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The Regulation 18 Plan evidence base requires some further clarification in respect of its assessment of specialist elderly persons accommodation referred to paragraphs 46 - 50. The SHMA Part 2 at paragraphs 6.3 - 6.14 attempts to assess the level of need for specialist elderly persons accommodation within the plan period by using the Strategic Housing for Older People tool developed by the Housing Learning and Improvement Network. In our view, this is a reasonable tool for assessing the likely level of specialist housing requirements for elderly persons in general but because it is, as confirmed in paragraph 6.8 of the SHMA, driven by demographic changes and does not take into account peoples' aspirations it is likely to be less accurate in assessing the level of need for Care Homes in Use Class C2. Paragraph 6.14 of the SHMA Part 2 suggests a need for an additional 424 spaces over the next 20 years. The problem with this demographic only assessment approach is that it is likely to over-estimate the actual need because it fails to take into account the traditional desire of elderly people to avoid taking accommodation in an institutional care home and also fails to recognize the greater variety of specialist housing options now available which are designed to allow elderly people to maintain their independence for longer. The HAPPI Spectrum published by the Housing our Ageing Population: Panel for Innovation (HAPPI) identifies a range of options which are available as specialized housing where personal care and support can be arranged or provided within the development together with shared facilities and activities. These include sheltered retirement homes, very sheltered homes, extra care housing, retirement villages and close care facilities.
Paragraph 72 of the Regulation 18 Plan suggests the provision at DHGV of "two large [care] homes -204 beds in total". While the Promoters do not object to the principle of providing elderly persons accommodation on site - indeed it is welcomed as part of creating an inclusive community - before committing to policy a precise provision requirement for two large care homes it will be important to be clear about the level and type of need. Alternatively, our recommendation would be to maintain flexibility and include in policy a requirement to provide specialist accommodation for the ageing population. Such flexibility would allow the Promoters and the Council to assess properly the level and type of requirements at the time of application submission and appropriately integrate that housing with the community. If, on the other hand, further detailed assessment or clarification of need and accommodation type is gathered then inclusion into the allocation policy would be entirely acceptable.
The Promoters are currently assessing the ability of DHGV to accommodate specialist pitches for Gypsy and Traveller households. It is noted that in Fig 13 of the Regulation 18 Plan DHGV has been identified in Step 6 of a sequential testing exercise for consideration of a possible 30 (approx) pitches. We are not yet convinced by the available evidence that sufficient need has been identified to justify the accommodation of this number of pitches, or in the DHGV location. Firstly, the Gypsy and Traveller Accommodation Assessment (October 2017) identifies a need within the borough for only 12 additional pitches for Gypsy and Traveller households which meet the planning definition contained in the Planning Policy for Traveller Sites. There is no explanation of why the Plan seeks to identify accommodation of additional pitches for households which do not meet the planning definition. Secondly, the Promoters are not persuaded that DHGV is a suitable location for such a large concentration of pitches, particularly in view of the fact that the sequential test has identified other more suitable sites to meet the need.