Cheltenham Plan Pre-Submission consultation

Document Section Pre-Submission Cheltenham Plan Housing mix and standards (no name) [View all comments on this section]
Comment ID 1143
Respondent Gladman (Nicole Penfold) [View all comments by this respondent]
Response Date 09 Apr 2018
Do you consider the document is Legally Compliant? Yes
Do you consider the document is Sound? No

1.1             Policy HM2: Elderly Care Provision

  • Policy HM2 relates to housing choice for older people. Policy H2 outlines the Council will support proposals that:
  • Help to meet an identified need;
  • Demonstrate that they would not have a harmful impact on character and amenities in the surrounding area; and
  • Are accessible to local shops and easily accessible by public transport.
    • The Policy goes on to outline that “A proportion of a scheme providing elderly care, defined by either C2 or C3 Use Class, or for supported or special needs housing, will normally be required to contribute to affordable housing need.” Gladman object to the policy requiring an element of affordable housing on these types of schemes as they are already providing a type of housing to meet a specialist need. It is therefore unreasonable to require the provision of affordable units on top of this.
    • The provision of specialist housing to meet the needs of older people is of increasing importance and the Council need to ensure that this is reflected through a positive policy approach within the Local Plan.
    • Specialist housing with care for older people is a type of housing which provides choice to adults with varying care needs and enables them to live as independently as possible in their own self-contained homes, where people are able to access high quality, flexible support and care services on site to suit their individual needs (including dementia care). Such schemes differ from traditional sheltered/retirement accommodation schemes and should provide internally accessible communal facilities including residents’ lounge, library, dining room, guest suite, quiet lounge, IT suite, assisted bathroom, internal buggy store and changing facilities, reception and care managers office and staff facilities.
    • Given the existing evidence in relation to ageing populations, and the national strategy in relation to housing for older people, Gladman recommend that the Local Plan should include a more specific policy in relation to the provision of specialist accommodation for older people. The following text provides an example of the type of policy which could be included in the new Local Plan:

“The provision of purpose built and/or specialist accommodation with care for older people in sustainable locations will be supported. Apartments should be restricted for occupation by only those with care needs, include minimum compulsory care packages, should also include age restrictions and an extensive range of communal facilities.

Schemes are expected to be promoted in partnership with an onsite 24/7 care provider to safeguard the delivery of care and support to residents.

Such schemes fall wholly within the auspices of C2 use, meet an otherwise unmet need for specialist accommodation for older people, deliver care and communal facilities and will not therefore be required to contribute towards affordable housing.”

1.2             Amendments to Principal Urban Area

  • The Principal Urban Area (PUA) marks the limits of Cheltenham Town and divides the built up area from the rural area. This is effectively a settlement boundary by another name. Paragraph 12.47 outlines that “Boundaries have been redrawn to include sites where land has been developed or planning permission has been granted for development over the last few years.” Gladman support the fact that the boundaries have been updated to reflect commitments.
  • Notwithstanding this, Gladman object to the use of settlement boundaries to arbitrarily restrict otherwise sustainable development from coming forwards. The Framework is clear that development which is sustainable should go ahead. The use of settlement limits to arbitrarily restrict suitable development from coming forward on the edge of settlements would not accord with the positive approach to growth required by the Framework.
  • Gladman recommend that in order to be found sound a more permissive policy approach should be taken in relation to development outside of the PUA, and that a criteria based approach would be appropriate. Such an approach would allow the plan to protect itself against unsustainable development at the same time as being open and flexible to additional development opportunities which come forwards to meet identified needs.
  • Gladman refer to the submission version of the Harborough Local Plan, specifically policy GD2, this states:

“In addition to the sites allocated by this Local Plan and neighbourhood plans, development within or contiguous with the existing or committed built up area of Market Harborough, Key Centres, the Leicestsershire Principal Urban Area (PUA), Rural Centres and Selected Villages will be permitted where….”

A series of criteria then follow.

  • Clearly this type of policy would need to reflect the local circumstances of Cheltenham, but the example above is of a Local Planning Authority taking a proactive approach to guiding development, and ensuring they can meet their housing targets and can plan for approaches if and when problems arise over the course of the plan with the delivery of allocated sites. Gladman believe it is prudent for the Cheltenham Plan to include a policy similar to the example above rather than the restrictive approach currently proposed to all development outside of the PUA.
Do you consider it necessary to participate at the Examination in Public? Yes