Other

ID sylw: 106466

Derbyniwyd: 28/02/2025

Ymatebydd: McCarthy Stone and Churchill Living

Asiant : The Planning Bureau Ltd

Strategic Objective 2:
The NPPF identifies the ‘critical’ need for Older Persons’ Housing (OPH) and specifically refers to this specialist form of housing in Paragraph 63 along with the other forms of specialist housing. This phrasing should also be reflected in the Strategic Objective in recognition of this
critical need and the significant ageing population of South Warwickshire.

Recommendation:
Meeting South Warwickshire's current and future housing need. Allowing growth in new homes that meet the diverse needs of our residents, including affordable, student, specialist (including housing suitable for older people such as retirement housing, housing with-care and care homes); and self and custom build housing along with the
accommodation needs of our gypsy and traveller and travelling show people communities.

Other

ID sylw: 106467

Derbyniwyd: 28/02/2025

Ymatebydd: McCarthy Stone and Churchill Living

Asiant : The Planning Bureau Ltd

The policy does not account for exceptions such as Older persons housing which is mainly provided on brownfield sites of less than 0.5ha in size and may be appropriate, including in terms of density and scale, on sites adjacent to Built Up Areas. OPH should be excluded from the threshold site size limitation.

Recommendation
Where such sites are adjacent to Built Up Area Boundaries, a threshold site size will be established, below which such developments are likely to be acceptable. (The threshold site size will not apply to Older Persons’ Housing)

Other

ID sylw: 106468

Derbyniwyd: 28/02/2025

Ymatebydd: McCarthy Stone and Churchill Living

Asiant : The Planning Bureau Ltd

Proposed policies need to reflect the urgency and ‘critical’ need for Older Persons’ Housing as well as recognising the many additional benefits delivered when such housing is developed in an area.

RECOMMENDATION:
The updated plan should include a specific and dedicated policy supporting the provision of housing for older people. The policy should acknowledge the additional value gained by the provision of dedicated housing for older people which facilitates right sizing in the housing market as well as the potential to achieve significant savings for healthcare together with the social and economic value added to the lives of older people in the area.
The following is a suggested form of wording which may be useful as a starting position for the council to draft a dedicated policy.
“The Council will encourage the provision of specialist housing for older people across all tenures in sustainable locations.
The Council aims to ensure that older people can secure and sustain independence in a home appropriate to their circumstances by providing appropriate housing choice,
particularly retirement housing and Extra Care Housing/Housing with Care. The Council will, through the identification of sites, allowing for windfall developments,
and / or granting of planning consents in sustainable locations, provide for the development of retirement accommodation, residential care homes, close care, Extra
Care and assisted care housing and Continuing Care Retirement Communities. The council recognises the significant health and wider economic benefits associated
with the provision of dedicated housing for older people and will strongly encourage new provision of such housing in sustainable locations”

No

ID sylw: 106469

Derbyniwyd: 28/02/2025

Ymatebydd: McCarthy Stone and Churchill Living

Asiant : The Planning Bureau Ltd

Although we appreciate this consultation is an early stage of plan production, we note that no supporting viability evidence has been published. A Viability Assessment will be a crucial element of the evidence base informing policy and deliverability directly, and must be open
to scrutiny and comment.


RECOMMENDATION:
We strongly recommend that for any policy for older persons’ housing to be considered justified, a viability assessment is run for sheltered and extra-care housing using the assumptions set out within the RHG guidance. These assumptions reflect the inputs and assumptions consistently agreed on a site-by-site level and are therefore appropriate to apply as part of a plan wide viability assessment. Our extensive experience is that the viability of specialist housing for older people will differ
from mainstream housing. Policy targets which reflect actual viability constraints will allow providers of specialist housing for older people to derisk the planning process and provide confidence for investors in the sector.

Other

ID sylw: 106470

Derbyniwyd: 28/02/2025

Ymatebydd: McCarthy Stone and Churchill Living

Asiant : The Planning Bureau Ltd

It is common for Local Authorities to conflate the needs of ‘wheelchair users’ with the needs of older people in the community. A supportive local planning policy framework will be crucial in increasing the delivery of specialist older persons’ housing and it should be acknowledged that although adaptable and accessible housing can assist it does not remove the need for specific older person’s housing. Housing particularly built to M4(3) standard
may serve to institutionalise an older person’s scheme reducing independence contrary to the ethos of older persons and particularly extra care housing. Older people’s housing and particularly extra care housing should therefore be incorporated into the emerging Local
Plan separately to adaptable and accessible housing and not confused with it.
Adaptable houses do not provide the on-site support, care and companionship of specialist older persons’ housing developments nor do they provide the wider community benefits such as releasing under occupied family housing as well as savings to the public purse by reducing the stress of health and social care budgets.
We would also like to remind the council of the increased emphasis on Local Plan viability testing in Paragraph 58 of the NPPF and 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). M4 2 and 3 Housing has a cost implication and may serve to reduce the number of dwellings and further reduce viability. This should be a consideration within the plan.

Other

ID sylw: 106471

Derbyniwyd: 28/02/2025

Ymatebydd: McCarthy Stone and Churchill Living

Asiant : The Planning Bureau Ltd

Were the Council to seek net zero or ask for higher standards than the building regulations from new development from the point of the Local Plan’s adoption then we would remind the Council to include the uplift in build costs for delivering net zero within any forthcoming
Local Plan viability assessment and that the PPG states that “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). Therefore, in order for the future plan to be found sound the following should be implemented:
• Any future policy should be stepped in line with emerging government targets and requirements and
• Ensure the policy is properly assessed within the forthcoming viability assessment

Other

ID sylw: 106472

Derbyniwyd: 28/02/2025

Ymatebydd: McCarthy Stone and Churchill Living

Asiant : The Planning Bureau Ltd

We would like to remind the Council of the increased emphasis on Local Plan viability testing in Paragraph 58 of the NPPF and 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). The introduction of an embodied carbon policy must not be so inflexible that it deems sites unviable and any future policy needs to ensure this to make sure it is consistent with NPPF/PPG and can justified by the
Council. The viability of specialist older persons’ housing is more finely balanced than ‘general needs’ housing and we are strongly of the view that these housing typologies should be robustly assessed in the forthcoming Local Plan Viability Assessment. Additionally, new development will often be far more sustainable in many circumstances
including building fabric by use of modern methods of construction but also extending beyond that, such as sustainability through optimisation of use of a site and operational use of carbon. Existing foundations of buildings that have reached the end of their life cycle will seldom be practicable for new buildings and particularly so in the case of much needed specialised housing for older people.

Other

ID sylw: 106473

Derbyniwyd: 28/02/2025

Ymatebydd: McCarthy Stone and Churchill Living

Asiant : The Planning Bureau Ltd

The option looks to include a policy that requires new developments to incorporate measures to adapt to higher temperatures such as the use of cool materials and using green infrastructure to create cooling. It is recommended that option C7c is taken forward ‘None of these’. This is because this area is now covered via Part O of the Building Regulations and the plan should not seek to amend or go beyond the building regulations. The Council also need to be mindful of how part O (Overheating) of the building regulations is balanced alongside daylight and sunlight requirements.
Therefore, in order for the future plan to be found sound the following should be implemented:
• Any future policy should be stepped in line with emerging government targets and requirements and
• Ensure the policy is properly assessed within the forthcoming viability assessment.

Other

ID sylw: 106474

Derbyniwyd: 28/02/2025

Ymatebydd: McCarthy Stone and Churchill Living

Asiant : The Planning Bureau Ltd

Water efficiency requirements should remain in line with Government targets and the Building Regulations. Were the Council to seek higher standards than the Building
Regulations from new development from the point of the Local Plan’s adoption this would need to be evidenced. We would also remind the Council to include the uplift in build costs for delivering adaptation to flood and drought events that goes beyond the Building Regulations within any forthcoming Local Plan viability assessment and that the PPG states that “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). Therefore, in order for the future plan to be found sound the following should be implemented:
• Any future policy should be stepped in line with emerging government targets and requirements and
• Ensure the policy is properly assessed within the forthcoming viability assessment

No

ID sylw: 106476

Derbyniwyd: 28/02/2025

Ymatebydd: McCarthy Stone and Churchill Living

Asiant : The Planning Bureau Ltd

Drainage requirements should remain in line with Government targets and the Building Regulations. Were the Council to seek higher standards than the Building Regulations from new development from the point of the Local Plan’s adoption this would need to be
evidenced. We would also remind the Council to include the uplift in build costs for delivering adaptation to flood and drought events that goes beyond the Building Regulations within any forthcoming Local Plan viability assessment and that the PPG states that “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).
Therefore, in order for the future plan to be found sound the following should be implemented:
• Any future policy should be stepped in line with emerging government targets and requirements and
• Ensure the policy is properly assessed within the forthcoming viability assessment