Chichester Local Plan 2021 - 2039: Proposed Submission

Request that a new subclause is added stating that:

Specialist older persons’ housing will be subject to a nil affordable housing requirement on brownfield / urban sites in the South of the District and a 30% affordable housing requirement on greenfield sites.

See attachment.

Conclusion

5.1.1 Churchill Retirement Living are strongly of the view that it would be more appropriate to set a nil affordable
housing target for sheltered and extra care development, at the very least in urban areas in the south of the
District. This approach accords with the guidance of the PPG which states that ‘Different (affordable housing)
requirements may be set for different types or location of site or types of development’ (Paragraph: 001
Reference ID: 10-001-20190509).

5.1.2 The guidance in the NPPF and the PPG is that the role for viability assessment is primarily at the Plan making stage:
Where up-to-date policies have set out the contributions expected from development, planning applications that
comply with them should be assumed to be viable. It is up to the applicant to demonstrate whether particular
circumstances justify the need for a viability assessment at the application stage. The weight to be given to a
viability assessment is a matter for the decision maker, having regard to all the circumstances in the case,
including whether the plan and the viability evidence underpinning it is up to date, and any change in site
circumstances since the plan was brought into force (paragraph 57.)

5.1.3 Council Members, Officers and the general public will assume that applications for sheltered or extra care
housing will be able to support a policy compliant level of affordable housing. This would however be wholly at
odds with the viability evidence underpinning the Local Plan.

5.1.4 The requirement for affordable housing contributions from specialist older persons’ housing typologies is therefore speculative rather than based on the evidence presented. The Local Plan is therefore considered to be unsound on the grounds the affordable housing targets are not justified, positively prepared or effective.

5.1.5 We therefore respectfully request that a new subclause is added stating that:
Specialist older persons’ housing will be subject to a nil affordable housing requirement on brownfield / urban
sites in the South of the District and a 30% affordable housing requirement on greenfield sites.

5.1.6 To that end, we would like to draw the Council’s attention to Paragraph 5.33 of Policy HP5: Provision of
Affordable Housing in the emerging Fareham Borough Local Plan which advises that:
5.33 ... The Viability Study concludes that affordable housing is not viable for older persons and specialist
housing. Therefore, Policy HP5 does not apply to specialist housing or older persons housing.

5.1.7 A nil affordable housing rate could facilitate a step-change in the delivery of older person’s housing in the District, helping to meet the diverse housing needs of the elderly. The benefits of specialist older persons’ housing extend beyond the delivery of planning obligations as these forms of development contribute to the regeneration of town centres and assist Council’s by making savings on health and social care.