Part One: Spatial Strategy and Policies (Regulation 19)

Comment

Representation ID: 1247

Received: 29/11/2024

Respondent: Churchill Retirement Living

Agent: Planning Issues Ltd

This policy stipulates that some development proposals will need to demonstrate how they address any adverse health impacts through the submission of a health impact assessment.

Older Persons' Housing produces a large number of significant benefits which can help to reduce the demands exerted on Health and Social Services and other care facilities - not only in terms of the fact that many of the residents remain in better health, both physically and mentally, but also doctors, physiotherapists, community nurses, hairdressers and other essential practitioners can all attend to visit several occupiers at once. This leads to a far more efficient and effective use of public resources.

A report "Healthier and Happier' An analysis of the fiscal and wellbeing benefits of building more homes for later living" by WPI Strategy for Homes for Later Living explored the significant savings that Government and individuals could expect to make if more older people in the UK could access this type of housing. The analysis showed that: 'Each person living in a home for later living enjoys a reduced risk of health challenges, contributing to fiscal savings to the NHS and social care services of approximately £3,500 per year. Building 30,000 more retirement housing dwellings every year for the next 10 years would generate fiscal savings across the NHS and social services of £2.1bn per year. On a selection of national well-being criteria such as happiness and life satisfaction, an average person aged 80 feels as good as someone 10 years younger after moving from mainstream housing to housing specially designed for later living.'
Furthermore, sub-clause 2 e) requires a screening assessment for the loss of community facilities and public open space. There is a presumption against the loss of public open space and recreational facilities in national policy (Para. 97 of the NPPF) and in other emerging Local Plan policies (i.e. DLP16, 23, 26, 37, 38) unless it can be comprehensively demonstrated that these facilities are no longer required or have been replaced. There would accordingly appear to be a significant amount of overlap therefore between the evidence required for the loss of community facilities / open space and the Health Screening Assessment and we would respectfully ask the Council to consider if sub-clause 2 e) is necessary on that basis.
RECOMMENDATIONS:
For the future plan to be in line with national policy and effective the following wording should be included to recognise the health benefits of older persons housing.
Specialist Housing for older people has a number of health benefits and proposals for such schemes will not be required to submit a Health Impact Assessment

Comment

Representation ID: 1249

Received: 29/11/2024

Respondent: Churchill Retirement Living

Agent: Planning Issues Ltd

Since the Regulation 18 consultation, held in November 2023, the Council have published their Dudley Local Plan Viability Study (November 2023) and Addendum Report (September 2024). The Addendum Report recently published is welcomed given its specific review of Older Persons Housing.
The Viability Report Addendum undertakes viability on both older persons housing and extra care schemes in three value zones, the schemes are all comprised of 60 units.
Paragraph 8.62 stipulates:
Across all the schemes, negative RLVs ranging from -£3,950,000 to - £3,023,000 per acre, meaning that all the schemes produce a large deficit when compared to the BLV's. This therefore means that all the schemes are fundamentally unviable. (our emphasis added)
Paragraph 11.13 further confirms:
Given the results of our viability appraisals in section 8 confirming that Older Persons's housing to be fundamentally unviable, we recommend that affordable housing provision is not included on retirement living and extra care schemes.

When reviewing the wording of Policy DLP12, it is greatly welcomed that the Council have proposed under Point 2) older person's homes for retirement living/sheltered housing and extra care as defined in the PPG are excluded from providing affordable housing. This considers the findings of the viability review recently undertaken and is therefore sound.

However, Point 3) of draft Policy DLP12 goes on to state "The Council will engage proactively with developers of older persons housing to seek to meet the identified affordable housing needs of the borough, including via partnership working and identifying funding and grant programs" This subsequent point therefore entirely contradicts the earlier exclusion of older persons housing in providing affordable housing within the three value zones. This would also be considered contrary to PPG guidance which states:

"Policy requirements should be clear SO that they can be accurately accounted for in the price paid for land. To provide this certainty, affordable housing requirements should be expressed as a single figure rather than a range."

Having gone to the extents of testing the typology at the plan making stage, to then contradict the findings seems to be a wasted exercise and contrary to the PPG which clearly requires that local plan policy should be clear and accurate, by way of providing expressed single figures rather than a range.
RECOMMENDATIONS:
We recommend the following amendment to draft policy DLP12 to ensure accordance with national guidance and the Council's own viability findings.
"The Council will engage proactively with developers of older persons housing to seek to meet the identified affordable housing needs of borough, including via partnership working and identifying funding and grant programs"

Comment

Representation ID: 1251

Received: 29/11/2024

Respondent: Churchill Retirement Living

Agent: Planning Issues Ltd

Paragraph 1 of the PPG Housing for Older and Disabled people states:
"The need to provide housing for older people is critical. People are living longer lives and the proportion of older people in the population is increasing. Offering older people, a better choice of accommodation to suit their changing needs can help them live independently for longer, feel more connected to their communities and help
reduce costs to the social care and health systems. Therefore, an understanding of how the ageing population affects housing needs is something to be considered from
the early stages of plan-making through to decision-taking".
The delivery of a suitable level of specialist older persons' housing will be a substantial undertaking over the Local Plan period and unless action is urgently taken the Council
will struggle to address this need. The inclusion of a dedicated policy which is supportive of the need to deliver specialist older persons' housing at suitable locations is commendable and supported accordingly.
We note the policy requires at points c) that provision for sufficient parking for residents, staff and visitors and manoeuvring of vehicles and impact on highway safety; and point d) provision of private amenity space or be in close proximity to in area of public open space. Whilst we understand the value of these requirements to the future occupants of developments, it must be ensured that there are specific adopted parking and amenity standards respectively which developers can refer to in tandem with the policy requirements.

Comment

Representation ID: 1252

Received: 29/11/2024

Respondent: Churchill Retirement Living

Agent: Planning Issues Ltd

The benefits of tree planting and their role in the Government's target to reach net zero by 2050 has been widely publicised. 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. 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 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 DLP2 Growth Network: Regeneration Corridors and Centres 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 reduces greenfield land-take and is a highly sustainable outcome accordingly. Large, landscaped areas are not always feasible, or desirable in higher density urban environments, such as town centre or edge of centre locations. A reduced tree standard for sites in urban areas would be more appropriate.

Given the significant requirement for tree planting an appropriate allowance should be 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 making 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" (Paragraph: 002 Reference ID: 10-002-20190509).

From reviewing the November 2023 Viability Study, it is clear to see an assumption has been made for the provision of trees and protection of trees, woodland and Ancient Woodland is to be included in the professional fee budget. However, there is no consideration of the cost to development in providing a 20% tree canopy coverage on site, especially on constrained brownfield sites of which both McCarthy Stone and Churchill Living are almost exclusively modelled on.