Greater Cambridge Local Plan Preferred Options

Paragraph 65 b) of the Framework makes clear that proposals for specialist accommodation should be exempt from providing at least 10% of properties for affordable home ownership, stating: “Exemptions to this 10% requirement should also be made where the site or proposed development: b) provides specialist accommodation for a group of people with specific needs (such as purpose-built accommodation for the elderly or students)”; Government policy is therefore clear that specialist accommodation should be exempt from this affordable housing policy requirement.
The proposed development at Branch Lane and Long Lane, Comberton would include a mix of C3 general needs dwellings and Use Class C2 Extra Care accommodation. The provision of affordable housing contributions will need to be assessed with this consideration in mind and as such the policy approach must support the separate assessment of affordable housing contributions on these types of mixed-use sites. For example, the Council’s proposals under Policy H/AH for mixed-tenure schemes including Build-to-Rent elements may be subject to making up any shortfall in affordable homes across the remainder of the development. Without prejudice to the justification for that position, Policy H/AH must be clarified to ensure that similar arrangements will not be applied to mixed-use sites incorporating specialist housing for older people.
Proposed Policy H/AH also sets out that on sites of 10 or more dwellings 40% of new homes will be required to be affordable, except where: there can be a proportionate reduction as a result of vacant buildings being re-used or re-developed (as set out in national planning policy), the development is solely for Build to Rent, the development is for some types of specialist accommodation that fall within Use Class C2, or the development is solely for residential caravans. Further clarification is required as to which types of specialist accommodation that fall within Use Class C2 would be exempt in light of the Framework and Planning Practice Guidance.
Retirement Communities providing for Extra Care take the form of a “core building” and containing a mix of service and residential uses and surrounding purpose designed specialist accommodation.
The village core will provide a number of communal facilities focussed on facilitating wellness and typically comprise up to 25% of its floorspace as non-saleable space. This includes the communal and care facilities available to its residents. These facilities may vary from village to village but will always include a minimum level of communal provision.
The specialist accommodation will be carefully designed to incorporate features that allow for practical living for older people and the delivery of care and assistance safely within that setting, which can be increased over time as necessary.
The proposed site would provide a mixed-use development with part of the site including the following features which suggest that some of the site falls within Use Class C2:
• The development provides for specialist housing that caters for the specific needs of older persons
• The care village provides a wide range of communal facilities to promote physical and mental health and wellbeing, including a wellness spa, restaurant, meeting spaces/library, transport services, landscaped grounds, back offices and staff facilities
• The accommodation would provide for specialist features including level access, maximised natural daylight, internal room layout, connectivity to staff
• The development would provide specialist management services including a village manager, wellbeing navigator and reassurance response co-ordinated through the central reception;
• An extensive review process to identify Registered Domiciliary Care Providers to provide Personal Care to residents
• Restriction of use through a legal agreement so that units are only used for Class C2 purposes in perpetuity
In this regard, Integrated Retirement Communities which provide Extra Care housing fall within use Class C2 of the Use Classes Order.
For the reasons outlined above, the delivery of Affordable Housing on Extra Care sites is typically challenging, which is why paragraph 10-007-20190509 of the PPG states that viability may need to be considered on schemes where particular types of development are proposed which may significantly vary from standard models of development for sale (for example housing for older people). Whilst an initial purchase may be discounted, the ongoing service charge for access to the village’s services and facilities cannot be discounted. It would also not be possible to discount the cost of care for residents within units provided as affordable tenures. It is considered that these practical issues should be addressed within policy as otherwise it could be difficult to implement and be ineffective.
The integrated retirement community/Extra Care model predominantly operates on the sale of individual units as part of a managed development. Care packages are purchased either from the operator or by a third-party care provider. This differs from care homes which are sold or let to an operator with individual residents paying for their room, board, and care.
The integrated retirement community/Extra Care model also differs from more general development in that they incorporate a significant level of facilities which results in the net to the total gross floorspace being significantly poorer than in traditional/general housing needs. This means that such schemes have a substantially lower amount of saleable floorspace compared with traditional developments and such schemes will also require the additional costs of lifts and specially adapted bathrooms and other such facilities appropriate to the target age group and level of care.
At paragraph 10-007-20190509 of the PPG, it states that: “Where up to date policies have set out the contributions expected from development, planning applications that fully 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. Policy compliant in decision making means that the development fully complies with up-to-date plan policies”.
The PPG continues to outline that: “Such circumstances could include, for example, where development is proposed on unallocated sites of a wholly different type to those used in the viability assessment that informed the plan; where particular types of development are proposed which may significantly vary from standard models of development for sale (for example built to rent or housing for older people), or where a recession or similar significant economic changes have occurred since the plan was brought into force”.
The First Proposals set out that the Plan will be subject to a viability assessment at each stage of plan making, including a whole plan viability assessment that will accompany the draft plan and be updated at subsequent stages of plan making. It adds that current evidence indicated that securing 40% affordable homes is deliverable across Greater Cambridge taking account of other development costs assumed so far but will be kept under review as the plan progresses.
The Viability Assessment that supports this consultation, paragraph 2.45 sets out that the Council have appraised generic retirement living or sheltered housing schemes typically delivered by developers such as McCarthy and Stone or Churchill retirement living, and these have been included within the residential typology rather than a separate element which therefore means it becomes tied up with Class C3 for viability purposes.
It is considered that the evidence base has failed to assess the different typologies available for the provision of specialist housing for older people by only appraising generic retirement living or sheltered housing schemes. The evidence is not reflective of the viability of schemes which seek to deliver Extra Care provision. The Councils evidence should therefore assess a range of typologies including Extra Care schemes up to 200 units to consider the viability of these developments to come forward.
The Viability Assessment should also consider the provision of affordable housing on such type of schemes as it is often the case that Affordable Housing is unlikely to be viable for Extra Care schemes.
It is imperative that careful consideration is given to the forms of specialist accommodation which relate to older persons’ housing and the different types of accommodation that can be provided as these can vary significantly.

Paragraph 62 of the NPPF requires local authorities to assess the size, type and tenure of housing needed for different groups in the community and reflected in planning policies. The NPPF also sets out that as part of achieving sustainable development a sufficient range of homes should be provided to meet the needs of present and future generations.
The proposed policy direction notes that new housing development of 10 or more dwellings will be required to provide an appropriate mix of housing sizes with the proportions of dwellings of each size to be guided by the housing mix for each tenure and for Cambridge and South Cambridgeshire as set out in the recommendations from the ‘Housing Needs of Specific Groups – Addendum for Greater Cambridge (2021)’ or any future update to the Greater Cambridge Housing Strategy or housing mix evidence published by the Councils.
Whilst this policy is applicable to traditional Class C3 residential schemes, consideration should be given on a site-by-site basis in respect of C2 residential institutional schemes as it is not always appropriate or viable to provide larger 4- and 5-bed properties on such type of schemes.
As set out at paragraph 3.3 in the accompanying ‘Representation by Inspired Villages – to support the practical delivery of much-needed specialist accommodation to meet the needs of an ageing population’ (Appendix 1), a standard model for an Inspired Villages site is for approximately 150 units of accommodation comprising a mix of cottages, bungalows and apartments ranging from 1, 2 and 3-beds with some 210,000sqft of floorspace, of which, approximately 20-25% would be communal facilities.
The policy approach should therefore be sufficiently flexible to take account of current identified and projected need for specialist housing for older people and recognise that such type of schemes may not necessarily meet the housing mix specified for C3 residential schemes, acknowledging that they serve different requirements for different markets.

A separate policy H/SS: Residential Space Standards and Accessible Homes is included which is intended to set the required space standards and provide a policy direction on the proportion of accessible and adaptable dwellings to be provided as part of the dwelling mix on sites. This notes that the policy will require that all new homes will be required to meet Building Regulation M4(2) ‘accessible and adaptable’ dwelling standards and that 5% of affordable homes on development which include 20 or more affordable homes will be M4(3).
Unlike traditional residential development (Class C3), there are no prescribed National Space Standards for Class C2 schemes. However, the future developer/operator will provide a range of C2 units to meet the intended housing mix.
In the context of our client’s land at Comberton the proposed C3 residential element of the proposal would adhere to Building Regulation M4(2) ‘accessible and adaptable’ dwelling standards as well as the M4(3) requirements, resulting in provision towards the Council’s overall objectives to deliver accessible and adaptable general needs dwellings in addition to specialist housing for older people.

It is essential that the policies of the Greater Cambridge Local Plan set out a clear approach to support the provision of specialist housing for older people. It is a requirement of national policy and guidance that these policies are based on an up-to-date assessment of needs for specialist housing, as a central component of the housing needs of different groups.
The Government has recently published the Social Care White Paper “People at the Heart of Care” (December 2021). The White Paper emphasises the need to expand the choice of housing options available, stating that “today, too many people with care and support needs live in homes that do not provide a safe or stable environment within which care and support can be effective” and notes that specialised housing is likely to offer the best option for support.
The White Paper highlights that the projected demand for supported housing in England is estimated to increase by 125,000 by 2030 and therefore the provision of increased housing options, including specialised housing and the ability to adapt existing homes, is considered to be a key action to help deliver the visions of the Government. Part of achieving this vision includes the provision housing in the “Right Place, at the Right Time”, and there is an emphasis on the intrinsic link between social care and housing and how the care needs of communities need to be effectively planned to sustainably support the changing needs of local populations. To assist with this, over the next 3 years the Government intends to increase the supply of supported housing by supporting providers across the housing sector to develop more options for people in the private housing market.
(i) National Policy Context
National policy and guidance are clear in requiring local authorities to plan to meet the needs of older people and importantly, the PPG confirms that “where there is an identified unmet need for specialist housing, local authorities should take a positive approach to schemes that proposed to address this need” (Paragraph: 016 Reference ID: 63-016-20190626). The PPG also confirms that plan makers should evaluate the tenure, types and size of supply and current stock to assess whether future needs will be met, recognising that, “The need to provide housing for older people is critical as the proportion of older people in the population is increasing” (ID: 63-001-20190626).
The policies in both the current Local Plans which plan for the period from 2018 – 2031 are not sufficient to meet the rising need.
The NPPF updates the definition of Older People contained in the 2012 Framework to state: “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.”
Paragraph 14 contains the following requirement for Planning Authorities: “as a minimum, provide for objectively assessed needs for housing and other uses”.
A fundamental objective of the Framework is the delivery of a wide choice of high-quality homes. The NPPF states at Paragraph 60 that in order to: “support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.”
Paragraph 62 sets out that: “The size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies (including, but not limited to, those who require affordable housing, families with children, older people, students, people with disabilities, service families, travellers, people who rent their homes and people wishing to commission or build their own homes).”
Planning Practice Guidance relating to the Housing Needs of Older People was updated in July 2019 and applies to preparation of the Greater Cambridge Local Plan.
The PPG outlines that Local Authorities will need to count homes for older people as part of their housing land supply (Paragraph: 035 Reference ID: 68-035-20190722).
In the PPG Housing for Older and Disabled People (Paragraph 001) it states: “The need to provide housing for older people is critical. People are living longer lives and the proportion of older people in the population is increasing. In mid-2016 there were 1.6 million people aged 85 and over; by mid-2041 this is projected to double to 3.2 million. Offering older people a better choice of accommodation to suit their changing needs can help them live independently for longer, feel more connected to their communities and help reduce costs to the social care and health systems. Therefore, an understanding of how the ageing population affects housing needs is something to be considered from the early stages of plan-making through to decision-taking (our emphasis).”
In the PPG Housing for Older and Disabled People (Paragraph 001) it states: “For plan-making purposes, strategic policy-making authorities will need to determine the needs of people who will be approaching or reaching retirement over the plan period, as well as the existing population of older people”.
The PPG ‘Housing for older and disabled people’ highlights the advantages as: “Offering older people a better choice of accommodation to suit their changing needs can help them live independently for longer, feel more connected to their communities and help reduce costs to the social care and health systems. Therefore, an understanding of how the ageing population affects housing needs is something to be considered from the early stages of plan-making through to decision-taking.” (Paragraph: 001 Reference ID: 63-001-20190626).
In respect of the evidence to be considered when identifying the housing needs of older people, the PPG states: “The age profile of the population can be drawn from Census data. Projections of population and households by age group can also be used. The future need for specialist accommodation for older people broken down by tenure and type (e.g. sheltered housing, extra care) may need to be assessed and can be obtained from a number of online tool kits provided by the sector, for example SHOP@ (Strategic Housing for Older People Analysis Tool), which is a tool for forecasting the housing and care needs of older people. Evidence from Joint Strategic Needs Assessments prepared by Health and Wellbeing Boards can also be useful. The assessment of need can also set out the level of need for residential care homes.” (Paragraph: 004 Reference ID: 63-004-20190626)
The PPG sets out that a range of specialised provision is available but notes that any single development may contain a range of different types of specialist housing (Paragraph: 010 Reference ID: 63-010-20190626): “There is a significant amount of variability in the types of specialist housing for older people. The list above provides an indication of the different types of housing available but is not definitive. Any single development may contain a range of different types of specialist housing.”
The guidance makes it clear that Local Plans need to appropriately provide for specialist housing where a need exists (Paragraph: 012 Reference ID: 63-012-20190626): “Plans need to provide for specialist housing for older people where a need exists. Innovative and diverse housing models will need to be considered where appropriate.”
The guidance then goes on to state how plan makers will need to account for older people who wish to stay or move to general housing that is already suitable, therefore ensuring that general housing is also sensitive to the needs of an ageing population (Paragraph: 012 Reference ID: 63-012-20190626): “Many older people may not want or need specialist accommodation or care and may wish to stay or move to general housing that is already suitable, such as bungalows, or homes which can be adapted to meet a change in their needs. Plan-makers will therefore need to identify the role that general housing may play as part of their assessment.”
The guidance clearly demonstrates how older people should have a wide choice of options when moving to specialised housing. This will be done through plan-makers considering the size, quality and location of dwellings for older people in the future or for them to move to more suitable accommodation (Paragraph: 012 Reference ID: 63-012-20190626): “Plan-makers will need to consider the size, location and quality of dwellings needed in the future for older people in order to allow them to live independently and safely in their own home for as long as possible, or to move to more suitable accommodation if they so wish”.
The guidance sets out possible criteria for site selection. Despite this, some larger facilities may still be viable and attractive for older persons despite not being close to nearby facilities and amenities (Paragraph: 013 Reference ID: 63-013-20190626): “It is up to the plan-making body to decide whether to allocate sites for specialist housing for older people. Allocating sites can provide greater certainty for developers and encourage the provision of sites in suitable locations. This may be appropriate where there is an identified unmet need for specialist housing. The location of housing is a key consideration for older people who may be considering whether to move (including moving to more suitable forms of accommodation). Factors to consider include the proximity of sites to good public transport, local amenities, health services and town centres.”
There is little guidance on the matter of Use Class and makes no mention of the application or otherwise of affordable housing requirements to developments of specialised accommodation for older people (Paragraph: 014 Reference ID: 63-014-20190626): “It is for a local planning authority to consider into which use class a particular development may fall. When determining whether a development for specialist housing for older people falls within C2 (Residential Institutions) or C3 (Dwelling house) of the Use Classes Order, consideration could, for example, be given to the level of care and scale of communal facilities provided.”
The guidance states that the need for older persons housing should be met (Paragraph: 016 Reference ID: 63-016-20190626): “Where there is an identified unmet need for specialist housing, local authorities should take a positive approach to schemes that propose to address this need.”
(ii) Evidence Base for the Councils’ Proposed Approach
Whilst policy H/SH: ‘Specialist Housing and Homes for Older People’ includes guidance for specialist housing designed to support a variety of groups such as older people, disabled people, people with alcohol or drug dependency, those requiring refuse from harassment and violence, and others who may, for a variety of reasons, be excluded from the local community, this is primarily in the context of provision as part of the general housing mix of new developments to be provided at new settlements and within urban extensions.
The Plan at this stage does also refer to a criteria-based policy similar to that in the adopted Cambridge Local Plan 2018, and the need to ensure that new specialist housing is provided where there is a need, in suitably accessible locations and without resulting in an excessive concentration of such housing. However, this only goes a limited way towards meeting need and there appears to be no current allocations or sites proposed that are specifically defined/safeguarded for older persons housing needs.
Paragraph 8.61 of the ‘Housing Needs for Specific Groups report 2021’ identifies that over all areas assessed within the study there is a significant shortfall of leaseholder housing with support (retirement housing) and also shortfalls of housing with care (i.e., Extra Care and Enhanced Sheltered) for both leasehold and rental tenures.
It is noted that the evidence provided by GL Hearn in the ‘Cambridgeshire and West Suffolk Housing Needs of Specific Groups study (August 2021)’ has been produced to examine the need for specific housing for the 2020 – 2040 period. Section 8 of this evidence provides information on Older and Disabled Persons.
It is noted that the assessment began with the Housing Learning and Improvement Network (LIN) SHOP@ baseline online toolkit for Housing with Care (to include both enhanced sheltered and extra-care housing) of 45 units per 1,000 population aged 75 (comprising 22.5 units per 1,000 as leasehold and rental respectively). The version of the toolkit adopted for comparison purposes in the GL Hearn Evidence comprises the projected “base case” demand at 2030 scenario from the 2013-based ‘Delivering the Detail’ version of toolkit assumptions.
No reference is made to the 2011 version of the SHOP@ Resource Pack which forecast greater representation within the ‘Housing with Care’ component of the sector. More detailed justification for the same assumptions was incorporated with the publication Housing in Later Life: planning ahead for specialist housing for older people, Housing LIN, NHF et al, December 2012. Both sources reflect strong growth in the demand for leasehold retirement housing and the emergence of the Extra Care sector specifically as informing measures to deliberately invert current levels of provision by tenure and to accelerate a shift from policies heavily reliant on traditional are home provision. The equivalent prevalence rate for ‘Housing with Care’ under these sources comprises 65 units per 1000 persons aged 75+, distributed as follows:
• Extra Care Housing: 45 units per 1,000 (30 leasehold; 15 rented)
• Enhanced Sheltered: 20 units per 1,000 (10 leasehold; 10 rented)
However, it is then noted that adjustments were made to this baseline based on evidence concerning the reflective health of the local older population in comparison to the national average which has decreased the prevalence rate by an average of 8% across the Housing Market Area and an estimate of tenure split for housing with support and housing with care (with more affluent areas expecting a higher proportion of specialist housing to be market sector).
The GL Hearn Evidence for Greater Cambridge results in an equivalent prevalence rate for ‘Housing with Care’ of 40 units per 1,000 persons aged 75+ (a reduction of 5 units per 1,000 compared to the 2013 SHOP@ baseline or 25 units if the ‘Housing in Later Life’/SHOP Resource Pack benchmarks are applied.
The rationale for making adjustments to any of the toolkit benchmarks referred to above are summarised in Paragraphs 8.45 and 8.50 – 8.52 of the 2021 Housing Needs of Different Groups Study but these are not justified in isolation.
Paragraph 8.46 identifies the ‘Assessment of Need for Specialist Housing for Older People in Greater Cambridge (Centre for Regional Economic and Social Research (CRESR), November 2017)’. The methodology adopted in the CRESR analysis was not driven by specific outputs for requirements for specialist older persons housing by tenure but did apply assumptions regarding the preferences of older homeowners. The foundation of the methodology adopted in that analysis was to take the median level of current provision of Specialised Accommodation for older people across the one hundred English housing authorities with the highest levels of provision of such accommodation and establish that as the “norm”. Its application to the population of Greater Cambridge was then moderated by considering a number of demographic, social and economic factors that might indicate a variance from the norm.
The model sought to increase the supply of care beds while barely increasing provision for Extra Care and Enhanced Sheltered units. The model also favoured increasing the supply of sheltered housing, which comprises a component of provision of specialist housing for older people less well-suited to meeting needs of an increasing ageing population experiencing greater frailty in later years following retirement. This assumption on the preferences for specialist housing within leasehold tenure is also incorporated within the GL Hearn evidence base.
Care must therefore be taken when comparing the total provision anticipated in the CRESR and subsequent GL Hearn Evidence Base per head of population against other benchmarks per head of population aged 75+. While overall levels may be similar (162 per 1,000 CRESR and 153 per 1,000 in GL Hearn versus 170 per 1,000 in the SHOP@ 2013 baseline) assumptions about the forms of accommodation and care and the tenure profile of that accommodation that will constitute an appropriate strategic response differ markedly.
The CRESR model itself recognises the need for further consideration of the proportion of needs that could more appropriately be met through provision for Extra Care: “Comparing our model’s estimates against those from SHOP@ reveals a very similar estimate of current ‘demand’ for specialist housing (3,422 in our model versus SHOP@’s 3,554) and care beds (2,152 beds in our model versus SHOP@’s 2,299). However, there is a distinct difference between the two models in term of the forms of specialist housing supply required. SHOP@ suggests enhanced sheltered and extra care units should make up approximately one in five specialist units [rising to approximately 1 in 4 within the SHOP@ 2011 and ‘Housing in Later Life’ benchmarks]. Hence it identifies significant deficits in the current supply of extra care and enhanced sheltered accommodation in Greater Cambridge. On the other hand, our model suggests only one in 10 of the recommended supply of specialist units in Greater Cambridge are either enhanced sheltered or extra care. This reflects the fact that our modelling is premised on existing provision in authorities with a high level of overall supply, and where extra care provision may vary in scale. As discussed in Chapter 5, if it is decided that extra care can meet a greater proportion of needs that are currently met in other areas of the system (e.g., in residential care), then this could dramatically change how many units of extra care are required. In addition, future changes in the health of the local population may affect projections for extra care in significant ways.”
The ‘Housing Needs of Specific Groups – Greater Cambridge Addendum’ published in September 2021 considers the up-to-date evidence of housing need in Cambridge and South Cambridge specifically. The addendum notes that the population aged 65+ is projected to see the highest proportionate increase in population.
The current development plan provision for specialist housing for older people falls well below that needed to address the requirements of national policy and guidance despite evidence of the rising need with the projected growth of approximately 55% between 2020-2040 across the HMA.
This work identified the shortfall in housing with care needed in Greater Cambridge when considering housing growth in line with the Council’s ‘medium’ objectively assessed housing need scenario (without prejudice to these representations on housing need). In the Council’s Topic Paper 7 (Housing) this scenario is summarises that the shortfall would be 802 units (leaseholder) considering a demand per 1,000 population of 23 units and 337 (rented) considering a demand per 1,000 population of 17 units as shown in Table 34 of the Final Addendum. A previous draft version of the addendum transposed these figures and incorrectly showed a lower leaseholder shortfall.
Critically, given the departure from established benchmarks and despite the comparisons with the SHOP@ toolkit produced in the CRESR Report, the most recent evidence does not continue to provide up-to-date assessments against relevant alternatives including the ‘Housing in Later Life’ benchmarks for Extra Care or all ‘Housing with Care’ categories.
The Council acknowledges a forecast shortfall in leasehold Housing with Care of at least 802 units at 2041. Table 1 below summarises these comparisons, indicating that under the Councils’ own scenario for housing need the forecast shortfall in leasehold ‘Housing with Care’ is substantially greater – between 780 to 1460 units. This specifically includes a shortfall of at least 1,072 units against the standalone benchmark for Extra Care provision within the SHOP@2011 and ‘Housing in Later Life’ benchmarks.
(iii) Soundness of the Councils’ Proposed Approach
The Council’s Preferred Approach cannot be considered sound. It is clear that further work needs to be undertaken to assess the full scale of need within Greater Cambridgeshire. The following sub-section demonstrates that the approach is not justified; not positively prepared; not consistent with national policy and guidance and not effective. Without prejudice to any future detailed assessment to be prepared on behalf of our client these representations provide a critique of the Council’s approach to demonstrate that the need is greater than the Council’s current evidence supporting the Local Plan proposals suggests.
The Council’s own Topic Paper presents no statement that the First Options proposals intend to provide policies that will meet in full needs for the type and tenure of specialist housing for older people, including against the Council’s own assessment of need. The scope for further work identified is extensive, indicating ongoing activity to amend forecasts of future provision and approaches to the delivery of care. The Councils accept that this may further inform their preparation of planning policies. These representations strongly assert that the provision of increased levels of Extra Care accommodation must form an important component of emerging objectives identified in the work, including supporting independent living and care tailored to individuals’ needs over their lifetime.
It is clear that the estimate of needs for Extra Care in the Housing Strategy are lower than those used in other relevant sources including the @SHOP Analysis Tool which is referred to in Planning Practice Guidance.
The figure of 45 units per 1000 persons comprising specific provision for Extra Care set out in Housing for Later Life has been considered to be a ‘very modest’ assumption in recent Appeal Decisions (PINS Ref: 32658614 – paragraphs 39 and 108) as it reflects just 4.5% of the population of people 75 years of age and over and primarily resulting from the lack of this type of accommodation available. It should be noted that when considering ‘Housing in Later Life Toolkit’ the total ratio for provision for enhanced and extra care housing (which has been grouped in the Greater Cambridgeshire evidence) is a provision of 65 units per 1,000 population.
The Addendum acknowledges that in every demographic growth level option considered, it is estimated that by 2041 there will be a shortfall of both rented and leaseholder housing with care (both extra care and enhanced sheltered accommodation).
It is noted that some of the strategic sites included in the Councils’ adopted Local Plans (2018) do include some provision for specialist accommodation however, delivery of these homes is not definitive as in the majority of the examples provided no information on the actual number of C2 units to be provided is evidenced and in some cases the strategic sites are not delivering any provision.
As a result, there is no attempt within the Councils’ Topic Paper 7 to quantify the identified provision in terms of its potential contribution to reducing forecast shortfall to 2041 as set out in Table 1 above. The Council has provided no other details of any development pipeline available to address the current identified shortfall in 2020.
As set out above it is critical that the Local Plan Review provides a clear approach to meet the needs for specialist older persons housing and recognises the wider benefits of this form of provision. The recent Appeal Decision on land at Little Sparrows, Sonning Common, Oxfordshire (PINS Ref: 3265861) provides a clear example of reasons to ensure that the development plan is not ‘left wanting’ in terms of addressing the need for Extra Care (see paragraph 31). In the Appeal case this reflected a failure to prescribe particular levels of provision by type of accommodation, nor policies to address the need for each notwithstanding the critical need for Extra Care.
This was a situation compounded in South Oxfordshire as a result of the ‘generic approach’ to provision by accommodation type and also that the characteristics and prospects for delivery of specific types of provision within the District’s strategic sites expected to comprise the main source of potential supply. The First Proposals for Greater Cambridge are exposed to the same risks as a result of the reliance on urban extensions and new settlements to meet needs for specialist older persons housing.
It is also relevant to note that in considering the delivery of Extra Care schemes the Inspector (paragraph 117) stated that undoubtedly Extra Care housing operated in a very different market and Extra Care housing providers cannot compete with house builders or with other providers of specialist housing for older people because of the build costs, the level of the communal facilities and the additional sale costs including vacant property costs. The inspector goes onto state: “It seems to me that these factors, all mean that age restricted developments and in particular extra care communities are less viable than traditional housing schemes. Ultimately, age restricted developers are less able to pay the same price for land as residential developers and it is much harder for age restricted developers, and in particular those seeking to deliver extra care, to secure sites for development and meet the housing needs they aim to supply.” (Paragraph 118)
In Paragraphs 121 and 122 the inspector highlights other benefits the scheme would deliver, each of which form relevant considerations for the policies of the Local Plan Review and objectives for sustainable development. These included:
a) Contributing to the overall supply of housing;
b) Savings in public expenditure (NHS and adult care);
c) Creating new employment and other economic investment (construction and operation);
d) Providing new facilities and services further reinforcing the role and function of settlements; and
e) Additional net revenues from Council tax and new homes bonus receipt.
The benefits to individuals and to the Public Good of facilitating a pattern of provision in which ever increasing dependence on Registered Care Home beds is mitigated by an expansion of housing-based care units, such as Extra Care, are well documented.
Gains are principally found in benefits to the Health and Social Care economy and the more effective and efficient use of the stock of general housing. Whilst the majority of older people will continue to live in general housing for the minority identified in our model specialised accommodation will provide a better quality of life and a better match to their needs.
The provision of a more adequate supply of Extra Care for homeowners will provide an environment of choice in which independence can be sustained and transfer to scarce Registered Personal Care Home beds and expensive Registered Nursing Care Home beds postponed or avoided. The development proposed for our client’s land at Comberton will help create a more adequate level of provision for older homeowners and contribute to a more equitable pattern of provision overall.
As identified at paragraphs 5.3 of the ‘Representation by Inspired Villages – to support the practical delivery of much-needed specialist accommodation to meet the needs of an ageing population’ (Appendix 1), the Housing Learning and Improvement Network (LIN) considers that the later living market needs to be made both acceptable and financially viable to enable older people to move from unsuitable accommodation (too large to manage, costly to maintain, poorly located or ill-equipped to deal with changing needs), to better, thoughtfully designed homes in sought-after places.
Frequently local planning authorities overlook the Extra Care model, particularly the scale of an Integrated Retirement Communities (IRC) and instead focus on retirement housing or care homes.
The ‘People at the Heart of Care: Adult Social Care Reform’ White Paper (December 2021) also talks about making every decision about care a decision about housing with the importance of housing and delivering the right housing in the right places being a key theme.
Many retirement living operators find it difficult to compete against the major house builders and smaller operators e.g. McCarthy and Stone when it comes to those sites identified for an element of retirement living as part of wider allocations, and more than often, the size of the site isn’t of sufficient scale for such type of proposals.
It is therefore essential that authorities recognise the different models which exist and plan to meet each of their respective needs.
The site at Branch Lane and Long Lane, Comberton is available to provide high-quality Integrated Retirement Community which provides Extra Care housing to address the need for specialist Extra Care housing for older people whilst also providing open green spaces and community facilities to support the development. The site is sustainably located with good links to existing services and facilities in Comberton as well as links to local bus services and the proposed Greenway to Cambridge, which will provide further sustainable transport options.
The PPG endorses the certainty that can be provided through the allocation of sites to deliver specialist housing for older people including in circumstances where there is an identified unmet need. Relevant considerations including access to health services, public transport and local amenities (ID: 63-013-20190626) together with the proximity of town centres. Age friendly design can also enhance the accessibility of housing for older people and improve the quality of place (ID: 63-018-20190626).
The Extra Care proposals for our client’s site at Comberton perform well against these considerations, which are not accurately considered in the Council’s assessment proforma in terms of recognising the opportunity to deliver specialist housing for older people at this location. Given the substantial uncertainty regarding the scale and nature of provision for these uses at the Councils’ existing and proposed new settlements and urban extensions the HELAA should reflect that other locations sustainably related in relation to the main settlement of Cambridge (in terms of proximity and connections) are likely to perform similarly or better in terms of their potential suitability to meet identified needs.
The policy approach being pursued by the Greater Cambridgeshire Local Plan should therefore reflect the need for site specific allocations for older-persons housing need rather than relying on the larger sites to make provision for such types of housing.

This policy defines that settlement boundaries will be identified around existing settlements and planned new development outlined in the Plan. It is proposed that boundaries would take into account the existing built-up areas but will not normally include buildings associated with countryside uses, such as farm buildings nor development which is detached from the main concentration of buildings in an existing area.
It is also proposed that outside defined settlement boundaries that no development would be permitted except for:
• allocations within Neighbourhood Plans that have come into force;
• Rural Exception Sites which help meet local needs for affordable housing;
• development for agriculture, horticulture, forestry, outdoor recreation and other uses that need to locate in the countryside; or
• development supported by other policies in the plan.
This policy limits the opportunity for suitable sites on the edge of settlements to come forward that can meet the needs of Extra Care development where it is required, and which can effectively tackle the known affordability crisis in the district. This policy needs to ensure that affordable housing is delivered quickly and in areas in which it will support the local community. PPG notes that ‘A wide range of settlements can play a role in delivering sustainable development in rural areas, so blanket policies restricting housing development in some types of settlement will need to be supported by robust evidence of their appropriateness.’ (Paragraph: 009 Reference ID: 67-009-2019072)
As outlined above, there is a defined current and future substantial unmet need for specialist housing. The current need of specialist housing is rising, and it is unlikely that this need will be met at urban extension or within new settlements, which are likely to come forward in the later parts of the plan period. Given the overall demand for housing in Greater Cambridge and the inflexibility of the Councils’ overall strategy the nature and extent of supply in these locations is such that operators within the specialist older persons housing sector face extreme pressures of competition in securing development opportunities. This is an issue exacerbated in circumstances where the limited provision that exists (in some cases) as part of committed developments fails to meet the operational requirements of the sector in terms of scale and scope to deliver a full and comprehensive range of services to residents as part of the Extra Care model.
Consideration should therefore be given to the release of such sites for development beyond sustainable settlement envelopes such as land at Branch Road and Long Lane, Comberton.

NPPF paragraphs 174 - 188 outline how planning policy and decisions should contribute to and enhance the natural environment where possible.
The Environment Act 2021 introduced new mandatory requirements for provision of biodiversity net gain and outlines the requirement for developments to provide a minimum of 10% net gain, it is expected that this will apply to all developments from 2023 pending secondary regulations coming into force.
This policy outlines the approach to be taken to biodiversity and geodiversity impacts from development. It is proposed the development will be required to achieve a minimum of 20% biodiversity net gain and notes that net gain calculations should be submitted using Defra Biodiversity Metric 3.0 or its successor. The policy notes that onsite provision of biodiversity net gain will be sought were possible but that off-site habitat measures will also be considered where appropriate and where consistent with strategic aims of the Plan as set out in Policy BG/GI. In these circumstances the Council’s proposed policy approach should be amended to reflect that the LPA will work proactively, positively, and collaboratively with landowners and relevant bodies to bring off-site enhancement measures forward in line with the delivery of development to ensure that the benefit to the community is clearly delivered.
The site proposal at Comberton includes measures to provide net biodiversity gain on site through the enhancement of existing landscape features on site and the provision of green open spaces throughout the site. The majority of the site is currently characterised as open farmland which are defined by hedgerow boundaries. Located to the west of the site is an area of woodland and a ditch runs along the south-west boundary. To the north of the site lies open countryside. There are therefore a number of opportunities available to provide biodiversity net gain measures on this site. Existing hedgerows which border the site would be retained and enhanced to strengthen the green edges of the site, new tree planting will be incorporated into a green corridor and will form part of the boundary treatment to screen the development from the wider countryside. It is also proposed that the swales and drainage basin which would be provided as part of the Sustainable Drainage System (SuDS) within the site would enhance the existing watercourse within the site and provide functional landscape features to improve the ecological and environmental benefits for local wildlife.
The allocation of the site at Comberton would allow for both the creation and connection of green spaces. The creation of both new green and blue corridors, green open spaces within the site and enhancement of the boundary features will improve the biodiversity value of the site.

This policy seeks to ensure that development proposals increase tree canopy cover, enhance treescape and protect existing trees of value. The proposals outlined in this policy are supported and provision of new tree planting, as detailed above, form a central aspect to the development proposed at Comberton to support biodiversity net gain and the enhancement of existing landscape features on the site.

This policy seeks to provide guidance on the provision of open scape required by new development. It is noted that both Councils have existing open space standards as set out in their current Local Plans which establish the quantity and accessibility of open space, on site provision and a guide to contributions required for off-site provision. It is proposed that a review of the standards will be undertaken to inform the draft plan to ensure that the standards are up to date.
The inclusion of a policy to support the delivery of new open spaces is supported however further clarity is required in due course as to how this will be calculated and what will be expected to be delivered on-site. The proposed development at the Comberton site would provide an opportunity to increase open space provision in the village with the creation of a central open space, which would be connected to the surrounding area through the enhancement of existing footpaths, to be a focal point of the new community and would be accessible to the existing community to improve social inclusion and cohesion.

The promotion of healthy living and the incorporation of health considerations into new developments is supported. If the site at Comberton were to be allocated this would provide a key opportunity to provide much needed specialist housing for older people in a sustainable location which would benefit the wider community and provide an integrated development with a mixed community to support social cohesion.
The provision of specialist housing is the central element to this proposal and provides an opportunity to support integrated living with the community rather than providing housing older people at the edge of settlements in urban extensions. The provision of community facilities within the site as well as the promotion of healthy lifestyles with enhanced pedestrian and cycle connectivity will improve the wellbeing of all residents in this location. A range of on-site services and facilities (e.g. café/bar, restaurant, small shop, hair salon, wellbeing centre, etc) which meet many of the day to day needs of existing and future residents would be delivered alongside the residential development proposed and would significantly increase the sustainability of the development and existing settlement.
The characteristics of Extra Care development (such as the provision of on-site services and facilities) should enable consideration of where this can contribute towards mixed and balanced communities and sustainable growth in rural areas (in accordance with NPPF2021 paragraph 79 and paragraph 92(a).

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.