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Policy 3 Environmental Protection and Enhancement
Representation ID: 24428
Received: 22/03/2021
Respondent: Trustees of First Viscount Mackintosh of Halifax and Trustees of CM Watt Residual Trust
Agent: La Ronde Wright
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy 3 is a standard policy that is adopted by most LPA's regarding the need to provide biodiversity enhancements as part of an overall ambition for conserving and enhancing the natural environment. This is a noted sentiment, however reality is that a large number of developments fail to provide meaningful or significant benefits to the natural environment, due to limited opportunities for providing Public Open Space and landscaped areas on site. An updated evidence base is needed and a new approach should be considered, which results in the dedicated allocation of significant amounts of land for enhancements, that can help mitigate carbon emissions and other impacts of development. Looking at the proposed allocations for development, the GNLP proposes a wealth of residential development that ultimately will drain the existing POS provision within the administrative area, and new POS will likely not address the biodiversity implications of development, due to its sporadic, and ad hoc placement within wider developments. As such, it is considered that this blanket approach of stating that net gain will be provided on-site or off-site is unlikely to be effective, and instead a new strategy based on an alternative approach as highlighted by paragraph 35 of the NPPF should be sought. In its current form, the plan is unsound due to this unjustified and ineffective strategy that has not been positively prepared.
Given the dire need for preserving and enhancing the natural environment, it is the view that large amounts of natural land should be allocated to provide Public Open Space, at a suitable scale that would supplement existing development, ensuring the whole Plan provides biodiversity net gains and ecological enhancements. For example, the land at Racecourse Community Park is an existing Parkland that is underused, but would benefit from additional revenue to facilitate a vast program of works to boost the biodiversity and ecological value of the land once the planned interventions along its boundaries take place. Namely, the extension to the Thickthorn Park & Ride and the A47/A11 Highways England link road. The opening up the park to the public alongside with the limited built development proposed at site GNLP0177-B would result in a range of benefits to economic, social and community infrastructure and contribute positively to the natural environment.
The allocation of this essential green infrastructure and the three relatively small sites which would secure its long-term management and maintenance within GNLP0177-B would protect it for present and future generations and reduce the deterioration of the landscape likely to result from the planned interventions along its boundaries.
As can be seen through the recent COVID-19 pandemic, the importance of accessible public open space within close proximity to homes and places of work is vital to maintaining a healthy lifestyle.
Given the existing infrastructure improvements and the adjacent Park and Ride and its planned extension this site could provide not only large-scale community space for the residents of both Hethersett and Cringleford, but would supplement the public open space provision of other allocations and developments nearby.
The GNLP is deficient in housing for the elderly, employment land, and the impact on the environment. See rep summaries for detail.
Object
Publication
Policy 5 Homes
Representation ID: 24429
Received: 22/03/2021
Respondent: Trustees of First Viscount Mackintosh of Halifax and Trustees of CM Watt Residual Trust
Agent: La Ronde Wright
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
It is considered that Policy 5, and the handling of elderly accommodation has not been positively prepared, is unjustified, ineffective, and inconsistent with national policy due to the failure to secure a suitable strategy to deliver quality elderly accommodation in sufficient numbers to address an identified need.
Paragraph 275 of the Strategy states “an increasing proportion of the population is over 65 or disabled, increasing the demand for supported accommodation such as sheltered housing, extra care housing and care homes, residential care and supported living. The local plan seeks to assist County’s aim to reduce residential care home and nursing home dependency and support people to remain more independent in their own homes or in supported housing.” There is an ever expanding need for older persons' accommodation. In fact, we applaud the efforts of the Greater Norwich Local Plan in trying to reduce the reliance in the traditional sense of residential care homes. Many individuals have seen how traumatic it is moving loved relatives in the later years of their life to such institutions which are often unfamiliar surroundings which exacerbate deteriorating health conditions.
Paragraph 276 of the Strategy states that “the policy therefore supports the provision of housing to meet the needs of older people and others with support needs, including sheltered housing, residential/nursing care accommodation and extra care housing. Norfolk County Council strategy identifies the need for 2842 additional extra care units by 2028. County wide evidence has identified the need for 3857 specialist retirement units (sheltered, age restricted or extra care housing) in Greater Norwich between 2020 and 2038.” Both of these figures differ from the stated 3,909 spaces within C2 institutions that the SHMA is expecting to be used. Given the discrepancy in the evidence base, it appears that these statistics are not based off of a robust up-to-date evidence base as required by paragraph 35 of the NPPF and as such, do not constitute a justified or sound approach.
Paragraph 277 of the Strategy states “to help provide for this need, the plan contains a specific allocation for a specialised development for active ageing at Colney Hall on site allocations with an element of specialist housing in the policy (Taverham, Aylsham, Harleston and Barrack Street, Norwich). In addition, policy 5 supports the delivery of older peoples and supported accommodation on housing sites with good access to local services including on sites allocated for residential use. The aim of this is to integrate older people and others with supported housing needs with the wider community, assisting active retirement and community cohesion. Development Management officers will ensure that the need for specialist housing for the elderly and other needs is considered on all housing schemes and advise applicants on the most up to date evidence of need.” As paragraph 276 states that there is a need for 3857 specialist units, as paragraph 277 states, this will be addressed through the provision of four dedicated sites with the shortfall being taken up in allocated residential sites.
Taking the above allocations into consideration, they would cumulatively result in the provision of approximately 300 dedicated elderly accommodation units. This is not a sound or appropriate strategy, nor is it positively prepared as the proposed allocations do not meet the areas need, nor does it meet even 25% of the area's identified need. As such, it is considered this approach is not sound in accordance with paragraph 35 of the NPPF.
As stated within the Inspectors report when assessing the Vale of Aylesbury Local Plan Policy H6, specialist housing for older people cannot be expected on mainstream housing sites and these should be addressed by specific allocations. This view is also echoed in paragraph 61 of the NPPF. Schemes that propose elderly care within larger residential allocations typically provide designated cul-de-sacs or clusters of specialist accommodation that does not help in providing or reinforcing community cohesion. Instead, such schemes promote isolation from the wider locality, as these elements within large residential sites are often inwardly focused with either secluded elements of public open space or a lack of connection to wider provision on site. This undermines the aspirations of delivering a healthy and cohesive community in conflict with the aims of the NPPF ultimately resulting in an unsound strategy in conflict with paragraph 35 of the NPPF.
Overall, the plan fails to secure a suitable strategy to deliver quality elderly accommodation in sufficient numbers to address an identified need and as such has not been positively prepared, is unjustified, ineffective, and is inconsistent with national policy.
Many individuals have seen how traumatic it is moving loved relatives in the later years of their life to C2 institutions which often result in unfamiliar surroundings which can exacerbate deteriorating health conditions. As such, the allocation of more 'Care Village' sites, where residents can age gracefully in the relative comfort of their own homes, whilst having independence, as well as medical and social care on site for when they need it, is a better strategy to address the needs of the aging population in the GNLP area. Additionally, through the allocation of specific additional sites, the significant identified need can be better addressed.
For example, one such site of the many needed is the Racecourse Community Park. this site promotes the concept of creating a care village which residents can move into before the critical stage of later life begins whilst they have full cognitive functions. This would foster community cohesion as well aid in stimulating community activities. There would be great benefit in allocating site GNLP0177-B at the Racecourse Community Park for specialist older persons accommodation and care provision to address the identified need. Through the allocation of Site GNLP0177-B , the Plan would not only better address the identified need for elderly accommodation, but provide a better alternative to C2 institutions and be in keeping with the aims and objectives of the GNLP and wider national strategies and ambitions.
As stated with the various evidence bases, there is a predicted short fall of over 3500 specialist units, if these were not to be provided across the residential allocations within the Greater Norwich Local Plan area. Incorporating so many of these in housing allocations has negative repercussions for future residents. Humans by nature thrive in communities, places where social interaction amongst like-minded and similar aged individuals helps retain and improve cognitive functions. The Racecourse Community Park provides the setting, and aspiration to deliver not only purpose-built homes in a community, but homes that would foster and encourage interactions amongst elderly occupiers and residents, whilst also being able to cater for a large dedicated variety of elderly care needs. Additionally, given the rise in suicide rates for elderly individuals due to depression and isolation it is viewed that providing more specialist accommodation clusters, such as this site in a setting which encourages outdoor social interaction could accommodate and help provide a better quality of life. This would also negate the inevitable token 3 or 4 units that will be sandwiched within large residential allocations in order to be policy compliant. As such, it is viewed that dedicated allocations of designated elderly accommodation is preferable not only for future occupiers, but also for developers aiding viability and ensuring deliverability of the residential allocations.
Policy 5 of the Greater Norwich Local Plan relates to the provision of housing. The policy encompasses all elements of housing including affordable housing, space standards, accessible and specialist housing, gypsy and traveler accommodation, purpose-built student accommodation, and self or custom build housing. Regarding the need for the provision of elderly accommodation, Policy 5 supports the incorporation of specialist accommodation within residential proposals. The Racecourse Community Park would include a significant element of specialist accommodation for the elderly and employment generating uses. The site therefore not only ties in with a wider strategic vision for the greater Norwich area but also adheres to the requirements of policy 5. It is noted that policy 5 will support specialist elderly accommodation where there is good access to local services. As part of the overall proposals for this site it is envisaged that a range of services will be provided that not only cover amenity, encouraging a healthy lifestyle, but also basic services to supplement those offered within both Hethersett and Cringleford. This is reinforced by the proposed Highways England improvement works to the A47/ A11 Thickthorn Junction Improvement scheme and the Parkland Management Plan for the Racecourse Community Park which has identified the need for minor allocations (for employment generating uses in close proximity to the Thickthorn Park & Ride extension and new link road) in support of the long-term ambitions and management strategy for the site.
The GNLP is deficient in housing for the elderly, employment land, and the impact on the environment. See rep summaries for detail.
Object
Publication
Policy 5 Homes
Representation ID: 24430
Received: 22/03/2021
Respondent: Trustees of First Viscount Mackintosh of Halifax and Trustees of CM Watt Residual Trust
Agent: La Ronde Wright
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The Local Plan identifies a significant need regarding the provision of elderly accommodation. Taking the available evidence, (paragraph 276 of the Strategy and the SHMA) this need is identified as between 2842 and 3857 additional specialist retirement units. The local plan identifies 4 sites to accommodate this additional need, however the sites in combination barely provide in excess of 300 units, leaving a potential 3500 units identified as being unmet by the proposed plan. This has further repercussions for neighbouring authorities who may not be able to take the additional need that would be unmet by dedicated allocations. As such, it is considered that draft Policy 5 in regard to elderly accommodation has not been positively prepared. Draft Policy 5 states that any shortfall shall be met through the requirement of making generic housing be accessible and easily adaptable (20% on all major housing developments). Although this is recognised as one potential solution from a housing perspective, adaptable homes do not facilitate medical care or truly enable the occupiers to remain in perpetuity. When occupiers require a few hours a week of care, this will have to be readily available and will likely result in the need for occupiers to vacate their homes for residential institutions causing much distress and at greater cost. The most efficient and viable from a national perspective, is to provide sites that cater specifically for the needs of older people where care is available 24/7 as needed and medical services can be provided to multiple residents in one trip. Such facilities that are age restricted also allow occupiers to enter before their needs are urgent, allowing them to become more accustomed to their surroundings and generally aid their declining years in comfort, knowing whatever happens they will be looked after. As such, the proposed solution of making multiple small pockets of isolated elderly communities is not considered to be justified as an appropriate strategy. Furthermore, this approach of not addressing and catering for elderly need, rather leaving it to chance for being delivered as part of larger residential schemes is not considered to be consistent with paragraph 61 of the NPPF or in accordance with Inspectors rulings regarding other Local Plan adoption processes (see Aylesbury Vale District Council, Vale of Aylesbury Local Plan Policy H6 (C2) Process Note, July 2019, pp 1-5.). A copy id annexed to this submission.
Regarding making the plan sound, it is viewed necessary that new sites be considered for allocation that provide dedicated elderly care facilities in meaningful numbers, to foster new elderly communities in sustainable locations and settings conducive to promoting active living as much as possible. It is considered essential that such facilities do not replicate old care-home institutions, but are more akin to the 'care village model', where independence is guaranteed through individual and self-contained accommodation, and both medical and social care are available on site around the clock. This reduces the need for turbulent evictions of those too old or ill to look after themselves and allows residents to retain an active lifestyle through available community facilities and open space in close proximity. Furthermore, through creating safe environments for residents, active social lives can be encouraged, where public open space is provided in abundance for all. This comes without the necessary maintenance issues that would deter older people from utilising private outdoor amenity space such as private gardens in their later years. Through the allocation of specific sites, the identified need is addressed more comprehensively, and this not only satisfies paragraph 61 of the NPPF but accommodates the vision outlined in the Strategy for promoting healthy vibrant lifestyles for communities.
The GNLP is deficient in housing for the elderly, employment land, and the impact on the environment. See rep summaries for detail.
Object
Publication
Policy 6 The Economy
Representation ID: 24431
Received: 22/03/2021
Respondent: Trustees of First Viscount Mackintosh of Halifax and Trustees of CM Watt Residual Trust
Agent: La Ronde Wright
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy 6 of the Regulation 19 draft Greater Norwich Local Plan states that “sufficient employment land is allocated in accessible locations to meet identified need and provide for choice.” This is disputed. The preferred sites and existing allocations do not objectively address identified needs, and that the proposed approach is not justified or sound in accordance with paragraph 35 of the NPPF.
The reliance on existing allocations undermines the policy. The evidence base Employment Land Assessment Addendum 2020 states: “Certain potential sites are large scale brownfield sites which would require significant site clearance and remediation in order to prepare the site for new employment development, which could affect the viability of delivering any form of employment activity on the site.” There is a reasonable alternative site forming a small part of the original site GNLP0177-B which would help to ensure a greater choice of employment venue better suited to the current trend and need for accommodation of a smaller scale in accessible locations. It suffers no significant viability concerns due to contamination and other issues.
Furthermore, the greater Norwich local plan allocates only 54.2 hectares of employment land for the next 17 years. It is considered that this is an exceptionally conservative estimate and that greater amounts of land may well be needed for future purposes. As already shown through the events of last year during the pandemic it is important to have a choice of places of employment within easy reach of new and existing homes. As such the GNLP needs to be more flexible providing opportunity for new creative industries and encouraging diversity in typology as much as possible to weather future crises. Through the allocation of more employment generating land of the type proposed at the Racecourse Community Park (site GNLP0177-B ) it is considered that the Greater Norwich Local Plan would be more robust as well as the local economy being more resilient through the provision and facilitation of greater choice of employment space and new opportunities close to existing homes and a Park and Ride.
The Greater Norwich Local Plan relies significantly upon undelivered previously allocated land. This land amounts to 229.9 hectares of land, as of April 2018, which will have been undeveloped for multiple reasons. It is fair to assume that not all of these reasons will have been overcome, and other issues impeding delivery have arisen. As such, further employment land, particularly smaller sites, need to be allocated to address existing and anticipated needs as a result of recent trends.
Policy 6 also states that development should seek to enhance the environment and economy of centers and villages with more dispersed services to protect their function and avoid the loss of commercial premises or local services.
As part of the Racecourse Community Park (GNLP0177-B ) a large area of public open space is to be provided. This land not only offers a wealth of biodiversity enhancements but usable public open space that would supplement and enhance the provision offered to both Hethersett and Cringleford. Furthermore, this site would result in more dispersed services within an easily accessible location to both residential areas. As such policy 6 would in theory be supportive of this development coming forward. The small parts of this site proposed for build development would perfectly supplement the employment provision proposed as part of the current draft Greater Norwich Local Plan.
The GNLP is deficient in housing for the elderly, employment land, and the impact on the environment. See rep summaries for detail.
Object
Publication
Sustainability Appraisal Report
Representation ID: 24432
Received: 22/03/2021
Respondent: Trustees of First Viscount Mackintosh of Halifax and Trustees of CM Watt Residual Trust
Agent: La Ronde Wright
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Regarding the GNLPs response to point 6: 6 Increased risk of urbanisation of the open countryside and coalescence. A total of 84 allocated sites are located on previously developed land in the open countryside of Greater Norwich. The proposed development within the GNLP in these locations would be expected to increase the risk of urbanisation of the countryside and coalescence.
It is important to undertake a new review of the strategic gaps and other areas between settlements at risk of coalescence to provide an up-to-date evidence base to inform new allocations. As such, with a lack of a review regarding the Strategic Gap, especially in light of the new strategic infrastructure works, it is considered that the GNLP is not justified regarding an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence and therefore conflicting with paragraph 35 of the NPPF.
It is considered that a review into strategic gaps and coalescence should be undertaken. An initial assessment has been completed for the Hethersett- Cringleford strategic gap. A copy is enclosed with this representation. From this we can see that development can be accommodated safely within the identified areas without impacting upon or resulting in coalescence between the two settlements. This would open up highly sustainable land, with a wealth of public benefits and opportunities. As a consequence of this, it is considered that the allocation of small sites within the originally proposed area identified as Hethersett GNLP0177-BR would be sustainable. This has been further evidenced through the procurement of a Parkland Management Plan for the site that would result in a strong preservation and enhancement of not only the historic assets but also the natural assets of the site whilst introducing new community and social infrastructure and opportunities for outdoor leisure and recreation through the creation of permission footpaths and access to the Parkland.
The GNLP is deficient in housing for the elderly, employment land, and the impact on the environment. See rep summaries for detail.
Object
Publication
Appendix B – Tables of Unallocated Sites with reasons for rejection
Representation ID: 24433
Received: 22/03/2021
Respondent: Trustees of First Viscount Mackintosh of Halifax and Trustees of CM Watt Residual Trust
Agent: La Ronde Wright
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Re: Broadland and South Norfolk Non-residential Sites, specifically GNLP0177-BR
Regarding the GNLPs response to point 6: 6 Increased risk of urbanisation of the open countryside and coalescence. A total of 84 allocated sites are located on previously developed land in the open countryside of Greater Norwich. The proposed development within the GNLP in these locations would be expected to increase the risk of urbanisation of the countryside and coalescence.
It is important to undertake a new review of the strategic gaps and other areas between settlements at risk of coalescence to provide an up-to-date evidence base to inform new allocations. As such, with a lack of a review regarding the Strategic Gap, especially in light of the new strategic infrastructure works, it is considered that the GNLP is not justified regarding an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence and therefore conflicting with paragraph 35 of the NPPF.
It is considered that a review into strategic gaps and coalescence should be undertaken. An initial assessment has been completed for the Hethersett- Cringleford strategic gap. A copy is enclosed with this representation. From this we can see that development can be accommodated safely within the identified areas without impacting upon or resulting in coalescence between the two settlements. This would open up highly sustainable land, with a wealth of public benefits and opportunities. As a consequence of this, it is considered that the allocation of small sites within the originally proposed area identified as Hethersett GNLP0177-BR would be sustainable. This has been further evidenced through the procurement of a Parkland Management Plan for the site that would result in a strong preservation and enhancement of not only the historic assets but also the natural assets of the site whilst introducing new community and social infrastructure and opportunities for outdoor leisure and recreation through the creation of permission footpaths and access to the Parkland.
The GNLP is deficient in housing for the elderly, employment land, and the impact on the environment. See rep summaries for detail.
Object
Publication
Policy 6 The Economy
Representation ID: 24440
Received: 22/04/2021
Respondent: Trustees of First Viscount Mackintosh of Halifax and Trustees of CM Watt Residual Trust
Agent: La Ronde Wright
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy 6 of the Regulation 19 draft Greater Norwich Local Plan states that “sufficient employment land is allocated in accessible locations to meet identified need and provide for choice.” This is disputed. The preferred sites and existing allocations do not objectively address identified needs, and that the proposed approach is not justified or sound in accordance with paragraph 35 of the NPPF.
The reliance on existing allocations undermines the policy. The evidence base Employment Land Assessment Addendum 2020 states: “Certain potential sites are large scale brownfield sites which would require significant site clearance and remediation in order to prepare the site for new employment development, which could affect the viability of delivering any form of employment activity on the site.” There is a reasonable alternative site forming a small part of the original site GNLP0177-B which would help to ensure a greater choice of employment venue better suited to the current trend and need for accommodation of a smaller scale in accessible locations. It suffers no significant viability concerns due to contamination and other issues.
Furthermore, the greater Norwich local plan allocates only 54.2 hectares of employment land for the next 17 years. It is considered that this is an exceptionally conservative estimate and that greater amounts of land may well be needed for future purposes. As already shown through the events of last year during the pandemic it is important to have a choice of places of employment within easy reach of new and existing homes. As such the GNLP needs to be more flexible providing opportunity for new creative industries and encouraging diversity in typology as much as possible to weather future crises. Through the allocation of more employment generating land of the type proposed at the Racecourse Community Park (site GNLP0177-B ) it is considered that the Greater Norwich Local Plan would be more robust as well as the local economy being more resilient through the provision and facilitation of greater choice of employment space and new opportunities close to existing homes and a Park and Ride.
The Greater Norwich Local Plan relies significantly upon undelivered previously allocated land. This land amounts to 229.9 hectares of land, as of April 2018, which will have been undeveloped for multiple reasons. It is fair to assume that not all of these reasons will have been overcome, and other issues impeding delivery have arisen. As such, further employment land, particularly smaller sites, need to be allocated to address existing and anticipated needs as a result of recent trends.
Policy 6 also states that development should seek to enhance the environment and economy of centers and villages with more dispersed services to protect their function and avoid the loss of commercial premises or local services.
As part of the Racecourse Community Park (GNLP0177-B ) a large area of public open space is to be provided. This land not only offers a wealth of biodiversity enhancements but usable public open space that would supplement and enhance the provision offered to both Hethersett and Cringleford. Furthermore, this site would result in more dispersed services within an easily accessible location to both residential areas. As such policy 6 would in theory be supportive of this development coming forward. The small parts of this site proposed for build development would perfectly supplement the employment provision proposed as part of the current draft Greater Norwich Local Plan.
Please find attached representations in relation to the GNLP Regulation 19 consultation with regard to site GNLP0177-B. These representations are submitted by Le Ronde Wright Limited on behalf of the Trustees of the site.
This representation relates to Policy 3, 5, 6 and the SA. For more details please view the summaries.
Object
Publication
Sustainability Appraisal Report
Representation ID: 24441
Received: 22/04/2021
Respondent: Trustees of First Viscount Mackintosh of Halifax and Trustees of CM Watt Residual Trust
Agent: La Ronde Wright
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Regarding the GNLPs response to point 6: 6 Increased risk of urbanisation of the open countryside and coalescence. A total of 84 allocated sites are located on previously developed land in the open countryside of Greater Norwich. The proposed development within the GNLP in these locations would be expected to increase the risk of urbanisation of the countryside and coalescence.
It is important to undertake a new review of the strategic gaps and other areas between settlements at risk of coalescence to provide an up-to-date evidence base to inform new allocations. As such, with a lack of a review regarding the Strategic Gap, especially in light of the new strategic infrastructure works, it is considered that the GNLP is not justified regarding an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence and therefore conflicting with paragraph 35 of the NPPF.
It is considered that a review into strategic gaps and coalescence should be undertaken. An initial assessment has been completed for the Hethersett- Cringleford strategic gap. A copy is enclosed with this representation. From this we can see that development can be accommodated safely within the identified areas without impacting upon or resulting in coalescence between the two settlements. This would open up highly sustainable land, with a wealth of public benefits and opportunities. As a consequence of this, it is considered that the allocation of small sites within the originally proposed area identified as Hethersett GNLP0177-BR would be sustainable. This has been further evidenced through the procurement of a Parkland Management Plan for the site that would result in a strong preservation and enhancement of not only the historic assets but also the natural assets of the site whilst introducing new community and social infrastructure and opportunities for outdoor leisure and recreation through the creation of permission footpaths and access to the Parkland.
Please find attached representations in relation to the GNLP Regulation 19 consultation with regard to site GNLP0177-B. These representations are submitted by Le Ronde Wright Limited on behalf of the Trustees of the site.
This representation relates to Policy 3, 5, 6 and the SA. For more details please view the summaries.
Object
Publication
Policy 5 Homes
Representation ID: 24442
Received: 22/04/2021
Respondent: Trustees of First Viscount Mackintosh of Halifax and Trustees of CM Watt Residual Trust
Agent: La Ronde Wright
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The Local Plan identifies a significant need regarding the provision of elderly accommodation. Taking the available evidence, (paragraph 276 of the Strategy and the SHMA) this need is identified as between 2842 and 3857 additional specialist retirement units. The local plan identifies 4 sites to accommodate this additional need, however the sites in combination barely provide in excess of 300 units, leaving a potential 3500 units identified as being unmet by the proposed plan. This has further repercussions for neighbouring authorities who may not be able to take the additional need that would be unmet by dedicated allocations. As such, it is considered that draft Policy 5 in regard to elderly accommodation has not been positively prepared. Draft Policy 5 states that any shortfall shall be met through the requirement of making generic housing be accessible and easily adaptable (20% on all major housing developments). Although this is recognised as one potential solution from a housing perspective, adaptable homes do not facilitate medical care or truly enable the occupiers to remain in perpetuity. When occupiers require a few hours a week of care, this will have to be readily available and will likely result in the need for occupiers to vacate their homes for residential institutions causing much distress and at greater cost. The most efficient and viable from a national perspective, is to provide sites that cater specifically for the needs of older people where care is available 24/7 as needed and medical services can be provided to multiple residents in one trip. Such facilities that are age restricted also allow occupiers to enter before their needs are urgent, allowing them to become more accustomed to their surroundings and generally aid their declining years in comfort, knowing whatever happens they will be looked after. As such, the proposed solution of making multiple small pockets of isolated elderly communities is not considered to be justified as an appropriate strategy. Furthermore, this approach of not addressing and catering for elderly need, rather leaving it to chance for being delivered as part of larger residential schemes is not considered to be consistent with paragraph 61 of the NPPF or in accordance with Inspectors rulings regarding other Local Plan adoption processes (see Aylesbury Vale District Council, Vale of Aylesbury Local Plan Policy H6 (C2) Process Note, July 2019, pp 1-5.). A copy id annexed to this submission.
Regarding making the plan sound, it is viewed necessary that new sites be considered for allocation that provide dedicated elderly care facilities in meaningful numbers, to foster new elderly communities in sustainable locations and settings conducive to promoting active living as much as possible. It is considered essential that such facilities do not replicate old care-home institutions, but are more akin to the 'care village model', where independence is guaranteed through individual and self-contained accommodation, and both medical and social care are available on site around the clock. This reduces the need for turbulent evictions of those too old or ill to look after themselves and allows residents to retain an active lifestyle through available community facilities and open space in close proximity. Furthermore, through creating safe environments for residents, active social lives can be encouraged, where public open space is provided in abundance for all. This comes without the necessary maintenance issues that would deter older people from utilising private outdoor amenity space such as private gardens in their later years. Through the allocation of specific sites, the identified need is addressed more comprehensively, and this not only satisfies paragraph 61 of the NPPF but accommodates the vision outlined in the Strategy for promoting healthy vibrant lifestyles for communities.
Please find attached representations in relation to the GNLP Regulation 19 consultation with regard to site GNLP0177-B. These representations are submitted by Le Ronde Wright Limited on behalf of the Trustees of the site.
This representation relates to Policy 3, 5, 6 and the SA. For more details please view the summaries.
Object
Publication
Policy 5 Homes
Representation ID: 24443
Received: 22/04/2021
Respondent: Trustees of First Viscount Mackintosh of Halifax and Trustees of CM Watt Residual Trust
Agent: La Ronde Wright
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
It is considered that Policy 5, and the handling of elderly accommodation has not been positively prepared, is unjustified, ineffective, and inconsistent with national policy due to the failure to secure a suitable strategy to deliver quality elderly accommodation in sufficient numbers to address an identified need.
Paragraph 275 of the Strategy states “an increasing proportion of the population is over 65 or disabled, increasing the demand for supported accommodation such as sheltered housing, extra care housing and care homes, residential care and supported living. The local plan seeks to assist County’s aim to reduce residential care home and nursing home dependency and support people to remain more independent in their own homes or in supported housing.” There is an ever expanding need for older persons' accommodation. In fact, we applaud the efforts of the Greater Norwich Local Plan in trying to reduce the reliance in the traditional sense of residential care homes. Many individuals have seen how traumatic it is moving loved relatives in the later years of their life to such institutions which are often unfamiliar surroundings which exacerbate deteriorating health conditions.
Paragraph 276 of the Strategy states that “the policy therefore supports the provision of housing to meet the needs of older people and others with support needs, including sheltered housing, residential/nursing care accommodation and extra care housing. Norfolk County Council strategy identifies the need for 2842 additional extra care units by 2028. County wide evidence has identified the need for 3857 specialist retirement units (sheltered, age restricted or extra care housing) in Greater Norwich between 2020 and 2038.” Both of these figures differ from the stated 3,909 spaces within C2 institutions that the SHMA is expecting to be used. Given the discrepancy in the evidence base, it appears that these statistics are not based off of a robust up-to-date evidence base as required by paragraph 35 of the NPPF and as such, do not constitute a justified or sound approach.
Paragraph 277 of the Strategy states “to help provide for this need, the plan contains a specific allocation for a specialised development for active ageing at Colney Hall on site allocations with an element of specialist housing in the policy (Taverham, Aylsham, Harleston and Barrack Street, Norwich). In addition, policy 5 supports the delivery of older peoples and supported accommodation on housing sites with good access to local services including on sites allocated for residential use. The aim of this is to integrate older people and others with supported housing needs with the wider community, assisting active retirement and community cohesion. Development Management officers will ensure that the need for specialist housing for the elderly and other needs is considered on all housing schemes and advise applicants on the most up to date evidence of need.” As paragraph 276 states that there is a need for 3857 specialist units, as paragraph 277 states, this will be addressed through the provision of four dedicated sites with the shortfall being taken up in allocated residential sites.
Taking the above allocations into consideration, they would cumulatively result in the provision of approximately 300 dedicated elderly accommodation units. This is not a sound or appropriate strategy, nor is it positively prepared as the proposed allocations do not meet the areas need, nor does it meet even 25% of the area's identified need. As such, it is considered this approach is not sound in accordance with paragraph 35 of the NPPF.
As stated within the Inspectors report when assessing the Vale of Aylesbury Local Plan Policy H6, specialist housing for older people cannot be expected on mainstream housing sites and these should be addressed by specific allocations. This view is also echoed in paragraph 61 of the NPPF. Schemes that propose elderly care within larger residential allocations typically provide designated cul-de-sacs or clusters of specialist accommodation that does not help in providing or reinforcing community cohesion. Instead, such schemes promote isolation from the wider locality, as these elements within large residential sites are often inwardly focused with either secluded elements of public open space or a lack of connection to wider provision on site. This undermines the aspirations of delivering a healthy and cohesive community in conflict with the aims of the NPPF ultimately resulting in an unsound strategy in conflict with paragraph 35 of the NPPF.
Overall the plan fails to secure a suitable strategy to deliver quality elderly accommodation in sufficient numbers to address an identified need and as such has not been positively prepared, is unjustified, ineffective and is inconsistent with national policy.
Many individuals have seen how traumatic it is moving loved relatives in the later years of their life to C2 institutions which often result in unfamiliar surroundings which can exacerbate deteriorating health conditions. As such, the allocation of more 'Care Village' sites, where residents can age gracefully in the relative comfort of their own homes, whilst having independence, as well as medical and social care on site for when they need it, is a better strategy to address the needs of the aging population in the GNLP area. Additionally, through the allocation of specific additional sites, the significant identified need can be better addressed.
For example, one such site of the many needed is the Racecourse Community Park. this site promotes the concept of creating a care village which residents can move into before the critical stage of later life begins whilst they have full cognitive functions. This would foster community cohesion as well aid in stimulating community activities. There would be great benefit in allocating site GNLP0177-B at the Racecourse Community Park for specialist older persons accommodation and care provision to address the identified need. Through the allocation of Site GNLP0177-B , the Plan would not only better address the identified need for elderly accommodation, but provide a better alternative to C2 institutions and be in keeping with the aims and objectives of the GNLP and wider national strategies and ambitions.
As stated with the various evidence bases, there is a predicted short fall of over 3500 specialist units, if these were not to be provided across the residential allocations within the Greater Norwich Local Plan area. Incorporating so many of these in housing allocations has negative repercussions for future residents. Humans by nature thrive in communities, places where social interaction amongst like-minded and similar aged individuals helps retain and improve cognitive functions. The Racecourse Community Park provides the setting, and aspiration to deliver not only purpose-built homes in a community, but homes that would foster and encourage interactions amongst elderly occupiers and residents, whilst also being able to cater for a large dedicated variety of elderly care needs. Additionally, given the rise in suicide rates for elderly individuals due to depression and isolation it is viewed that providing more specialist accommodation clusters, such as this site in a setting which encourages outdoor social interaction could accommodate and help provide a better quality of life. This would also negate the inevitable token 3 or 4 units that will be sandwiched within large residential allocations in order to be policy compliant. As such, it is viewed that dedicated allocations of designated elderly accommodation is preferable not only for future occupiers, but also for developers aiding viability and ensuring deliverability of the residential allocations.
Policy 5 of the Greater Norwich Local Plan relates to the provision of housing. The policy encompasses all elements of housing including affordable housing, space standards, accessible and specialist housing, gypsy and traveler accommodation, purpose-built student accommodation, and self or custom build housing. Regarding the need for the provision of elderly accommodation, Policy 5 supports the incorporation of specialist accommodation within residential proposals. The Racecourse Community Park would include a significant element of specialist accommodation for the elderly and employment generating uses. The site therefore not only ties in with a wider strategic vision for the greater Norwich area but also adheres to the requirements of policy 5. It is noted that policy 5 will support specialist elderly accommodation where there is good access to local services. As part of the overall proposals for this site it is envisaged that a range of services will be provided that not only cover amenity, encouraging a healthy lifestyle, but also basic services to supplement those offered within both Hethersett and Cringleford. This is reinforced by the proposed Highways England improvement works to the A47/ A11 Thickthorn Junction Improvement scheme and the Parkland Management Plan for the Racecourse Community Park which has identified the need for minor allocations (for employment generating uses in close proximity to the Thickthorn Park & Ride extension and new link road) in support of the long-term ambitions and management strategy for the site.
Please find attached representations in relation to the GNLP Regulation 19 consultation with regard to site GNLP0177-B. These representations are submitted by Le Ronde Wright Limited on behalf of the Trustees of the site.
This representation relates to Policy 3, 5, 6 and the SA. For more details please view the summaries.