UPSVLP 2561
While the plan identifies housing for older person as a need this is not quantified by the plan or differentiated within Policy DEV1.
We would encourage a standalone policy that encourages the provision of specialist older persons? housing and acknowledges the already identified need for such accommodation. While we appreciate that no one planning approach will be appropriate for all areas, an example policy is provided that, we hope, will provide a useful reference for the Council: ?The Council will encourage the provision of specialist housing for older people across all tenures in sustainable locations. The Council aims to ensure that older people are able to secure and sustain independence in a home appropriate to their circumstances by providing appropriate housing choice, particularly retirement housing and Extra Care Housing/Housing with Care. The Council will, through the identification of sites, allowing for windfall developments, and / or granting of planning consents in sustainable locations, provide for the development of retirement accommodation, residential care homes, close care, Extra Care and assisted care housing and Continuing Care Retirement Communities.?
In assessing the Local Plan Viability Assessment we note that no viability appraisals were undertaken for specialist older persons? housing typologies ? namely Sheltered Housing and Extra Care accommodation. This is contrary to both best practice and the typology approach detailed in Paragraph: 004 (Reference ID: 10-004-20190509) of the PPG.
We are strongly of the view that it would be more appropriate to set a nil affordable housing target for sheltered and extra care development, at the very least in urban areas.
Mindful of the guidance in the PPG that is the responsibility of site owners and developers to engage in the Plan making process, McCarthy Stone and Churchill Retirement Living have undertaken financial viability appraisals for sheltered and extra care older persons? housing typologies in this report to encourage dialogue with the Council. All the scenarios tested result in substantial negative residual land value. The extent of the deficit is such that the existing framework of planning obligations places an unacceptable burden on specialist older persons? housing in the area. This is an inappropriate method for setting policy and creates unrealistic expectations for Council Officers and Council Members. It is wholly contrary to Paragraph 57 of the NPPF. The Local Plan is considered to be unsound on the grounds the affordable housing targets are not justified, positively prepared or effective. The PPG however advises that ?Different (affordable housing) requirements may be set for different types or location of site or types of development? (Paragraph: 001 Reference ID: 10-001-20190509). A nil affordable housing rate could facilitate a step-change in the delivery of older person?s housing in the Borough, helping to meet the diverse housing needs of the elderly. The benefits of specialist older persons? housing extend beyond the delivery of planning obligations as these forms of development contribute to the regeneration of town centres and assist Council?s by making savings on health and social care.
While we support measures to move development towards ?net zero? carbon emissions, the costs of energy saving measures will need to be robustly and proportionately accounted for in the Local Plan Viability Assessment and balanced against the planning obligations regime accordingly. Our buildings incorporate a ?fabric first? approach and are highly efficient in their construction techniques, which achieve significant reductions in energy output, often without the requirement for ?bolt on? solutions.
We would broadly agree with the requirements relating to fabric efficiency renewable energy and heating and cooling which are consistent with national policy. The Council?s commitment to meeting both its target of reducing carbon is commendable. Encouraging measures to reduce the energy usage in new development to be a pragmatic approach. We would respectfully remind the Council that the PPG states that: ?The role for viability assessment is primarily at the plan making stage. Viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the plan? (Paragraph: 002 Reference ID: 10-002-20190509).
Specialist older person?s housing delivery should be monitored by the council and should be measured by both tenure and type to ensure the needs of Warrington?s ageing population are both planned for and met over the plan period. This is required under paragraph 1 of the PPG Housing for Older and Disabled people. It is clear from the documentation included there is a critical need for specialist accommodation in the area that needs to be addressed through the Local Plan and, unless properly planned for, there is likely to be a serious shortfall in specialist accommodation for the older population, which will have a knock-on effect in meeting the housing needs of the whole Warrington area and wider policy objectives.