Comment

Representation ID: 22701

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
37. The Draft Strategy acknowledges at paragraph 245 that an increasing proportion of the population is over 65 or suffers from a disabilty which affects daily activities, increasing the demand for supported accommodation, including care accommodation. The Central Norfolk Strategic Housing Market Assessment 2017 identifies a growth of 3,909 people in care homes for the period 2015 to 2036. It points out that if these bed spaces are not provided, older people will not vacate dwellings and therefore the Local Plan will need to deliver a proportionate increase in housing numbers.
38. The Plan seeks to assist Norfolk County Council’s aim to ‘reduce residential care home and nursing home dependency and support people to remain more independent in their own homes or in supported housing’.
39. This approach is supported in both National Policy and Planning Practice Guidance (PPG). In particular the ‘Housing for Older and Disabled People’ PPG, which requires Plan-makers to consider the diverse needs of older people, including those approaching retirement. The PPG also states that 'Plan-making authorities should set clear policies to address the housing needs of groups with particular needs such as older and disabled people' (Paragraph: 006 Reference ID: 63-006-20190626). The Draft Strategy’s recognition of the need to provide suitable homes in the right locations is supported. A lack of availability of suitable accommodation forces people to move away from friends and family to find a property more suited to their needs, or, to make costly adaptions to their own homes.
40. In order to ensure an adequate provision of specialist housing, Scott Properties believes that Policy 5 – Homes should encourage a range of properties to suit a variety of needs, and specific allocations or requirements within site specific policies should be made for specialist housing, including care homes. Allocations such as Land at Briar Farm, Harleston which will provide opportunities for specialist housing and care facilities should be encouraged. This will ensure that a varied range of accommodation can come forward to meet the diverse needs of older people as set out in PPG and provide choice for those in later life, which can include:
- Age-restricted general market housing;
- Retirement living or sheltered housing;
- Extra care housing or housing-with-care; and
- Residential Care Homes
41. To ensure a variety of the housing, as identified within PPG above is delivered within Greater Norwich, the Plan should make specific allocations as opposed to just a generic housing mix policy that requires a diverse mix of housing. General housebuilders do not build specialist housing, and by providing housing that is deemed as suitable for older people that is also available to the general housing market does not adddress the varied and diverse needs of older people, or those with a disability.
42. We would draw attention to the recent interim findings of the Inspector following the examination of the Suffolk Coastal Local Plan, which states:
'The Plan as submitted seeks to address the needs of older people through Policy SCLP5.8 Housing Mix. The Policy however, whilst supporting the provision of housing for older people, does not address clearly the significant need identified and would not be effective in delivering the market or affordable housing units for older people required. The Policy and supporting text should be amended to set out how the housing needs of older people will be addressed through the provision of housing and to boost the supply of this type of housing.'
43. We would therefore encourage the Council to consider the merits of allocating specific sites for specialist accommodation within the Greater Norwich Local Plan. It is vitally important that suitable housing is provided to meet the needs of an ageing population.
44. The inclusion of a site for a 90 bed C3 care block will ensure that there is accommodation to meet the needs of an ageing population at a local level. Additional specialist accommodation for older people (circa 30 units) is also proposed as part of the area highlighted for “Care” use on the Masterplan. Furthermore, it is proposed that approximately 20% of the dwellings comprise single storey properties suitable for those older members of the community as well as those with or supporting someone with a disability are also proposed at Briar Farm, Harleston. These combined measures will enable people to downsize while remaining in the local area and close to friends, family, and local support networks. By providing this type of accommodation on an edge of town location, it allows people wishing to move to a property better suited to their current or future needs.
45. At present, the retirement housing market is dominated by a handful of providers who typically produce flatted developments within town centres for those approaching the later years of their lives (predominantly 75+ years of age). This results in a lack of choice and highly inflated prices for those aged 75+, who are looking to move to a property more suited to their current or future needs but also wish to remain close to friends and family. Needless to say, the couples and individuals who are of the 60-75 age bracket are left with no alternative housing option, other than making costly adaptations to their existing property.
46. Extensive research has shown a number of benefits arising from the provision of suitable specialist accommodation for the older population. The lack of suitable alternative and attractive accommodation acts as a significant barrier to down-sizing for the over 55s. Providing such accommodation will facilitate the release of under-occupied housing through downsizing. This will free up more housing in the locality for families, thus reducing the pressures on the local authority to make provisions for additional housing and costly adaptations to their existing housing stock.
47. The proposed development could make significant contribution to not only accessible and specialist housing but also much need affordable and market housing within the Greater Norwich area.