Object
Publication
Representation ID: 24444
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
It is considered that Policy 5, and the handling of elderly accommodation has not been positively prepared, is unjustified, ineffective, and inconsistent with national policy due to the failure to secure a suitable strategy to deliver quality elderly accommodation in sufficient numbers to address an identified need.
Paragraph 275 of the Strategy states “an increasing proportion of the population is over 65 or disabled, increasing the demand for supported accommodation such as sheltered housing, extra care housing and care homes, residential care and supported living. The local plan seeks to assist County’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.” There is an ever expanding need for older persons' accommodation. In fact, we applaud the efforts of the Greater Norwich Local Plan in trying to reduce the reliance in the traditional sense of residential care homes. Many individuals have seen how traumatic it is moving loved relatives in the later years of their life to such institutions which are often unfamiliar surroundings which exacerbate deteriorating health conditions.
Paragraph 276 of the Strategy states that “the policy therefore supports the provision of housing to meet the needs of older people and others with support needs, including sheltered housing, residential/nursing care accommodation and extra care housing. Norfolk County Council strategy identifies the need for 2842 additional extra care units by 2028. County wide evidence has identified the need for 3857 specialist retirement units (sheltered, age restricted or extra care housing) in Greater Norwich between 2020 and 2038.” Both of these figures differ from the stated 3,909 spaces within C2 institutions that the SHMA is expecting to be used. Given the discrepancy in the evidence base, it appears that these statistics are not based off of a robust up-to-date evidence base as required by paragraph 35 of the NPPF and as such, do not constitute a justified or sound approach.
Paragraph 277 of the Strategy states “to help provide for this need, the plan contains a specific allocation for a specialised development for active ageing at Colney Hall on site allocations with an element of specialist housing in the policy (Taverham, Aylsham, Harleston and Barrack Street, Norwich). In addition, policy 5 supports the delivery of older peoples and supported accommodation on housing sites with good access to local services including on sites allocated for residential use. The aim of this is to integrate older people and others with supported housing needs with the wider community, assisting active retirement and community cohesion. Development Management officers will ensure that the need for specialist housing for the elderly and other needs is considered on all housing schemes and advise applicants on the most up to date evidence of need.” As paragraph 276 states that there is a need for 3857 specialist units, as paragraph 277 states, this will be addressed through the provision of four dedicated sites with the shortfall being taken up in allocated residential sites.
Taking the above allocations into consideration, they would cumulatively result in the provision of approximately 300 dedicated elderly accommodation units. This is not a sound or appropriate strategy, nor is it positively prepared as the proposed allocations do not meet the areas need, nor does it meet even 25% of the area's identified need. As such, it is considered this approach is not sound in accordance with paragraph 35 of the NPPF.
As stated within the Inspectors report when assessing the Vale of Aylesbury Local Plan Policy H6, specialist housing for older people cannot be expected on mainstream housing sites and these should be addressed by specific allocations. This view is also echoed in paragraph 61 of the NPPF. Schemes that propose elderly care within larger residential allocations typically provide designated cul-de-sacs or clusters of specialist accommodation that does not help in providing or reinforcing community cohesion. Instead, such schemes promote isolation from the wider locality, as these elements within large residential sites are often inwardly focused with either secluded elements of public open space or a lack of connection to wider provision on site. This undermines the aspirations of delivering a healthy and cohesive community in conflict with the aims of the NPPF ultimately resulting in an unsound strategy in conflict with paragraph 35 of the NPPF.
Overall, the plan fails to secure a suitable strategy to deliver quality elderly accommodation in sufficient numbers to address an identified need and as such has not been positively prepared, is unjustified, ineffective, and is inconsistent with national policy.
Many individuals have seen how traumatic it is moving loved relatives in the later years of their life to C2 institutions which often result in unfamiliar surroundings which can exacerbate deteriorating health conditions. As such, the allocation of more 'Care Village' sites, where residents can age gracefully in the relative comfort of their own homes, whilst having independence, as well as medical and social care on site for when they need it, is a better strategy to address the needs of the aging population in the GNLP area. Additionally, through the allocation of specific additional sites, the significant identified need can be better addressed.
For example, one such site of the many needed is the Racecourse Community Park. this site promotes the concept of creating a care village which residents can move into before the critical stage of later life begins whilst they have full cognitive functions. This would foster community cohesion as well aid in stimulating community activities. There would be great benefit in allocating site GNLP0177-B at the Racecourse Community Park for specialist older persons accommodation and care provision to address the identified need. Through the allocation of Site GNLP0177-B , the Plan would not only better address the identified need for elderly accommodation, but provide a better alternative to C2 institutions and be in keeping with the aims and objectives of the GNLP and wider national strategies and ambitions.
As stated with the various evidence bases, there is a predicted short fall of over 3500 specialist units, if these were not to be provided across the residential allocations within the Greater Norwich Local Plan area. Incorporating so many of these in housing allocations has negative repercussions for future residents. Humans by nature thrive in communities, places where social interaction amongst like-minded and similar aged individuals helps retain and improve cognitive functions. The Racecourse Community Park provides the setting, and aspiration to deliver not only purpose-built homes in a community, but homes that would foster and encourage interactions amongst elderly occupiers and residents, whilst also being able to cater for a large dedicated variety of elderly care needs. Additionally, given the rise in suicide rates for elderly individuals due to depression and isolation it is viewed that providing more specialist accommodation clusters, such as this site in a setting which encourages outdoor social interaction could accommodate and help provide a better quality of life. This would also negate the inevitable token 3 or 4 units that will be sandwiched within large residential allocations in order to be policy compliant. As such, it is viewed that dedicated allocations of designated elderly accommodation is preferable not only for future occupiers, but also for developers aiding viability and ensuring deliverability of the residential allocations.
Policy 5 of the Greater Norwich Local Plan relates to the provision of housing. The policy encompasses all elements of housing including affordable housing, space standards, accessible and specialist housing, gypsy and traveler accommodation, purpose-built student accommodation, and self or custom build housing. Regarding the need for the provision of elderly accommodation, Policy 5 supports the incorporation of specialist accommodation within residential proposals. The Racecourse Community Park would include a significant element of specialist accommodation for the elderly and employment generating uses. The site therefore not only ties in with a wider strategic vision for the greater Norwich area but also adheres to the requirements of policy 5. It is noted that policy 5 will support specialist elderly accommodation where there is good access to local services. As part of the overall proposals for this site it is envisaged that a range of services will be provided that not only cover amenity, encouraging a healthy lifestyle, but also basic services to supplement those offered within both Hethersett and Cringleford. This is reinforced by the proposed Highways England improvement works to the A47/ A11 Thickthorn Junction Improvement scheme and the Parkland Management Plan for the Racecourse Community Park which has identified the need for minor allocations (for employment generating uses in close proximity to the Thickthorn Park & Ride extension and new link road) in support of the long-term ambitions and management strategy for the site.
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.