Object
Publication
Representation ID: 24442
Received: 22/04/2021
Respondent: Trustees of First Viscount Mackintosh of Halifax and Trustees of CM Watt Residual Trust
Agent: La Ronde Wright
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The Local Plan identifies a significant need regarding the provision of elderly accommodation. Taking the available evidence, (paragraph 276 of the Strategy and the SHMA) this need is identified as between 2842 and 3857 additional specialist retirement units. The local plan identifies 4 sites to accommodate this additional need, however the sites in combination barely provide in excess of 300 units, leaving a potential 3500 units identified as being unmet by the proposed plan. This has further repercussions for neighbouring authorities who may not be able to take the additional need that would be unmet by dedicated allocations. As such, it is considered that draft Policy 5 in regard to elderly accommodation has not been positively prepared. Draft Policy 5 states that any shortfall shall be met through the requirement of making generic housing be accessible and easily adaptable (20% on all major housing developments). Although this is recognised as one potential solution from a housing perspective, adaptable homes do not facilitate medical care or truly enable the occupiers to remain in perpetuity. When occupiers require a few hours a week of care, this will have to be readily available and will likely result in the need for occupiers to vacate their homes for residential institutions causing much distress and at greater cost. The most efficient and viable from a national perspective, is to provide sites that cater specifically for the needs of older people where care is available 24/7 as needed and medical services can be provided to multiple residents in one trip. Such facilities that are age restricted also allow occupiers to enter before their needs are urgent, allowing them to become more accustomed to their surroundings and generally aid their declining years in comfort, knowing whatever happens they will be looked after. As such, the proposed solution of making multiple small pockets of isolated elderly communities is not considered to be justified as an appropriate strategy. Furthermore, this approach of not addressing and catering for elderly need, rather leaving it to chance for being delivered as part of larger residential schemes is not considered to be consistent with paragraph 61 of the NPPF or in accordance with Inspectors rulings regarding other Local Plan adoption processes (see Aylesbury Vale District Council, Vale of Aylesbury Local Plan Policy H6 (C2) Process Note, July 2019, pp 1-5.). A copy id annexed to this submission.
Regarding making the plan sound, it is viewed necessary that new sites be considered for allocation that provide dedicated elderly care facilities in meaningful numbers, to foster new elderly communities in sustainable locations and settings conducive to promoting active living as much as possible. It is considered essential that such facilities do not replicate old care-home institutions, but are more akin to the 'care village model', where independence is guaranteed through individual and self-contained accommodation, and both medical and social care are available on site around the clock. This reduces the need for turbulent evictions of those too old or ill to look after themselves and allows residents to retain an active lifestyle through available community facilities and open space in close proximity. Furthermore, through creating safe environments for residents, active social lives can be encouraged, where public open space is provided in abundance for all. This comes without the necessary maintenance issues that would deter older people from utilising private outdoor amenity space such as private gardens in their later years. Through the allocation of specific sites, the identified need is addressed more comprehensively, and this not only satisfies paragraph 61 of the NPPF but accommodates the vision outlined in the Strategy for promoting healthy vibrant lifestyles for communities.
Please find attached representations in relation to the GNLP Regulation 19 consultation with regard to site GNLP0177-B. These representations are submitted by Le Ronde Wright Limited on behalf of the Trustees of the site.
This representation relates to Policy 3, 5, 6 and the SA. For more details please view the summaries.