Question 29: Do you support, object or have any comments relating to the approach to accessible and specialist Housing?

Support

Representation ID: 20978

Received: 14/03/2020

Respondent: Mr Andrew Cawdron

Essential.

Comment

Representation ID: 21000

Received: 14/03/2020

Respondent: Mr Keith Benjafield

Sufficient residential care home should be provided as currently there appears to be a shortfall. These homes should be of the standard whereby persons have their own independent living with the support of community facilities (shop hairdressers , bar etc. )and support within the development .
An example I have witnessed is where the development consists of independent living , Care home , and nursing home all integrated with beautiful gardens etc. this allows for an easier transition if and when required

Comment

Representation ID: 21581

Received: 16/03/2020

Respondent: Hingham Town Council

The Policy does not take into account or directly address the needs of older people generally, who reside within general accommodation within developments, e.g people that may wish to downsize from house to a bungalow, it does not take into account that these people will grow older while in their home and may have greater needs as they age. Therefore ALL development should address the need for residents to have good access to services within the community, and infrastructure within the community be improved sufficiently to be able to provide this, for example adequate footways and pedestrian priority crossing points.

Support

Representation ID: 21755

Received: 16/03/2020

Respondent: Brown & Co

We support the approach to accessible and specialist housing.
Clarion provide specialist LiveSmart Housing; delivering facilities management and intensive housing management for older residents. This enables residents to benefit from safe, secure and consistent services, and a designated staff member to provide regular contact and comfort.

Comment

Representation ID: 21910

Received: 12/03/2020

Respondent: Home Builders Federation

We welcome the support in this policy to supporting specialist accommodation for older people. However, given that paragraph 63-006 states that the Council should: “… set clear policies to address the housing needs of groups with particular needs such as older people…” with paragraph 63-016 going on to state that where there is an identified unmet need for specialist houses that “local authorities should take a positive approach to schemes that address this need” we consider it to be essential that the Council establishes within policy the amount of such specialist accommodation the Council will seek to provide. Without the clarity of a stated requirement for such homes it will not be clear to decision makers of the need for such schemes and whether there is an under provision this of specialist accommodation for older people. We would also suggest that the Council’s work with specialist providers to identify suitable sites that will meet the specific needs of older people. We recognise that PPG does not require allocations to be made it is necessary for older peoples housing to be in sustainable locations close to services and as such it is important to work closely with this sector of the housebuilding industry to understand the needs of their customers and where possible allocate appropriate sites.

Comment

Representation ID: 22134

Received: 16/03/2020

Respondent: M Scott Properties Ltd

Agent: Strutt & Parker LLP

The Draft Strategy acknowledgs at paragraph 245 that an increasing proportion of the population is over 65 or disabled, increasing the demand for supported accommodation. 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 supporte housing’.

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). We support the Draft Strategy’s recognition of the need to provide suitable homes in the right locations. 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.

In order to ensure an adequate provision of specialist housing, Scott Properties believe 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, and portions of allocations such as Land between Shelfanger and Mount Street, Diss should be set aside for specialist housing. This will ensure that a varied type of housing 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

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.

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.'

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.

Approximately 24 single-storey properties specifically designed for those aged 55 and over as well as those with or supporting someone with a disability are proposed at Land between Shelfanger and Mount Street, Diss (as shown on the accompanying indicative masterplan). Providing this type of accommodation in a central town location, allows people to move to a property better suited to their current or future needs, whilst remaining close to friends and family.

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.

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.

The proposed development could make contribution to not only accessible and specialist housing but also much need affordable and market housing within the Greater Norwich area in a sustainable location. As such we consider the GNLP should reconsider our client’s site Land between Shelfanger and Mount Street, Diss and include it as an alloaction in the Regulation 19 Draft Plan.

Comment

Representation ID: 22142

Received: 16/03/2020

Respondent: Cygnet Care Ltd

Agent: CODE Development Planners Ltd

The policy supports proposals providing specialist housing options for older people’s accommodation and others with support needs, including through the provision of sheltered housing, supported housing, extra care housing and residential/nursing care homes, where there is good access to local services. However, to meet changing needs, the policy requires at least 20% of homes proposed through major housing developments to be constructed to Building Regulation M4 (2)[1) standard or any successor. The supporting text to the policy (paragraphs 245 and 246) recognises the increasing proportion of the population is over 65 or disabled, which is increasing the demand for specialist accommodation across the Greater Norwich Local Plan (GNLP) area (and nationwide). Paragraph 246 recognises the need for 2,842 additional extra care units by 2028. The construction of 20% of homes on major development proposals to Building Regulation M4(2)[1] standard (or any successor) will not meet the ever increasing need for extra care units (or other types of specialist accommodation for older people) across the local plan area. Planning practice guidance (PPG) (paragraph 006 Reference ID: 63-006-20190626) states “Plan-making authorities should set clear policies to address the housing needs of groups with particular needs such as older and disabled people. These policies can set out how the plan-making authority will consider proposals for the different types of housing that these groups are likely to require. They could also provide indicative figures or a range for the number of units of specialist housing for older people needed across the plan area throughout the plan period.” In addition, the PPG considers “Plans need to provide for specialist housing for older people where a need exists. Innovative and diverse housing models will need to be considered where appropriate” (paragraph 012 Reference ID: 63-012-20190626. The Regulation 18 version of the GNLP recognises the need for additional extra care units (2.842 additional extra care units by 2028) but does not make any formal allocations to meet the need over the period to 2028 (and beyond). In these circumstances and considering the advice contained within national planning policy and guidance, CODE Development Planners consider that formal allocations should be made within the GNLP to meet the need for specialist housing for older people over the plan period. At the very least, Policy 5 (Homes) should ensure that where new specialist accommodation might best be located outside of existing settlement boundaries (but still within suitable walking and cycling distance to existing services and facilities, or where sustainable public transport options exist to provide access to those services), development is not precluded by restrictive policies which only allow development within settlement boundaries. To assist the authorities in meeting the need for new specialist housing over the plan period, the following site (GNLP0280) on land to the south of Bungay Road, Poringland is submitted for consideration as an allocation within the emerging GNLP (please see the submitted site location plan) for a Use Class C2 facility including a care home and extra care bungalows. Please note, the site has previously been submitted for consideration for the development of 40 residential dwellings. This was before our client’s involvement. The site is located, as shown on the appended site location plan, to the south east of the village, on the B1332/Bungay Road, which runs from Norwich to Bungay. The existing site use comprises two detached dwellings, garden outbuildings and garages and a 25 bed care home run by the Applicant (Cresta Lodge Care Home). To the rear of the properties are horse paddocks with a stable block. The site is 2.66ha in size.

The existing Cresta Lodge home is located in a bungalow on site that has been extended over the years. The home enjoys almost 100% occupancy throughout the year; however, the building is now becoming unfit for the future with small bedrooms, some without en-suites, small bathrooms and limited communal and social space. There is therefore a need to redevelop the home with a more modern facility in order to provide future residents with the necessary quality of accommodation our elderly population deserve. To do nothing here is not an option because the accommodation would become increasingly challenged and the quality of life for residents would inevitably diminish. If no further development took place on site there would be a further 25 bed reduction in care home accommodation in South Norfolk and the GNLP area.

The proposals will be designed to respect the existing character of this part of Poringland and make a positive contribution to the built environment in this location. With appropriate landscape mitigation, the adverse impacts on users of the Public Right of Way (PRoW) to the south east of the site could be minimised. The scheme can also provide extensive social, economic and environmental benefits, (see attachment for full content)

The proposals would therefore deliver a sustainable form of development, providing social, economic and environmental benefits in accordance with the overarching principles of the National Planning Policy Framework (NPPF). The site is considered to be appropriate for sustainable development and its development would not result in any harm to interests of acknowledged importance. In accordance with paragraph 35 of the Framework, the regulation 18(c) version of the GNLP (with regard to the provision of specialist accommodation for older people) is not positively prepared (as the local plan does not seek to meet, as a minimum, the need for this type of accommodation) and is not effective. However, as detailed within these representations, measures can be taken by the local planning authorities to ensure that suitable schemes can come forward beyond existing settlement boundaries (subject to being sustainably located with any impacts upon existing character and appearance being appropriately mitigated) and making formal allocations for specialist accommodation within the local plan (including the site to the south of Bungay Road, Poringland).

Comment

Representation ID: 22156

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

The needs of those in institutional accommodation
3.25 The SHMA for Central Norfolk identifies a need for 3,909 people aged 75 or over to be accommodated in residential institutions over the period 2015-36. The 2014 based institutional population projections identify an increase of 2,060 such people within the GNLP area over the period 2015-38 comprising 1,088 in Broadland, 291 in Norwich and 681 in South Norfolk.
3.26 In the period 2015-18, a total of 234 bedspaces in older persons communal establishments were built, including 7 in Broadland, 225 in Norwich and 2 in South Norfolk. This leaves a residual need for 1,826 bedspaces in the period 2018-36, comprising 1,081 in Broadland, 57 in Norwich and 679 in South Norfolk.
3.27 The household projections which inform both the SHMA and the standard method do not include this population and the SHMA correctly recognises that in the absence of 1,826 bedspaces in communal establishments the population who would have occupied these will remain in the dwelling stock rather than releasing them as assumed in the projections.3.28 It is therefore apparent that there is a need for 1,826 bedspaces in communal establishments in addition to the standard method and that in the absence of such provision the housing requirement will need to increase as fewer dwellings will be released to the market. The number of dwellings that would not be released in the absence of such residential institutions is 987 using the calculation identified in the PPG (63-016a) comprising 584 in Broadland, 33 in Norwich and 369 in South Norfolk.
3.29 It will therefore either be necessary to make provision for the 1,826 bedspaces or increase the housing requirement by 987 homes to meet the objectively assessed needs within the GNLP and to accord with the Vision of the GNLP. This would result in a need for either 43,408 or 43,390 homes or to 42,421 or 42,403 homes and 1,826 bedspaces.

Support

Representation ID: 22166

Received: 16/03/2020

Respondent: Norwich Liberal Democrats

Number of people: 3

We support the Policy addressing the need for homes for all sectors of the community including a variety of homes in terms of tenure and cost. New homes should provide for a good quality of life in mixed and inclusive communities.
We agree the need to provide 33% affordable housing, except in Norwich City Centre where the requirement is at least 28% and the policy requirement for accessible and adaptable housing to provide 20% for major housing development.

Comment

Representation ID: 22172

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Exceeding the minimum housing need
3.12 The standard method also only provides the minimum local housing need, and the PPG (2a-010) identifies that this should be exceeded including in situations where there is a growth strategy or where strategic infrastructure improvements may drive an increase in housing need or where previous assessments of need are significantly greater than the standard method. All three of these situations arise in Greater Norwich.
The City Deal
3.13 Paragraph 13 of the Draft Local Plan identifies that the Greater Norwich City Deal requirements will be met through the Draft Local Plan. As the Greater Norwich City Deal forms a growth strategy which has been agreed with Government, the Local Plan is required to meet the requirements of the City Deal as this forms part of national policy as set out in paragraph 6 of the NPPF.
3.14 The City Deal identifies that strategic infrastructure is needed including to deliver a step change in housing delivery. It sets a target for an average of 3,000 homes per annum in the period 2014-19 and for 37,000 homes to be delivered in the period 2008-26.3.15 MHCLG Live Tables identify that only 10,715 houses were built in the period 2014-19 in addition to the equivalent of 581 homes provided as student and older persons bedspaces. This provides a total of 11,296 or an average of only 2,259 homes per annum. It is therefore apparent that the short-term target of the City Deal has not been met and that accordingly this shortfall of 3,704 homes should be addressed as soon as possible to achieve the objectives of the City Deal. No such short-term uplift to remedy this shortfall is made within the Draft Local Plan contrary to the requirements of national policy in the form of the City Deal.
3.16 In the period 2008-19, the MHCLG Live Tables identify an equivalent of 19,416 housing completions, which means that in order to provide 37,000 homes in the period 2008-26 it will be necessary to deliver the remaining 17,584 in the period2019-26 or an average of 2,512 per annum. However, the housing need identified in emerging Policy 1 of 40,550 homes 1 only provides for an average need of 2,028 homes per annum. The housing need of the Draft Local Plan therefore again does not provide a sufficient number of homes to meet the housing needs identified in the City Deal.
3.17 It is therefore evident that the Draft Local Plan does not meet any of the targets of the City Deal and that it is accordingly not effective, not justified, not positively prepared and inconsistent with national policy.

Comment

Representation ID: 22174

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Accessible and Specialist Housing
5.8 The Policy then proceeds to support the delivery of accessible and specialist housing providing they have good access to local services which is welcomed.
5.9 However, as identified in response to Policy 1 there is a need for 1,826 bedspaces in residential institutions for older people across the plan area which would be best addressed, at least in part, through the identification of specific allocations to meet this need. In the absence of such allocations, the GNLP cannot demonstrate and more importantly may not meet the objectively assessed needs of this population contrary to paragraphs 35a and 61 of the NPPF.
5.10 There is a need for 1,081 bedspaces in Broadland, 57 in Norwich and 679 in South Norfolk over the plan period. In 2018/19, 8 were built in Broadland leaving a residual need for 1,072 and 83 were built in Norwich meaning that there is no residual need in this LPA. In order to ensure that these needs are addressed it would therefore be appropriate to allocate sites in both Broadland and South Norfolk to meet these needs.
5.11 In addition to the need for residential institutions (including care homes and nursing homes) there will also be a need for independent living units including those which offer communal facilities and/or a level of care (such as sheltered housing or extra care) to accommodate older households.
Norfolk County Council has assessed the need for such accommodation in Living Well, July 2018 and identify a need for 3,376 such homes in Broadland, 122 in Norwich and 3,257 in South Norfolk. Owing to the scale of this need, it would again be appropriate to identify specific allocations to ensure that the needs of communities are addressed.
5.13 Any such allocations for residential institutions or independent living units should be primarily within Broadland and South Norfolk where the need arises on sites which have good access to local facilities and to public transport infrastructure.
5.14 The Policy requires proposals for major housing development to provide; “..at least 20% of homes to the Building Regulation M4(2)(1) standard or any successor.”
5.15 This implies that any development of 10 or more dwellings will need to provide upwards of two dwellings that meet the accessibility standard to enable people to stay in their homes longer, however there is no evidence provided that such a high percentage of adaptable dwellings will be required over the life time of the plan. While it is long recognised that many affordable homes are built to such a standard, this is an additional policy requirement that developers are being requested to meet which will have a knock on impact on the cost of new homes and therefore their accessibility in terms of cost to those seeking to enter the housing market.
5.16 It is considered that the requirement for the delivery of adaptable and specialist accommodation should be specific to individual allocations which will ensure that the needs can be met across the GNLP area and that these will be met at appropriate locations in close proximity to services and facilities.

Comment

Representation ID: 22336

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

5. POLICY 5 – HOMES
5.1 Policy 5 identifies that proposals should address the need for homes for all sectors of the community having regard to the latest evidence which is to be supported.
Space Standards
5.2 The Policy requires all housing development to meet the Government’s Nationally Described Space Standard for internal space (NDSS)5.
5.3 NDSS are not currently a mandatory requirement of Building Regulations and therefore should a Council wish to introduce them they are required to accord with the tests of NPPF 2019 paragraph 127f and Footnote 46 which requires the use of the NDSS to be ‘justified’.
5.4 The Councils also need to demonstrate that the costs associated with implementing the NDSS have been subject to whole plan viability appraisal as required by planning practice guidance6.
5.5 The Council’s NDSS Study (August 2019) is attached at Appendix B of the Interim Viability Appraisal (2019). The Councils have not identified harm that may be arising to residents as a result of dwellings not being built to the NDSS. Nor is there any evidence that houses not built to the NDSS are not selling as well as those that are, or that such homes are considered inappropriate by purchasers.
5.6 If the Government considered it appropriate to make the NDSS mandatory, as proposed by draft Policy 5, then this could quickly and easily be introduced through Building Regulation legislation rather than through the Development Plan process.
5.7 Introducing the NDSS in the GNLP will have an impact on the cost of construction of dwellings and therefore on their affordability to consumers, as well as on the density of development that can be achieved at development sites, thereby affecting the efficient use of land. It will also have a knock-on effect on the viability of the GNLP which may translate into impact on the deliverability of dwellings and therefore on the delivery of the emerging plan.
Accessible and Specialist Housing
5.8 The Policy then proceeds to support the delivery of accessible and specialist housing providing they have good access to local services which is welcomed.
5.9 However, as identified in response to Policy 1 there is a need for 1,826 bedspaces in residential institutions for older people across the plan area which would be best addressed, at least in part, through the identification of specific allocations to meet this need. In the absence of such allocations, the GNLP cannot demonstrate and more importantly may not meet the objectively assessed needs of this population contrary to paragraphs 35a and 61 of the NPPF.
5.10 There is a need for 1,081 bedspaces in Broadland, 57 in Norwich and 679 in South Norfolk over the plan period. In 2018/19, 8 were built in Broadland leaving a residual need for 1,072 and 83 were built in Norwich meaning that there is no residual need in this LPA. None were built in South Norfolk leaving a residual need for 679. In order to ensure that these needs are addressed it would therefore be appropriate to allocate sites in both Broadland and South Norfolk to meet these needs.
5.11 In addition to the need for residential institutions (including care homes and nursing homes) there will also be a need for independent living units including those which offer communal facilities and/or a level of care (such as sheltered housing or extra care) to accommodate older households.
5.12 Norfolk County Council has assessed the need for such accommodation in Living Well, July 2018 and identify a need for 3,376 such homes in Broadland, 122 in Norwich and 3,257 in South Norfolk. Owing to the scale of this need, it would again be appropriate to identify specific allocations to ensure that the needs of communities are addressed.
5.13 Any such allocations for residential institutions or independent living units should be primarily within Broadland and South Norfolk where the need arises on sites which have good access to local facilities and to public transport infrastructure. 5.14 The site at Land off Station Road, Hethersett offers a suitable location for such provision and provides sufficient scope to address a significant element of the residual need for bedspaces in a care home and/or sheltered/extra care accommodation within a care village.
5.15 The Policy requires proposals for major housing development to provide;
“...at least 20% of homes to the Building Regulation M4(2)(1) standard or any successor.”
5.16 This implies that any development of 10 or more dwellings will need to provide upwards of two dwellings that meet the accessibility standard to enable people to stay in their homes longer, however there is no evidence provided that such a high percentage of adaptable dwellings will be required over the life time of the plan. While it is long recognised that many affordable homes are built to such a standard, this is an additional policy requirement that developers are being requested to meet which will have a knock on impact on the cost of new homes and therefore their accessibility in terms of cost to those seeking to enter the housing market.
5.17 It is considered that the requirement for the delivery of adaptable and specialist accommodation should be specific to individual allocations which will ensure that the needs can be met across the GNLP area and that these will be met at appropriate locations in close proximity to services and facilities.
Self/Custom-Build
5.18 There does not appear to have been any assessment of the need for self/custombuild housing to justify the requirement in Policy 5 for 5% self/custom-build on sites of 40 or more homes.
5.19 The Councils have not published evidence to justify their policy requirement to self-build plots either with regard to the percentage of plots sought or the size of site from which they are to be sought. As written sites of 40 or more homes will be required to provide at least two plots as self/custom build.
5.20 Notwithstanding the above, concern is expressed that the policy as written is not adequately evidenced. The self-build register of each Council is not publicly available to validate the policy approach being pursued. Generally, many of those seeking to build their own homes wish to do so on plots in rural areas or villages, not in urban locations, therefore there is no certainty over the delivery of the policy approach being proposed.
5.21 Therefore, it is considered that the requirement for the delivery of self-build plots should be specific to individual allocations to ensure that the needs will be met across the GNLP area and that these will be met at locations and at scales which are likely to be attractive to the self-build market. In addition, the policy could be expanded to allow self-build schemes to come forward where they are well related to settlement boundaries and have access to a range of services and facilities.

Comment

Representation ID: 22373

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

5. POLICY 5 – HOMES
5.1 Policy 5 identifies that proposals should address the need for homes for all sectors of the community having regard to the latest evidence which is to be supported.
Space Standards
5.2 The Policy requires all housing development to meet the Government’s Nationally Described Space Standard for internal space (NDSS)5.
5.3 NDSS are not currently a mandatory requirement of Building Regulations and therefore should a Council wish to introduce them they are required to accord with the tests of NPPF 2019 paragraph 127f and Footnote 46 which requires the use of the NDSS to be ‘justified’.
5.4 The Councils also need to demonstrate that the costs associated with implementing the NDSS have been subject to whole plan viability appraisal as required by planning practice guidance6.
5.5 The Council’s NDSS Study (August 2019) is attached at Appendix B of the Interim Viability Appraisal (2019). The Councils have not identified harm that may be arising to residents as a result of dwellings not being built to the NDSS. Nor is there any evidence that houses not built to the NDSS are not selling as well as those that are, or that such homes are considered inappropriate by purchasers.
5.6 If the Government considered it appropriate to make the NDSS mandatory, as proposed by draft Policy 5, then this could quickly and easily be introduced through Building Regulation legislation rather than through the Development Plan process.
5.7 Introducing the NDSS in the GNLP will have an impact on the cost of construction of dwellings and therefore on their affordability to consumers, as well as on the density of development that can be achieved at development sites, thereby affecting the efficient use of land. It will also have a knock-on effect on the viability of the GNLP which may translate into impact on the deliverability of dwellings and therefore on the delivery of the emerging plan.
Accessible and Specialist Housing
5.8 The Policy then proceeds to support the delivery of accessible and specialist housing providing they have good access to local services which is welcomed.
5.9 However, as identified in response to Policy 1 there is a need for 1,826 bedspaces in residential institutions for older people across the plan area which would be best addressed, at least in part, through the identification of specific allocations to meet this need. In the absence of such allocations, the GNLP cannot demonstrate and more importantly may not meet the objectively assessed needs of this population contrary to paragraphs 35a and 61 of the NPPF.
5.10 There is a need for 1,081 bedspaces in Broadland, 57 in Norwich and 679 in South Norfolk over the plan period. In 2018/19, 8 were built in Broadland leaving a residual need for 1,072 and 83 were built in Norwich meaning that there is no residual need in this LPA. In order to ensure that these needs are addressed it would therefore be appropriate to allocate sites in both Broadland and South Norfolk to meet these needs.
5.11 In addition to the need for residential institutions (including care homes and nursing homes) there will also be a need for independent living units including those which offer communal facilities and/or a level of care (such as sheltered housing or extra care) to accommodate older households.
5.12 Norfolk County Council has assessed the need for such accommodation in Living Well, July 2018 and identify a need for 3,376 such homes in Broadland, 122 in Norwich and 3,257 in South Norfolk. Owing to the scale of this need, it would again be appropriate to identify specific allocations to ensure that the needs of communities are addressed.
5.13 Any such allocations for residential institutions or independent living units should be primarily within Broadland and South Norfolk where the need arises on sites which have good access to local facilities and to public transport infrastructure.
5.14 The Policy requires proposals for major housing development to provide; “..at least 20% of homes to the Building Regulation M4(2)(1) standard or any successor.”
5.15 This implies that any development of 10 or more dwellings will need to provide upwards of two dwellings that meet the accessibility standard to enable people to stay in their homes longer, however there is no evidence provided that such a high percentage of adaptable dwellings will be required over the life time of the plan. While it is long recognised that many affordable homes are built to such a standard, this is an additional policy requirement that developers are being requested to meet which will have a knock on impact on the cost of new homes and therefore their accessibility in terms of cost to those seeking to enter the housing market.
5.16 It is considered that the requirement for the delivery of adaptable and specialist accommodation should be specific to individual allocations which will ensure that the needs can be met across the GNLP area and that these will be met at appropriate locations in close proximity to services and facilities.
Self/Custom-Build
5.17 There does not appear to have been any assessment of the need for self/custombuild housing to justify the requirement in Policy 5 for 5% self/custom-build on sites of 40 or more homes.
5.18 The Councils have not published evidence to justify their policy requirement to self-build plots either with regard to the percentage of plots sought or the size of site from which they are to be sought. As written sites of 40 or more homes will be required to provide at least two plots as self/custom build.
5.19 Pigeon are supportive of providing self-build plots and their proposals at Diss allow for such development. Indeed, the Diss site allows for a discrete area of 10 self-build plots allowing for mutual support amongst the self-build community and bespoke design solutions to come forward.
5.20 Notwithstanding the above, concern is expressed that the policy as written is not adequately evidenced. The self-build register of each Council is not publicly available to validate the policy approach being pursued. Generally, many of those seeking to build their own homes wish to do so on plots in rural areas or villages, not in urban locations, therefore there is no certainty over the delivery of the policy approach being proposed. 5.21 Therefore, it is considered that the requirement for the delivery of self-build plots should be specific to individual allocations to ensure that the needs will be met across the GNLP area and that these will be met at locations and at scales which are likely to be attractive to the self-build market. As such, provision for approximately 10 self-build plots is made as part of the proposal on land to the east of Walcot Green Lane. In addition, the policy could be expanded to allow self-build schemes to come forward where they are well related to settlement boundaries and have access to a range of services and facilities.

Comment

Representation ID: 22434

Received: 16/03/2020

Respondent: Gladman Developments

Question 29: Accessible and Specialist Housing 6.2.1 Policy 5 relates to the provision of accessible and specialist housing to meet the needs of older people, disabled people and vulnerable people with specific housing needs. Gladman is supportive of a policy in relation to this type of housing provision.
6.2.2 The provision of specialist housing to meet the needs of older people is of increasing importance and the Councils need to ensure that this is reflected through a positive policy approach within the GNLP. The Councils need a robust understanding of the scale of this type of need across the plan area.
6.2.3 Specialist housing with care for older people is a type of housing which provides choice to adults with varying care needs and enables them to live as independently as possible in their own selfcontained homes, where people are able to access high quality, flexible support and care services on site to suit their individual needs (including dementia care). Such schemes differ from traditional sheltered/retirement accommodation schemes and should provide internally accessible communal facilities including a residents’ lounge, library, dining room, guest suite, quiet lounge, IT suite, assisted bathroom, internal buggy store and changing facilities, reception and care manager’s office and staff facilities.
6.2.4 Policy 5 also relates to the Building Regulation M4(2) ‘accessible and adaptable dwellings’ and requires that 20% of housing should be built to this standard. 6.2.5 With regards to the provision of accessible and adaptable homes, Gladman refers to the PPG which provides additional guidance on the use of these optional standards. The Councils would need to ensure that any such policy in the GNLP is in line with the guidance and that the justification and specific details of the policy take account of the various factors that the PPG refers to:
“Based on their housing needs assessment and other available dataset it will be for the local planning authority to set out how they intend to approach demonstrating the need for Requirement M4(2) (accessible and adaptable dwellings), and/or M4(3) (wheelchair user dwellings), of the Buildings Regulations. There is a wide range of published official statistics and factors which local planning authorities can consider and take into account, including:
 The likely future need for housing for older and disabled people (including wheelchair user dwellings).
 Size, location, type and quality of dwellings needed to meet specifically evidenced needs (for example retirement homes, sheltered homes or care homes).
 The accessibility and adaptability of existing housing stock.
 How needs vary across different housing tenures.
 The overall impact on viability.” (ID 56-007-20150327)
6.2.6 In order to be able to include specific requirements in relation to M4(2) and M4(3) the Councils will need to be able to robustly justify the inclusion and demonstrate that consideration has been given to these requirements within the viability study. The provision of M4(3) wheelchair user dwellings is far more onerous in terms of size requirement therefore it is crucial that the implications of any proposed policy requirement have been properly considered.
6.2.7 With regards to M4(3) Gladman refers again to the PPG which states:
“Part M of the Building Regulations sets a distinction between wheelchair accessible (a home readily useable by a wheelchair user at the point of completion) and wheelchair adaptable (a home that can be easily adapted to meet the needs of a household including wheelchair users) dwellings.
Local Plan policies for wheelchair accessible homes should be applied only to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling.” (ID 56-009020150327)

Support

Representation ID: 22638

Received: 13/03/2020

Respondent: M Scott Properties Ltd

Number of people: 2

Agent: Bidwells

Support, with comments
The approach to the provision of accessible and specialist housing is supported. However, the policy should recognise that in identifying the need for accessible and specialist housing consideration will be given to the demographics of the area. For example, due to an assessment of the demographics within a certain area, specific demands for a type of accommodation, such as bungalows, may be identified and included within a planning application.

Support

Representation ID: 22679

Received: 16/03/2020

Respondent: Mrs Nicole Wright

Policy 5: Homes

We support this policy except for the part on Self/ Custom- Build Homes

This part of the policy does not address the real need to respond to the demand and choice of bespoke homes in the locations where they are needed.

It does not show a positive, sound and justified approach in the spirit of the NPPF. (Paragraph 16 of the NPPF)

An approach more akin to the Breckland strategy and consistent with the NPPF would be more appropriate.

Paragraph 251 of the Draft GNLP states that: “In line with the Right to Build and the NPPF, self and custom-build housing delivery is promoted through the GNLP on a range of sites. This policy sets a requirement for larger sites to provide self and custom-build plots. The thresholds have been set to ensure that plots are provided across Greater Norwich. Policies 7.4 and 7.5 also promote self and custom-build on smaller scale windfall sites. Overall, this comprehensive approach will both increase the supply of housing in urban and rural areas and provide opportunities for small and medium enterprises to build houses, as well as for self-build.”

However, Draft Policy 7.4 provides no guidance or criteria in relation to self-build and custom housebuilding.

Draft Policy 7.5 needs to allow for consideration of new self/custom-built homes being adjacent to what it describes as “a recognisable group of dwellings”. Please refer to the new Breckland Local Plan (adopted November 2019)



(For refrence:
Policy HOU 05 of the Breckland Local Plan (adopted November 2019)

Policy HOU 05 - Small Villages and Hamlets Outside of Settlement Boundaries
Development in smaller villages and hamlets outside of defined settlement boundaries will be limited, apart from where it would comply with other policies within the development plan* and if all of the following criteria are satisfied:
1. The development comprises of sensitive infilling and rounding off of a cluster of dwellings with access to an existing highway;
2. It is of an appropriate scale and design to the settlement;
3. The design contributes to enhancing the historic nature and
4. connectivity of communities; and
5. The proposal does not harm or undermine a visually important gap that
6. contributes to the character and distinctiveness of the rural scene.
Opportunities for self-build dwellings which meet the criteria set out above will be supported.
Farmsteads and sporadic small scale groups of dwellings are considered as lying in the open countryside and are not classed as small villages and hamlets. These, and isolated locations in the countryside, are unlikely to be considered acceptable.)

The GNLP Homes Objective is defined in the Draft Plan - To enable delivery of high-quality homes of the right density, size, mix and tenure to meet people's needs throughout their lives and to make efficient use of land.

We support this objective

However, the Monitoring Framework, Indicator Code GNLP 39 and indicator demonstrates the shortcomings of this Draft Policy in identifying the sole indicator for monitoring custom housebuilding as:
‘Percentages of sites of 40 dwellings or more (excluding flats) where 5% of plots are provided for custom build.’

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.

Object

Representation ID: 22976

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Pegasus Planning Group

As with the proposed requirements for self-build and space standards our client has serious concerns about the impact that requirements for accessible specialist housing will have on the viability of developments. The proposals for major housing development to provide at least 20% of homes to the Building Regulation M4(2)[1] will add additional costs to housing developments, which in some instances may be unviable with a policy compliant percentage of affordable housing. Therefore, the wording of Policy 5 needs amending to allow for scenarios when it may not be possible to achieve the 20% requirement where viability issues are a material consideration.

Comment

Representation ID: 23046

Received: 16/03/2020

Respondent: Hingham Town Council

Having a policy specifically relating to specialist housing in particular to that of older peoples accommodation does not take into account or directly address the needs of older people generally, who reside within general accommodation within developments, for instances people that may wish to downsize from a house to a bungalow, it does not take into account that these people will grow older while in their home and may have greater needs as they age. Therefore ALL development should address the need for residents to have good access to services within the community, and infrastructure within the community be improved sufficiently to be able to provide this, for example adequate footways and pedestrian priority crossing points.

Comment

Representation ID: 23171

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Accessible and Specialist Housing
6.8 The Policy then proceeds to support the delivery of accessible and specialist housing providing they have good access to local services which is welcomed.
6.9 However, as identified in response to Policy 1 there is a need for 1,826 bedspaces in residential institutions for older people across the plan area which would be best addressed, at least in part, through the identification of specific allocations to meet this need. In the absence of such allocations, the GNLP cannot demonstrate and more importantly may not meet the objectively assessed needs of this population contrary to paragraphs 35a and 61 of the NPPF.
6.10 There is a need for 1,081 bedspaces in Broadland, 57 in Norwich and 679 in South Norfolk over the plan period. In 2018/19, 8 were built in Broadland leaving a residual need for 1,072 and 83 were built in Norwich meaning that there is no residual need in this LPA. In order to ensure that these needs are addressed it would therefore be appropriate to allocate sites in both Broadland and South Norfolk to meet these needs.
6.11 In addition to the need for residential institutions (including care homes and nursing homes) there will also be a need for independent living units including those which offer communal facilities and/or a level of care (such as sheltered housing or extra care) to accommodate older households.
6.12 Norfolk County Council has assessed the need for such accommodation in Living Well, July 2018 and identify a need for 3,376 such homes in Broadland, 122 in Norwich and 3,257 in South Norfolk. Owing to the scale of this need, it would again be appropriate to identify specific allocations to ensure that the needs of communities are addressed.
6.13 Any such allocations for residential institutions or independent living units should be primarily within Broadland and South Norfolk where the need arises on sites which have good access to local facilities and to public transport infrastructure.
6.14 The Policy requires proposals for major housing development to provide;
“..at least 20% of homes to the Building Regulation M4(2)(1) standard or any successor.”
6.15 This implies that any development of 10 or more dwellings will need to provide upwards of two dwellings that meet the accessibility standard to enable people to stay in their homes longer, however there is no evidence provided that such a high percentage of adaptable dwellings will be required over the life time of the plan. While it is long recognised that many affordable homes are built to such a standard, this is an additional policy requirement that developers are being requested to meet which will have a knock on impact on the cost of new homes and therefore their accessibility in terms of cost to those seeking to enter the housing market.
6.16 It is considered that the requirement for the delivery of adaptable and specialist accommodation should be specific to individual allocations which will ensure that the needs can be met across the GNLP area and that these will be met at appropriate locations in close proximity to services and facilities.

Support

Representation ID: 23196

Received: 16/03/2020

Respondent: Orbit Homes

Agent: Armstrong Rigg Planning

Policy 5 requires at least 20% of homes on major developments to be built to M4(2) accessibility standards. Orbit Homes considers this requirement to be reasonable based on the need for such dwellings in the local population.