The SA highlights that a number of different spatial options for growth have been consulted upon at the ‘First conversation’ Consultation in January and February 2020 and that these were subject to SA and presented in the Sustainability Appraisal of Issues and Options (December 2019).
It is noted in paragraph 2.19 that a medium level of growth has been selected as the preferred option which sits between the use of the government’s standard method local housing need figure (minimum growth option) and the option to plan for the higher jobs forecast and level of homes associated with it (maximum growth option). Both alternatives were rejected as the Councils do not consider that they represent Greater Cambridge’s objectively assessed need.
The SA has considered the three policy options for the delivery of Specialist Housing and homes for older people. The three options were as follows:
• Preferred option: Policy H/SH which is considered to be enable the delivery of sufficient specialist housing to meet the identified need;
• Alternative option: No policy: this has not been appraised as it was not considered to be a reasonable alternative due to the need to provide a criteria-based polity to ensure the delivery of specialist housing; and
• Alternative Option: Not to allocate sites for new specialist housing at new settlements and within urban extensions. This has not been appraised as it was not considered a reasonable alternative as Councils need to set out how they deliver sufficient specialist housing and as developments should seek to delivery balanced and mixed communities. It is also noted national planning policy requires that the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies.
For the reasons set out below the Council’s approach to the SA and undertaking a detailed assessment of only its Preferred Option is unsound (not justified) and not legally compliant in terms of the requirements for SA. The SA assessment findings on the Council’s Preferred Option are also not supported by the assumptions underlying the Preferred Option.
The findings of the sustainability assessment of the preferred option as shown in Table 5.66: Policy H/SH: Specialist housing and homes for older people of the SA is included below.
The SA notes a significant positive contribution that the preferred policy will make to the delivery of housing to meet the identified needs. There is however no discussion on an alternative option to allocate specific sites to deliver specialist housing to meet the identified issues of potential under delivery of housing on strategic sites and urban extensions.
The SA is a critical tool to enable the Councils to demonstrate that they have identified an appropriate strategy that is justified with support from the Plan’s evidence base (NPPF, 2021 Paragraph 35). In the context of specialist housing for older people, the baseline characteristics that it is required to consider as part of the SA process include a current and forecast future shortfall in the supply of housing towards the needs of this group. The likely evolution of this baseline without implementation of new policies, assessed in accordance with the PPG (ID: 11-016-20190722), will result in significant adverse effects for social and economic sustainability, across a number of the Council’s own SA objectives (including Health, Housing, Employment, Social Inclusion and Access to Services and Facilities).
The Planning Practice Guidance specifies that reasonable alternatives should be identified on the basis of being realistic and fully assessed against relevant baseline characteristics to enable likely significant effects to be evaluated. The assumptions used in assessing the significance of the effects of the plan will need to be documented, with the SA forming part of an iterative exercise during the plan-making process. Testing of reasonable alternatives should enable the different sustainability implications of sufficiently distinct options to be assessed (ID: 11-018-20140306).
Within the context of the PPG there is no justification for the following assessment findings of the Council’s Preferred Option under the following objectives:
• Housing – Significant Positive Effects (amend to Uncertain Minor Positive Effects)
• Social Inclusion – Significant Positive Effects (amend to Uncertain Minor Positive Effects)
The Council’s own evidence does not propose to set out requirements in policy and the identification of allocated sites at new settlements and urban extensions that will meet the needs for specialist older persons housing in full to 2041. The Council’s Topic Paper 7 acknowledges a high degree of uncertainty in likely provision from existing committed and potential future supply. Failure to meet needs in full would clearly equate to potential adverse effects to health, employment and social inclusion given the projected increase in demand.
The Council’s approach to achieving social inclusion objectives through the delivery of specialist older persons housing at urban extensions and new settlements is entirely dependent on sites coming forward at these locations. Similar or enhanced positive effects could be secured through the result of meeting the housing needs of older people through dedicated allocations at other sustainable locations within the settlement hierarchy, including our client’s site at Comberton.
There is no justification for the Council’s failure to test a reasonable alternative that would provide greater certainty in meeting a full assessment of the needs for specialist housing for older people through the allocation of sites at locations within Greater Cambridge including outside of urban extensions and new settlements. Such an approach would satisfy the requirements of national policy in terms of setting out the size, type and tenure of housing needed and how this will be provided. Specific allocations to meet identified needs would provide a robust basis for the effective monitoring of future supply.
The likely significant effects of the Alternative Option as described above would be distinct from the Council’s Preferred Option (as a result of setting out measures to meet needs in full and maximise the locations benefiting from development). The assessment findings for an Alternative Option incorporating our client’s site at Comberton would justify significant positive effects in relation to Housing and Social Inclusion and other positive effects in terms of objectives including Health, Employment and Services and Facilities due to the characteristics of the proposals for an Integrated Retirement Community under the Extra Care model.
It is therefore unclear why the preferred option, which brings with it a level of uncertainty of achieving the required delivery of specialist housing has been chosen.
As set out within the accompanying ‘Representation by Inspired Villages – to support the practical delivery of much-needed specialist accommodation to meet the needs of an ageing population’ (paragraph 4.7), it is important the evidence base properly assesses supply and demand, given the substantial increase in the elderly demographics, the high proportion of home ownership for those ages 65+ and the rapidly increasing cost of caring for the elderly population. Continuing past trends in supply against projected growth in elderly demographics is not considered the best way of predicting demand for particular types of elderly care and accommodation, as traditional residential care homes make way for new forms of accommodation and care.
It is therefore essential that the local authority has a full understanding of the various forms of care and accommodation, knowledge of schemes and their availability and input from a range of sources to determine appropriate sites and levels of need over the plan period. The government’s response to the ‘Inquiry into Housing for Older People’ (2019), identified that offering older people a better choice of accommodation can help them to live independently for longer, improve their quality of life and free up more family homes for other buyers.
As has been demonstrated throughout these representations, sites such as our client’s site at Branch Lane and Long Lane, Comberton, offer a sustainable site in a location which is in close proximity to a number of services and facilities. The Council should therefore consider allocating specific sites such as this which are designed to support integrated living and extra-care accommodation within existing communities.