Publication Plan April 2024

Object

Representation ID: 6914

Received: 31/05/2024

Respondent: Completelink Ltd

Agent: Zesta Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

No specific requirement is provided for specialist housing and registered care, despite this representing a significant proportion of the overall need.

Details of existing policy requirements can be found in paragraphs 2.5 - 2.15 and contains figures for completed units for extra care.

Comment

Representation ID: 6915

Received: 31/05/2024

Respondent: Completelink Ltd

Agent: Zesta Planning Ltd

The key evidence base is the South Staffordshire Housing Market Assessment Partial Update 2024 and the Homes for Older People and Disabled People Topic Paper April 2024. These predict a significant increase in older people in the district and that the proportion of single older persons households will increase. Table 7.2 indicates 1,198 additional units will be required up to 2041, as a mixture of sheltered/retirement and extra care/supported living units. An additional 153 Registered Care spaces are required. There is clearly an identified need for this type of accommodation.

Object

Representation ID: 6916

Received: 31/05/2024

Respondent: Completelink Ltd

Agent: Zesta Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DS5 does not set out a strategy for meeting the evidenced needs for specialist housing and registered care. The Council’s ‘Homes for Older People and Disabled People Topic Paper’ discusses the ways in which the Publication Plan is responding to the evidenced needs in paragraphs 3.3 and 3.4. Three sites are identified for specialist elderly housing, indicating a very substantial unmet need for specialist housing over the plan period. No clear justification is provided by the Council for their approach of not addressing the need for specialist housing.

Object

Representation ID: 6917

Received: 31/05/2024

Respondent: Completelink Ltd

Agent: Zesta Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Whilst the plan does allocate a range of smaller sites, these are all for general housing with no specific policy allocation for specialist housing. Instead, the plan relies of these sites being delivered in accordance with its ‘housing mix’. It is considered that lower levels of specialist housing will be delivered on the non-strategic sites allocated in Policy SA3. It is clear the Council does not have a realistic plan in place for addressing the substantial need for specialist housing.

Object

Representation ID: 6918

Received: 31/05/2024

Respondent: Completelink Ltd

Agent: Zesta Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

There is no assessment of the potential to allocate sites in Tier 3 or Tier 4 settlements or importantly to expand established existing specialist accommodation sites, such as Prestwood House Care Home & Estate. The conclusion seems to be that older people will automatically seek care provision in their existing village. The Publication Plan does not provide a suitable strategy for meeting the evidenced needs for specialist housing and registered care spaces over the plan period and results in a very substantial unmet need. Whilst some of this would be meet by non-strategic site allocations, it is clear these cannot provide anywhere near the identified shortfall. As such, it is not positively prepared and not consistent with national policy. Proposed amendments to the policy to make it ‘sound’ can be found in paragraphs 2.42 – 2.48 of the full representation.

Object

Representation ID: 6919

Received: 31/05/2024

Respondent: Completelink Ltd

Agent: Zesta Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

It is clear there will be a very substantial unmet need for registered care, and that some of this need would have to be met at sites in the Green Belt. We consider policy DS1 unsound as it does not remove enough land from the Green Belt to accommodate the evidenced needs for specialist housing and care accommodation. It would not be positively prepared in that it does not facilitate a development strategy which meets the area’s evidenced needs. It would not be consistent with national policy as it does not do enough to address the needs for older people.

Comment

Representation ID: 6920

Received: 31/05/2024

Respondent: Completelink Ltd

Agent: Zesta Planning Ltd

As an alternative approach for realising opportunity presented by Prestwood House Care Home & Estate to address the unmet needs for specialist housing, it is suggested that a special policy area could be designated around the site, within which proposals for the redevelopment and intensification of the site to provide specialist housing will be supported where they would contribute towards meeting the needs for these types of accommodation. It could then remain in the Green Belt whilst enabling its careful re-intensification. Details of similar approaches can be found in paragraphs 2.54 – 2.68 of the full representation.

Object

Representation ID: 6921

Received: 31/05/2024

Respondent: Completelink Ltd

Agent: Zesta Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Whilst we welcome the strong support given by this policy to proposals for the provision of specialist housing, we consider that it does not go far enough given the substantial unmet need for this type of accommodation. The policy requirements for specialist housing proposals to be well integrated with the settlement and situated in a sustainable location is a concern, we struggle to see how the unmet need could be addressed under this policy approach without involving greenfield development in the Green Belt. HC5 will only act to preclude opportunities coming forward and do little to address unmet need. The policy is not positively prepared or consistent with national policy and needs to take a more positive and flexible approach to meet the tests of soundness (proposed wording in paragraph 2.76 of full representation) .

Object

Representation ID: 6922

Received: 31/05/2024

Respondent: Completelink Ltd

Agent: Zesta Planning Ltd

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Prestwood House Care Home & Estate is an established older people and care home site of nearly 40 years, offering a range of high-quality care services. Site details can be found in paragraphs 3.3 – 3.9 of the full representation. We are promoting Prestwood House Care Home & Estate as an established specialist care accommodation, capable of providing around 140 additional bedroom units. The only significant constraint is its location within the Green Belt. Details on the Green Belt Study and landscape setting for this site are in paragraphs 3.16 – 3.24 of full representation.