We have concerns that this policy will not address the identified need for specialist accommodation for older people in its entirety, nor will it ensure the right type of accommodation is delivered in the right places. In accordance with paragraph 62 of the NPPF, the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies, including, inter alia, older people. Older people are defined within the NPPF as:

“People 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.”

It is therefore imperative that the Plan makes provision for the delivery of a broad range of housing suitable for older people. PPG (Paragraph: 010 Reference ID: 63-010-20190626) provides a non-exhaustive list as to the different types of specialist housing designed to meet the diverse needs of older people, which include age-restricted general market housing, retirement living/sheltered housing, extra-care and housing-with-care, and residential care homes and nursing homes.

PPG confirms that the need to provide housing for older people is critical, and Greater Cambridge is no exception.

The Homes Topic Paper summarises the findings of the Older People’s Housing: Care and Support Needs in Greater Cambridge 2017-2036, which develops a model to estimate the supply and demand for older people’s housing. Using this model, the report identifies a need for 917 additional age exclusive homes within Greater Cambridge, in addition to 2,741 additional self-contained specialist homes in the form of sheltered accommodation or extra care accommodation. The report also identifies a shortfall, as of 2016 in the provision of specialist accommodation, recommending a total supply at 2035 of 2,036 age exclusive homes, and 6,163 specialist self-contained units.

This highlights a considerable current deficit in the supply of older persons’ accommodation, and a critical need to ensure that suitable and adequate provision is made within the Plan for specialist accommodation.

Policy H/SH confirms that some forms of specialist housing will be delivered through the requirements for all new homes to be built to M4(2) accessible and adaptable Building Standards. Whilst we support the intention to ensure all homes are built to these standards, M4(2) dwellings do not satisfy the broad range of housing needs of older people and should form part of the strategy for delivering sufficient suitable housing for older people.

There is insufficient detail within the Plan to demonstrate that either Policy H/SH or Policy H/HM (Housing mix) will ensure that provision of specialist housing will be required as part of the housing mix of new developments, particularly at new settlements and within urban extensions. This is particularly given these sites make up a considerably small element of the overall housing supply within the Plan period, therefore we question how these sites will be capable of delivering the identified need for specialist housing. Further, 97% of the additional sources of housing supply identified within the Plan are large, strategic sites, many of which, such as Cambridge Airport and the extension to Cambourne, will not be delivered until post 2030, with actual delivery timescales uncertain. A reliance on these sites to deliver specialist accommodation will not ensure timely delivery, not least due to the long lead times associated with developments of this size, which will cause further, considerable delay in meeting identified needs when there is already a substantial undersupply. Additionally, this approach does not ensure that homes will be delivered in locations where needs currently exist, requiring older people to make the choice of staying in a home that is not suitable for their needs, or move away from their existing community to find suitable accommodation.

We raise concerns that the Plan does not include sufficient sites to deliver housing within the short-term plan period in our comments on Policy S/DS, and this is applicable to the deliver of specialist accommodation.

Given the significant need for specialist housing identified within the Homes Topic Paper, and the inability of the Plan as proposed to meet this, we consider it is critical for the Plan to identify additional sites for specialist housing for older people, within sustainable locations throughout Greater Cambridge, to ensure the right type of homes are delivered in the right places. It is surprising that the reasonable alternatives considered did not include the allocation of sites for specialist housing, as part of a combined approach to ensure the diverse needs of older people will be met within the Plan period and, within the locations it is needed.

We disagree with the Councils’ consideration of site-specific arguments for exceptional circumstances for releasing sites from the Green Belt on the edge of Cambridge, particularly in relation to the land to the east of Ditton Lane, Fen Ditton (Site Reference: 40217), for specialist accommodation. Our comments in relation to the assessment of this site within the HELAA are noted against Policy S/EOC, however, the Council state in the Development Strategy Topic Paper (page 209) that the need for specialist accommodation does not justify the exceptional circumstances to release land from the Green Belt. We question how the critical need for specialist accommodation (including a considerable existing undersupply) does not justify the exceptional circumstances to release sites within a highly accessible location on the edge of Cambridge from the Green Belt but releasing sites to meet general housing needs from the Green Belt in other areas which benefit from good accessibility to public transport does, particularly in light of the High Court judgment Calverton Parish Council v Greater Nottingham Councils [2015] EWHC 10784. This confirms that factors that should ideally be considered in deciding whether exceptional circumstances exist include, inter alia, acuteness/intensity of the objectively assessed need and the inherent constraints on supply/availability of land prima facie suitable for sustainable development.

We would highlight the commentary within paragraph 4.40 of the Sustainability Appraisal, which states that whilst also helping to support existing services and facilities, growth within villages may be particularly important for the villages’ older residents, noting that the population in rural areas have a higher average age than Cambridge city. Fen Ditton has excellent access to a number of services and facilities and public transport links, and is an example of a village within Greater Cambridge which would be suitable for specialist accommodation.