Publication Plan April 2024

Object

Representation ID: 5799

Received: 29/05/2024

Respondent: McCarthy Stone

Agent: Miss Natasha Styes

Legally compliant? No

Sound? No

Duty to co-operate? No

As a minimum flexibility should be provided within the plan for the older persons typology for the plan to be justified and consistent with its own evidence. The following could be introduced to paragraph9 of the policy 'Such an exceptional circumstance includes the provision of specialist housing for older people where viability is found to be more marginal'. In addition the Viability Assessment should be re-run, including the older persons housing typology properly, using the correct assumptions in line with the RHG briefing note. The outcomes of this update should be incorporated into the plan. See full rep for details.

Comment

Representation ID: 5800

Received: 29/05/2024

Respondent: McCarthy Stone

Agent: Miss Natasha Styes

Policy HC4: Homes for older people and others with special housing requirements
Policy HC5: Specialist Housing
Although we are supportive of policies HC4 and HC5 we feel that the policies could be combined so that the plan is clearly written in line with paragraph 16 of the NPPF.

Comment

Representation ID: 5801

Received: 29/05/2024

Respondent: McCarthy Stone

Agent: Miss Natasha Styes

Policy HC4: Homes for older people and others with special housing requirements
Policy HC5: Specialist Housing
Although we are supportive of policies HC4 and HC5 we feel that the policies could be combined so that the plan is clearly written in line with paragraph 16 of the NPPF.

Object

Representation ID: 5803

Received: 29/05/2024

Respondent: McCarthy Stone

Agent: Miss Natasha Styes

Legally compliant? No

Sound? No

Duty to co-operate? No

Recommendation:
For the plan to be in line with national policy and effective Policy HC14 should be amended so it reads as follows:

Proposals for major residential developments must be assessed against the capacity of existing healthcare facilities through........................

In addition, the following wording should be added to the policy to recognise the health benefits of older persons housing.

'Specialist Housing for older people has a number of health benefits and proposals for such schemes will not be required to submit a Health Impact Assessment '

See attached representation.

Object

Representation ID: 5804

Received: 29/05/2024

Respondent: McCarthy Stone

Agent: Miss Natasha Styes

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy HC17 introduces s number of open space requirements for new residential development. The council should note that open space needs of older people are much less than for mainstream housing. For older people the quality of open space either on site or easily accessible for passive recreation is much more important than formal open space. The Local Plan, if the council decide to set a minimum size for residential outdoor amenity open space, should provide an exemption for older people’s housing schemes but consider the quality and function of the amenity space instead.

Object

Representation ID: 5806

Received: 29/05/2024

Respondent: McCarthy Stone

Agent: Miss Natasha Styes

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy NB2: Biodiversity
We note that policy NB2 Biodiversity seeks to secure the habitat gain into perpetuity rather than for the statutory 30 years. The Council should reconsider the additional wording it proposes with regard to BNG to ensure the policy is in line with the guidance and statutory instruments that the government have recently updated / published regarding statutory Biodiversity Net Gain.

Object

Representation ID: 5810

Received: 29/05/2024

Respondent: McCarthy Stone

Agent: Miss Natasha Styes

Legally compliant? No

Sound? No

Duty to co-operate? No

Whilst Council’s commitment to meeting both its and the UK Government’s target of net zero carbon emissions is commendable, it appears that the Council is going to achieve this through having mandatory carbon and climate standards from adoption of the plan that go beyond government targets. It is our view that any requirement should be ‘stepped’ in line with Government targets and the proposed changes to the building regulations.

This approach is confirmed within the Ministerial Statement (statement no : Statement UIN HCWS123) released on 13th December 2023.