country Strategy. We would request that HIA’s are limited to developments with a clear detrimental impact on health and well-being and / or housing development in excess of 100 units.

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.

Object

Representation ID: 44764

Received: 03/10/2021

Respondent: Churchill Retirement Living and McCarthy Stone Retirement Lifestyles

Agent: Planning Issues

The benefits of tree planting and their role in the Government’s target to reach net zero by 2050 has been widely publicized. It is commendable that the Council is looking to engage proactively with this matter in the Local Plan.

We note that there is a requirement for all sites to provide a minimum tree canopy cover of 20% of the site area and a recommended level of canopy cover of 30%. It is also noted that the tree planting requirements are expected to be met within the development site and there appears to be no opportunity to provide tree planting off site.
The aim of the replacement tree planting standards would appear to be a long term increase in tree cover rather than like-for-like replacement which will be an impediment to building at higher densities, particularly on previously developed sites in urban areas. This appears to run contrary to Policy HOU2 which encourages the efficient use of land in sustainable, urban environments. While we appreciate there are benefits to providing trees in urban areas, building at higher densities in these locations greatly reduces greenfield land-take and is a highly sustainable outcome accordingly. A reduced tree standard for sites in urban areas would be more appropriate.
Given the significant requirement for tree planting we are surprised that there was no allowance made for tree planting within the Local Plan Viability Assessment. We would respectfully remind the Council that the PPG states that “The role for viability assessment is primarily at the plan make stage. Viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic and that the total cumulative cost of all relevant policies will not undermine deliverability of the Plan.” Para 002 Ref ID: 10-002-20190509
Recommendation:
3) Reduce the requirement for additional tree planting in urban areas
4) To include an allowance for tree planting, green walls/roofs in the Local Plan Viability Assessment.