Draft Greater Norwich Local Plan – Part 1 The Strategy
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Draft Greater Norwich Local Plan – Part 1 The Strategy
Question 29: Do you support, object or have any comments relating to the approach to accessible and specialist Housing?
Representation ID: 22142
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) 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).
Please see attached for full submission