Publication Plan November 2022

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Object

Publication Plan November 2022

7.13

Representation ID: 4239

Received: 23/12/2022

Respondent: McCarthy Stone

Agent: Miss Natasha Styles

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The older person's housing need identified uses the existing prevalence rate projected forward rather than the national prevalence rate advocated by the SHOP model. If the national figures had been used to try and overcome the shortfall in rather than disregarding it due to comments from stakeholders, the figure would be higher. Instead research should have been undertaken to determine a realistic figure.

The council should also ensure that the additional housing requirement generated from Birmingham also includes an element of older people’s housing to meet the need from Birmingham. This again would increase the requirement for older persons’ housing.

Object

Publication Plan November 2022

Policy HC5: Specialist Housing

Representation ID: 4243

Received: 23/12/2022

Respondent: McCarthy Stone

Agent: Miss Natasha Styles

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

We support policies HC1, 4 and 5 as they attempt to provide a positive framework for the delivery of older persons’ housing in line with the PPG on housing for older and disabled, given our response to other policies we feel that the phrase ‘Development proposals should be consistent with other Local Plan policies’ should be removed from policy HC5 as some exemptions may need to be applied to older person’s housing schemes.

Object

Publication Plan November 2022

Policy HC3: Affordable Housing

Representation ID: 4248

Received: 23/12/2022

Respondent: McCarthy Stone

Agent: Miss Natasha Styles

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

As older peoples’ housing has been found to not be viable with a 30% affordable housing threshold the affordable housing requirement should be amended for such schemes to ensure the Plan is in accordance with national policy and its own evidence.

The Plan should clarify that older people's housing schemes should be exempt from providing first homes and starter homes.

The stage 1 viability study should be updated to ensure up to date values for older person's housing schemes are used to reflect the current market conditions. Thresholds should be reduced or a nil affordable housing requirement introduced where necessary.

Object

Publication Plan November 2022

Policy HC12: Space about dwellings and internal space

Representation ID: 4250

Received: 23/12/2022

Respondent: McCarthy Stone

Agent: Miss Natasha Styles

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The council should note that the open space needs of older people are much less than that presented in the plan. 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 council should therefore acknowledge this within the policy and add amend policy HC12.

Object

Publication Plan November 2022

Policy HC14: Health Infrastructure

Representation ID: 4252

Received: 23/12/2022

Respondent: McCarthy Stone

Agent: Miss Natasha Styles

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

There is a common misconception that older person’s housing places an additional burden on healthcare infrastructure. It produces a large number of benefits which can help to reduce the demands on Health and Social Services and other care facilities. Residents remain in better health, both physically and mentally and essential practitioners can all attend to visit several occupiers at once. This leads to a far more efficient and effective use of public resources.

This is supported by PPG on Housing for Older and Disabled People at Paragraph 001 Reference ID: 63-001-20190626.

Object

Publication Plan November 2022

Policy NB6: Sustainable construction

Representation ID: 4253

Received: 23/12/2022

Respondent: McCarthy Stone

Agent: Miss Natasha Styles

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Currently it appears that the council is going to achieve net zero through having mandatory standards from adoption of the plan that go beyond government targets. However, it is our view that any requirement should be ‘stepped’ in line with Government targets. This is more desirable as there is considerable momentum from Government in preparing enhanced sustainability standards as it is clear the energy efficiency requirements for domestic and non-domestic buildings will increase sharply in the coming years. Aligning the Council’s requirement for carbon neutral development with those of Government would therefore be pragmatic and more achievable.

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