Recommendation
In order for Policy H8 to be more positively prepared to assist in delivering the substantial need for specialist housing for older people, policy H8 should be amended so that it reads as follows:

Policy H8 Specialist accommodation for older people and those with specialised needs

Specialist housing for older people

All housing sites over 200 units, including those allocated in this plan, will be required to provide specialist accommodation housing for older people.

The Council will also support proposals delivering specialist housing for older people across all tenures in sustainable locations. Specialist housing for older people should be located in in close proximity to everyday services, be well connected by safe and suitable walking / cycling routes or public transport for the intended occupier.

Specialist housing
Proposals for specialist housing, such as homes for, students, HMOs or essential worker accommodation37, and other groups requiring specifically designed accommodation will be supported where the following criteria are met:
1. There is an identified need;
2. It will not lead to a concentration of similar uses in an area that would be detrimental to the character or function of an area and / or residential amenity;
3. It is in close proximity to everyday services, connecting by safe and suitable walking / cycling routes or public transport for the intended occupier;
4. It can be demonstrated that the development is designed to provide the most appropriate types of support for the target resident;
5. It can be demonstrated that revenue funding can be secured to maintain the long-term viability of the scheme (if relevant to the type of accommodation proposed); and
6. The scheme is supported by the relevant agencies (if relevant to the accommodation type to be provided).

Proposals which may result in the loss of specialist needs accommodation will not be permitted unless it can be demonstrated that there is no longer a need for such accommodation in the plan area, or alternative provision is being made available locally through replacement or new facilities.

Policy H8 Specialist accommodation for older people and those with specialised needs

Thank you for the opportunity to comment on the Chichester Local Plan 2021-2039 Proposed Submission Draft (Regulation 19) consultation. McCarthy Stone is the leading provider of specialist housing for older people.

Whilst we are encouraged by ‘Policy H8 Specialist accommodation for older people and those with specialised needs’ we feel that trying to combine a policy on encouraging specialist housing for older people and specialist accommodation has resulted in a confusing policy that is not positively prepared. Given the substantial need for specialist housing for older people identified within the Chichester Housing and Economic Development Needs Assessment, 2022, Iceni (HEDNA) we feel the policy should be redrafted to make it clearer and more consistent with national policy as detailed in our response to policy H5 Housing Mix and specifically paragraphs 001 Reference ID: 63-001-20190626, 003 Reference ID: 63-003-20190626 and 006 Reference ID: 63-006-20190626 of PPG Housing for Older and Disabled People. This should ensure that some of the substantial need for specialist housing for older people is delivered without applicants having to consider policy requirements that would not be relevant for such schemes.

In addition, developers of older people’s housing schemes should not be required to demonstrate need given the substantial need identified.