MM35.

As modified, Pigeon’s view is that the Policy remains too rigid in its requirements and does not provide the level of flexibility or encouragement that is necessary to address the growing needs in the two Districts. The precise amount and type of specialist accommodation required will depend on a range of factors including the choices of individual people and households.

Pigeon therefore considers that the Council should modify the wording of the policy to be more flexible and positive in the way it will assess applications for this type of development. The policy should therefore allow for the provision of such facilities on the edge of, but also including the outside of, the settlement boundaries of sustainable settlements, where the latter would not give rise to unacceptable impacts and would otherwise comply with other policies in the Plan, taken as a whole. Pigeon suggests that the wording to Policy LP06 is amended to provide for this flexibility in the following way:

1a) Where possible, proposals should be located within a settlement boundary and where there is good access to services and facilities, especially health services and public transport;
1e) Where there is an identified specialist housing need, supported by up-to-date housing needs information, proposals for supported and special needs housing, located outside of, but adjacent to, existing settlement boundaries, will also be supported, where the scheme is well connected to the existing settlement, has good access to other services and facilities, and is proportionate in size to it.

Pigeon welcomes the modifications to this policy as it removes a considerable amount of the prescriptive wording that was found in the former LP07 policy.

Notwithstanding this, Pigeon do remain concerned that the policy continues to not contain a proactive strategy to manage growth and meet the changing needs of residents over their lifetime or as their circumstances change. In Pigeon’s view, this will be best achieved by supporting a range of housing products to meet different needs and maximise choice. These will include Independent / Retirement Living, Extra Care housing, care and nursing homes and affordable housing, as well as securing market housing designed to be accessible for a range of people.

As time passes since the original evidence base was prepared, Pigeon would question whether it is appropriate for the Councils to provide an update to the original SHMA (2017) so that the Policy can address the level of up-to-date need and recognise the significant differences within the specialist housing sector in respect of use class and the level of care and support provided.

The Plan could be made sound by allocating sites for care homes and care or retirement
accommodation.

Older Persons Housing
• Recognised as one of the key social issues in the plan (page 10)
• Very significant ageing population – recognition of the fact that there will be different demands on housing, infrastructure, services and facilities.
• Also recognised in the ‘vision’ (page 14) – reflects how centrally important this is as an issue
• Particularly surprising that there is no policy when you have policy LP06 directed at supported and special needs housing
The emerging Part 1 Plan Policy LP06: Special Needs Housing at 13.17 confirms that the Council acknowledge that there is a significant need for:
“1,005 additional specialist units” comprising sheltered, enhanced sheltered and extra care and “1,004 Care Home bed spaces”.
The emerging Plan LP06, whilst confirming “support” for Care Home bed spaces and retirement accommodation does not propose any allocations nor to make provision (for example) for an exception based policy to accommodate the need for Care Home bed spaces or retirement accommodation.
National Planning Policy Framework
The NPPF is an important material consideration of very significant weight. It states that:
“To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.” (NPPF para60)
“…, the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies (including, but not limited to, those who require affordable housing, families with children, older people, students, people with disabilities, service families, travellers, people who rent their homes and people wishing to commission or build their own homes).” (NPPF para 62) (emphasis added)
The NPPF glossary sets out the definition of ‘older people’ as those who are:
…over or approaching retirement age, including the active, newly-retired through to the very frail elderly; and whose housing needs can encompass accessible, adaptable general needs housing through to the full range of retirement and specialised housing for those with support or care needs.” (NPPF Glossary)
Planning Practice Guidance
Again, this is a material consideration of very significant weight given its role in ensuring
that the policies of the Framework are achieved.
Housing for older and disabled people
The PPG sets out the different types of specialist housing for older people (ID: 63-010- 20190626), ranging from age-restricted retirement housing to residential care and nursing homes. Specific guidance in the PPG is given on assessing the housing needs of older people, which highlights the importance of planning for these needs:
“The need to provide housing for older people is critical.” (emphasis added)
In the PPG section on Housing for older and disabled people, guidance is also given on
decision-taking:
“What factors should decision makers consider when assessing planning applications for specialist housing for older people? Decision makers should consider the location and viability of a development when assessing planning applications for specialist housing for older people. Local planning authorities can encourage the development of more affordable models and make use of products like shared ownership. Where there is an identified unmet need for specialist housing, local authorities should take a positive approach to schemes that propose to address this need.” (PPG ID: 63-016-20190626) (emphasis added).
The Plan could be made sound by allocating sites for care homes and care or retirement accommodation.

Amend MM35 as expressed in red below:
Policy LP06 – Mix and type of composition of Housing and Older Person’s, Supported and Special
Needs Housing
1. Proposals for older person’s, supported and special needs housing will be supported where they:
a. Are located within a settlement boundary and where there is good access to services and facilities,
especially health services and public transport;
b. Have access to open space designed to meet the needs of residents;
c. Have a high quality of design that meets the specific needs of the intended occupiers and is
sympathetic to the surrounding townscape and/or landscape; and
d. Meet as a minimum, the requirements for accessible and adaptable dwellings under Part M4(2)
of Building Regulations (or any relevant regulation that supersedes and replaces)

Please find below our
comments, which specifically responds to modifications MM34, MM35, MM36 and AM48.
We support MM34 and MM36 in the deletion of the text of policies LP06, Mix and type of composition
of housing and LP07 Supported and Special Needs Housing and the replacement with proposed main
modification MM35 that combines both policies. We also support AM48 that amends and clarifies
the supporting paragraphs to LP06 / LP07 and specifically expresses the need for older person’s
housing. This is consistent with the requirements of national policy.
However, given the great older person’s housing need identified in AM48 para 13.16 and 13.17 that
makes up around 13% of the total housing requirement expressed within Table 3 of the Local Plan and
amended in MM4, we feel that MM35 should be amended slightly to clarify that the amended policy
LP06 also refers specifically to older person’s housing.
Amend MM35 as expressed in red below:
Policy LP06 – Mix and type of composition of Housing and Older Person’s, Supported and Special
Needs Housing
1. Proposals for older person’s, supported and special needs housing will be supported where they:
a. Are located within a settlement boundary and where there is good access to services and facilities,
especially health services and public transport;
b. Have access to open space designed to meet the needs of residents;
c. Have a high quality of design that meets the specific needs of the intended occupiers and is
sympathetic to the surrounding townscape and/or landscape; and
d. Meet as a minimum, the requirements for accessible and adaptable dwellings under Part M4(2)
of Building Regulations (or any relevant regulation that supersedes and replaces)

Please see attached document.

This is particularly important in the absence of any other provision in the Local Plan to meet the Districts’ considerable needs to provide specialist housing; the SHMA predicts that the over-65 population within the Ipswich Housing Market Area is expected to increase by 57.8% over the Plan period, and identifies a need for 1,369 additional specialist housing units required in Babergh and 1,005 in Mid-Suffolk, not including registered care. It is not clear how much of this need will be met by the committed development that makes up the vast majority of the Plan’s housing supply, but it is assumed that there will be a considerable under-provision. It is therefore vitally important that the Part 1 Plan includes a policy that will assist in delivering this type of accommodation to ensure that, in accordance with the NPPF, the needs of groups with specific housing requirements are properly addressed and met.

We object to the proposed modification to the policy on Supported and Special Needs Housing (formerly LP07, now LP06) as limiting the location of such development to within settlement boundaries is not justified or effective. Such developments are often less financially viable than general needs housing due to requirements, for example, to provide areas of communal space and other considerations. Consequently, they may not be able to compete with general needs housing providers on allocated sites or sites within the settlement boundaries, where land values are high. A similar approach should be taken to that adopted for Community-Led and Rural-Exception Housing in Policy LP07 (formerly LP08), which allows for development on sites that are well-connected to, but not necessarily within the settlement boundary of, an existing settlement.
This is particularly important in the absence of any other provision in the Local Plan to meet the Districts’ considerable needs to provide specialist housing; the SHMA predicts that the over-65 population within the Ipswich Housing Market Area is expected to increase by 57.8% over the Plan period, and identifies a need for 1,369 additional specialist housing units required in Babergh and 1,005 in Mid-Suffolk, not including registered care. It is not clear how much of this need will be met by the committed development that makes up the vast majority of the Plan’s housing supply, but it is assumed that there will be a considerable under-provision. It is therefore vitally important that the Part 1 Plan includes a policy that will assist in delivering this type of accommodation to ensure that, in accordance with the NPPF, the needs of groups with specific housing requirements are properly addressed and met.

MM35: New Policy LP06
SCC largely supports the changes to this policy and considers it sound. In particular, SCC supports the policy which seeks to address issues arising from the County’s ageing population.

Please see attached full document.

1.5. Suggested amendment to new Policy LP06 ‘Supported and Special Needs Housing’:
1. Proposals for supported and special needs housing will be supported where they:
a. Are located within a settlement boundary and where there is good access to services
and facilities, especially health services and public transport;
b. Have access to open space designed to meet the needs of residents;
c. Have a high quality of design that meets the specific needs of the intended occupiers
and is sympathetic to the surrounding townscape and/or landscape; and
d. Meet as a minimum, the requirements for accessible and adaptable dwellings under
Part M4(2) of Building Regulations (or any relevant regulation that supersedes and
replaces).

1.1. New Policy LP06, previously numbered Policy LP07, enables proposals for supported
and special needs housing to be delivered where they comply with specific policy criteria.
General support is given to such a policy however it is suggested that the policy wording
is amended to allow sites to come forward at sustainable locations beyond settlement
boundaries.
1.2. Proposed paragraphs 13.14 to 13.17 of the Joint Local Plan Part 1 cross refer to the
supporting evidence base, particularly the Strategic Housing Market Assessment (2019),
which highlights the significant need for supported and special needs housing across the
two Districts.
1.3. The Council’s supporting evidence, Aspinall Verdi Plan Viability and CIL Study (October
2020) concludes in respect of both previously numbered Policies LP06 and LP07 that
they have high impact on viability (page 5). Typically proposals for such accommodation
are not as financially competitive when considered in comparison at a prime residential
land, as such it is considered that the policy amendment would assist in reducing
competition for sites which is understood to be a contributing factor in preventing
sufficient sites for this use coming forward.
1.4. It is also felt that the removal of reference to within the settlement boundary is particularly
important at present as the settlement boundaries are yet to be formally reviewed and will only do so under Local Plan Part 2.
1.5. Suggested amendment to new Policy LP06 ‘Supported and Special Needs Housing’:
1. Proposals for supported and special needs housing will be supported where they:
a. Are located within a settlement boundary and where there is good access to services
and facilities, especially health services and public transport;
b. Have access to open space designed to meet the needs of residents;
c. Have a high quality of design that meets the specific needs of the intended occupiers
and is sympathetic to the surrounding townscape and/or landscape; and
d. Meet as a minimum, the requirements for accessible and adaptable dwellings under
Part M4(2) of Building Regulations (or any relevant regulation that supersedes and
replaces).

Please see attached full document