SECOND ADDENDUM to PLANNING POLICY STATEMENT In support of an outline application for a Continuing Care Retirement Community on land north of Grovelands Way, Warminster. BA12 8TB.
on behalf of Ace Retirement (Warminster) Ltd and Durmast Ltd
The contents of this document must not be reproduced in whole or in part
without the written consent of Tanner & Tilley Development Consultants October 2017 JM/1147/031I
1.0 INTRODUCTION
2.0 FORM OF DEVELOPMENT
3.0 NEED
4.0 WIDER PUBLIC BENEFITS
5.0 BUNGALOWS
6.0 THE SEQUENTIAL TEST
7.0 THE EXCEPTIONS TEST
8.0 THE MEDICAL CENTRE
9.0 THE WEST WARMINSTER URBAN EXTENSION
10.0 CONCLUSION
APPENDICES Appendix 1 Carterwood Primary Catchment Area Plan Wiltshire Community Areas Plan (Figure 1.1 from Wiltshire Population 2011) Comparison Plan of Wiltshire Community Areas and Carterwood Primary Catchment Area Wiltshire Community Areas Population Estimates and Projections to 2026. Appendix 2 Definitions of older persons housing Need calculation Tables A, B and C. Appendix 3 Accommodation Search Listings EAC accommodation description reports – Chantry, Florence, Avonpark, The Courtyard Appendix 4 Spatial Planning Response Paper – 6th September 2017 Appendix 5 Housing Response Paper – 10th September 2017
1.0 INTRODUCTION
This addendum is produced in response to the Spatial Planning consultation response dated August 20917 and the subsequent meeting held at the Council Offices on 19th September 2017. It should be read in conjunction with the applicant’s Response Paper dated 6th September 20017 a copy of which is appended to this addendum at Appendix 4. Also submitted with this addendum are a research publication titled ‘Extra Care Housing – where do residents come from?’ by Associated Retirement Community Operators (ARCO) & Carterwood and a publication titled ‘Continuing Care Retirement Communities’ (CCRC’s) which was produced on behalf of the Joseph Rowntree Foundation and the Planning Officers Society as a national good practice guide on planning for CCRC’s. The former publication explores catchment areas for extra care and CCRC schemes. The latter publication answers many of the general questions being raised about the ethos, the sustainability, the viability and the delivery of a CCRC. Similarly many of these questions have already been addressed in submitted documents such as the Design & Access Statement, the Original Planning Statement and various rebuttal documents. However for clarity the points in relation to the proposed CCRC are set out in detail below.
2.0 FORM OF DEVELOPMENT
2.1 There is no absolute definition of a CCRC. In 2004 the Department of Health described CCRCs as large-scale extra care housing comprising ‘an all-embracing, comprehensive alternative to both sheltered housing and residential care providing for a range of needs and individual circumstances.’ The Housing LIN, previously responsible for managing the Department of Health’s Extra Care Housing Fund, defines a Retirement Village as “purpose built extra care within a larger retirement village concept with a range of dwelling types and facilities”. The attached ‘Continuing Care Retirement Communities’ publication describes innovative models of housing for older people stating: ‘These models aim to accommodate both ‘fit’ and ‘frail’ older people, providing socially supportive, stimulating environments (our emphasis) in which older people may live wholly independently, and also receive extensive care and support services when required. Rather than simply focusing on care and support, these models address a range of needs: quality of accommodation; opportunities for social interaction; affordability; and continued independence.’ It goes on to state ‘CCRCs have all the usual features of ‘extra care’ housing, together with a commitment to supporting the vast majority of people in that community irrespective of needs. They comprise groups of self-contained properties designed for older people all on one site.’ (our emphasis). It describes key features of a CCRC (paras 2.8 – 2.11) and indicators of suitable sites (para 4.14) the majority of which apply to the proposed CCRC as follows.
2.2 The proposed CCRC will provide a mix of accommodation, tenure, supporting communal facilities, supporting care packages and economy of scale.
2.2.1 The accommodation comprises of the following:
One and two bedroom self-contained apartments all with direct internal access to supporting communal facilities. Two and three bedroom self-contained terraced bungalows set in communal grounds and with access to the supporting communal facilities via the internal footpath network which also accommodates mobility scooters. Two and three bedroom detached bungalows with small manageable private gardens set within the communal grounds and access as above. Care bedrooms with en-suite bathrooms all contained within a care home building registered with the Care Quality Commission. A medical centre and pharmacy providing space for 16 clinical rooms.
2.2.2 The tenures will be as follows:
Private for sale on a minimum 125 year leasehold basis Affordable shared equity or rented.
2.2.3 The supporting communal facilities available to all residents comprise of the following:
Resident’s lounge and dining room within the private extra care building. Resident’s café and lounge within the affordable extra care building. Day Areas and Café within the care home building for residents and visitors. Guest rooms within the affordable and private extra care buildings. Hotel style reception entrance areas. A wellness suite and function suite within the private extra care building. Commercial kitchens and laundry within each building. Staff rooms, offices and sleepover rooms within each building. Mobility Scooter parking and charging
2.2.4 The supporting care packages are provided through service charges and will comprise of the following:
A minimum care package and service charge for all residents of bungalows and apartments to cover the costs of the following:
Domiciliary support (help with shopping and cleaning). On site manned 24 hour emergency call monitoring supported by experienced and qualified care staff. On site staff to facilitate and organise social activities and events. On site customer services staff providing reception and booking (concierge) services, resident’s access to on site services (care and wellness) and general administration. Hospitality staff (catering and laundry) Maintenance staff (buildings and grounds) Use of communal facilities for socialising, entertaining friends etc. Access to a subsidised meals service either within the dining/café areas or at home. Access to a maid service. Access to a laundry service. Availability of personal companion.
Additional options for different levels of personal care and support.
Pre-arranged nurse visits. Medication services. Assistance bathing. Transport to hospital etc. One to One care Overnight care End of life care 2.3 Economy of scale
2.3.1 It is a very simple calculation that the more residents available to contribute to the fixed overheads then the lower the cost will be for each resident or the more facilities/services that can be offered. Cost calculations were provided with the consultation response statement but clearly either the 91 apartments and bungalows or the 130 including the affordable extra care apartments make a significant reduction in costs compared to say a single extra care scheme of 50 units. Or they allow a wider range of facilities to be supported such as the wellness suite which would not be viable for a stand-alone scheme of 50 units. The bungalows are critical to this economy of scale because if say the alternative was 91 extra care apartments this would be too many apartments in one location. Clearly the bungalows give a choice and appeal to a wider market particularly couples where one person may be in more need of the care environment than the other. A bungalow within the CCRC allows the couple to stay together with accommodation and care suitable for their respective needs.
2.3.2 It should be noted that when developing the Wiltshire Housing Strategy many Registered Providers were supportive of the need specifically for CCRC schemes compared to stand-alone Extra Care schemes and that is directly as a consequence of the economies of scale that can be derived from having a larger community of end users who between them collectively contribute to and share the costs of the essential core service provision across a wider number of people.
2.4 The form of the development thus provides choices for older people in terms of accommodation and levels of care to suit their different needs and financial circumstances. It is essential for the accommodation to be on one site so that all of the residents can easily access the choice of accommodation, supporting facilities and services with the commensurate economy of scale. It is also important to understand that a CCRC is not just about the ‘bricks and mortar’, it is about the experiences and lifestyle that being part of the CCRC gives to residents and their relatives. Key benefits are as follows:
Safety and security not just through physical design but availability of on-site staff and living alongside like-minded people. Health and wellbeing. It is well documented that living within a care community contributes to maintaining the physical and mental wellbeing of residents. Social inclusion. The opportunity for companionship and social interaction both formally through organised clubs or activities and informally within communal areas. Community spirit. The mutual support that exists between residents creates a true sense of place and community spirit. Choice of care. The ability to tailor care packages as needs change either within a resident’s home, moving from a bungalow into extra care, a temporary stay in the care home or in the event of more serious need a permanent move to a care bed. Flexibility for couples. The accommodation and care packages can offer flexibility for couples where one person may still be relatively fit and active but the other has care needs.
This is also recognised in the Continuing Care Retirement Communities document at Paragraphs 6.9 – 6.12 and 6.18.
2.5 Notwithstanding the above it is true to say that whilst the proposed Medical Centre is very important to the CCRC because of accessibility being on the same site this is not essential provided that there is an alternative nearby. Similarly with the affordable extra care except for the fact that if an operator such as Registered Social Landlord (RSL) were to take on the whole development then they would benefit from the wider economy of scale of 130 units compared to 91. Or indeed as one RSL has already indicated with the affordable extra care on site they would prefer to enter into a catering contract with the private extra care and avoid the cost of a full commercial kitchen and catering staff within the affordable extra care which is financially challenging for only 39 units. Nevertheless it can be clearly seen that the location of the private extra care apartments, bungalows and care home are essential to be on one site.
3.0 NEED
There is a clearly identified and accepted need for this form of development within a circa 10-mile catchment area around Warminster. The majority of future residents will be drawn from the Warminster area. The catchment area is explained more fully in section 6.1 below but is derived from a market analysis by Carterwood and a map is included at Appendix 1. The Primary Catchment Area from this map extends to a circa 11.3 mile radius from the site and within this area there is a shortfall of extra care and enhanced sheltered housing after deduction of the current provision of 203 units as follows:
2017: shortfall of 497 units 2020: shortfall of 585 units 2026: shortfall of 713 units
Thus the overall need within this Primary Catchment Area is undeniable and significant enough to designate this area as the Sequential Test Area. The proposed development will make a valuable contribution to meeting this need in a sustainable location on the edge of Warminster. However, it should be noted that even after the deduction of the proposed 130 units at Grovelands Way (91 private and 39 affordable) there will still be a significant shortfall within the catchment area of 367 units in 2017, 455 in 2020 and 583 in 2026.
The above need shortfall is calculated using methodology contained within industry standard online ‘toolkits’ as recommended by Planning Practice Guidance (PPG 2014) for Local Authorities to provide robust assessments of housing need. The primary ‘toolkit’ used for this assessment is specifically for older persons housing need and is the ‘Strategic Housing for Older People (SHOP) analysis tool by Housing Lin. This document was submitted as part of the current planning application being attached to the response to the Housing Officers consultation. This response is attached at Appendix 5 and also includes relevant extracts from the PPG.
The SHOP tool needs prevalence rates to apply to population figures in order to calculate the need for a particular target group such as older people. In this instance the population group is for those aged 75 or over and the rates are taken from a second ‘toolkit’ produced by The Communities and Local Government in association with Care Services Improvement Partnership (CISP) called ‘More Choice, Greater Voice a toolkit for producing a strategy for accommodation with care for older people February 2008. A copy of this ‘toolkit’ is submitted with this planning addendum.
The prevalence rates are set out on Page 44 of the second ‘toolkit’ and are as follows: 20 units per 1000 population for Enhanced Sheltered Housing and 25 units per 1000 population for Extra Care Housing.
The housing need calculation derived from these prevalence rates and identifying the shortfall figures above is set out in Table A at Appendix 2. Whilst the shortfall is clearly significant it would also be substantially higher if the population group was extended to those aged 65 and over rather than 75 and over. The proposed CCRC at Grovelands Way will inevitably attract some from this younger age group given the provision of bungalows and therefore in reality the need for the CCRC is even greater than the shortfall identified above.
It should be noted that the above prevalence rates are higher than those used previously. This is because earlier assessment from the first planning application was more narrowly focused on one specific type of specialised housing for older people, namely Extra Care and for that the ratio applied to the population of the agreed Catchment Area aged 75 and over was set at the industry accepted prevalence rate of 30 persons per 1,000.
The change is, that as set out in Section 2.0 above, the residents of the bungalows and chalets are now inextricably linked into the overall envelope of the Extra Care regime being able to access the ‘hub’ central facilities provided within the main Private / Market Extra Care building together with the domiciliary and care services provided on site. All of which require these residents to contribute to the costs of provision through an annual service charge. As such the bungalows and chalets constitute ‘Enhanced Sheltered Housing’ as referred to in the PPG and ‘toolkits’. For reference the range of older persons accommodation as defined by the Elderly Accommodation Counsel (EAC) is attached at Appendix 2.
As noted above the shortfall figures take account of the existing supply of 203 units of Extra Care and Enhanced Sheltered accommodation. This supply is confirmed by a search of the Elderly Accommodation Counsel, First Stop on-line search engine (www.housingcare.org) for the subject site using its postcode of BA 12 8TB and setting a 20KM radius of the site (12.5-mile radius) of the site. This exceeds the Primary Catchment Area radius which aligns with postcode census information and hence it varies up to 11.3 miles as noted within the Map – see Appendix 1. The Current Supply schemes are summarised in Table A1 below which also indicates in the last column the type of accommodation of either Extra Care or Enhanced Sheltered housing. Two of the three schemes totalling 163 units fall within the ‘Enhanced Sheltered definition.
Table A1: Summary of Existing Supply of Extra Care / Enhanced Sheltered Housing Schemes with Catchment Area A Name and Address Operator Units Tenure Type Chantry Court, Westbury Quercus 64 L/H Sheltered / Enhanced BA13 3FE (Westbury) Ltd Sheltered Florence Court, Rutland OSJCT 40 L/H, S/O, Extra Care Housing Cres, Trowbridge BA14 0FH Rent (Social) Avonpark Village, Winsley Retirement 99 L/H Enhanced Sheltered Hill, Limpley Stoke, Bath Villages Ltd Housing Avon BA2 7FF Total Extra Care / Enhanced 3 203 Mixed Sheltered / Enhanced Sheltered Housing Schemes tenures Sheltered / Extra Care / Units
The Accommodation Description reports on each of the above Current Schemes, as downloaded from the EAC website search engine as abovementioned, is included within Appendix 3.
It is also evident from these searches that there is no difference in the Current Supply when comparing those that fall within the Leasehold and Shared Ownership categories to those that include these plus the Social for Rent Category for Enhanced Sheltered and Extra Care type schemes. A copy of each search record of the Accommodation Search Listings is included in Appendix 3.
An alternative assessment of need can be carried out using data from the Wiltshire and Community Area Population Estimates and Projections 2001 to 2026: Trend based 2011 Estimates prepared by Maggie Rae, Director of Public Health and Protection Services. From this document the Wiltshire Community Areas map can be compared with the Primary Catchment Area used above to identify the corresponding Community Areas. Population figures for these Community Areas can then be extracted from the same document for both those aged 65 and above or 75 and above to which the previous prevalence rates can be applied.
The Wiltshire Community Areas map is included at Appendix 1 together with the Primary Catchment Area map and a combined Comparison Map. For clarity a 10 mile radius from the site is also superimposed on this map. It can be seen that the 10 mile catchment radius and the Primary Catchment Area broadly correspond to the 4 Community Areas of Warminster, Trowbidge, Westbury and Mere. The extracted population figures for these Community Areas are set out in the tables at the end of Appendix 1.
The Net Needs for additional specialised housing accommodation of Enhanced Sheltered and Extra Care for these 4 Community Areas using the extracted population figures and the previous prevalence rates are as follows:
Aged 75 and above: Aged 65 and above:
2016: shortfall of 306 units 2016: Shortfall of 765 units 2021: shortfall of 373 units 2021: Shortfall of 853 units 2026: shortfall of 479 units 2026: Shortfall of 976 units
Thus as before the overall need within the designated catchment area is undeniable. For reference the housing need calculations identifying the shortfall figures above are set out in Table B and C at Appendix 2.
In each analysis described above of the Net Need for additional specialised Enhanced Sheltered and Extra Care it is clear that: - , 1) There is a current significant Net Need for additional units in the Warminster Primary Catchment Area of 497 units in 2017 rising to a substantial need for 713 units by 2026 based on the industry-wide prevalence rates applied to the population aged 75 and over. 2) There is a comparable significant Net Need for additional units within the 4 Community Areas of Warminster, Westbury, Trowbridge and Mere amounting to 306 units in 2017 and rising to 479 units by 2026 based on the industry-wide prevalence rates applied to the population aged 75 and over. 3) When considering the population aged 65 and over, the Net Need is even more substantial across these 4 Community Areas from 765 units in 2017 rising to 976 units by 2026. 4) Moreover, in each of the Needs Analysis Tables above, A, B & C there remains a significant balance of Net Need after the deduction of the proposed 130 private and affordable units at Grovelands Way.
The Need is established beyond doubt on each of these measures, and similarly endorses the selected Primary Catchment Area / Sequential Test Area.
4.0 WIDER PUBLIC BENEFITS
The proposed development brings wider public benefits as set out in the community benefits plan and text submitted with the planning application. These benefits are as follows:
Settling a 30 year dispute over the legal status of the land with regard to Public Open Space and maintenance thereof. Providing an additional 0.71ha of Public Open Space and a useable recreational area compared to the disputed historical S52 Agreement. Securing long term maintenance and management of the Public Open Space. Removing the conflict of existing agricultural use with surrounding residential development and public/informal footpaths crossing the land. Utilising a ‘unique’ site in a key Wiltshire town with the size and setting suitable for the provision of a CCRC but still easily accessible to the established town centre. Providing a choice of accommodation and care for older people in need. Enabling those people in need to stay within the community of Warminster where most will have lived all of their lives. Providing employment for up to 100 people in full and part-time positions. Releasing under occupied housing. Freeing residents and relatives from the stresses of providing family care and support. Providing a wide range of social and recreational facilities and activities which are available to residents, relatives and the wider community (by invitation/booking) alike thereby ensuring vitality in the CCRC with a spectrum of ages. Provision of affordable housing. The scheme will deliver 30% affordable housing in accordance with Policy CP 43. Whilst the applicants’ preference is for this to be delivered on-site if this is not feasible it can be facilitated elsewhere by way of a financial contribution. Providing for the relocation of the existing play area which has been deemed unsafe. Providing new 3m wide public footpaths/cycleways connecting Grovelands Way to the WWUE. It should be noted that without the proposed development there would be a gap of a muddy track following the line of the eastern public right of way between Grovelands way and the WWUE. Providing new adopted footpaths along the northern side of Grovelands Way. Providing two new bus shelters on Grovelands Way complete with real time information. Providing a much needed new state of the art public Medical Centre with room for expansion. Providing an on-site publicly accessible Pharmacy. Complementing the WWUE to provide a balanced community and opportunity for interrelationships with businesses in the new Local Centre. Provision of outreach services to contribute to meeting the care needs of the wider community Creation of a hub which could provide economic support to smaller retirement or extra care schemes in towns or villages that could not otherwise support such schemes.
5.0 BUNGALOWS
5.1 It is set out above how the proposed bungalows are essential to the success of the CCRC on a single site. They provide a wider choice of accommodation to satisfy the range of need, the residents have to subscribe to the minimum service charge and many will choose for additional optional services either at the beginning or as they become more frail and thus they contribute to the economy of scale/affordability of the development. They are not general market homes both for these reasons and also in terms of physical design. All bungalows including the chalet types have large ground floor bedrooms with en suite facilities capable of being provided with hoist access if required. They are fitted with the same features as the extra care apartments such as emergency call, wider doors, raised sockets and are designed to wheelchair mobility standards.
5.2 The bungalows as with the extra care apartments will be retained exclusively for older people in perpetuity by the minimum age restriction of 65 embodied in a planning condition. Also the financial support costs and physical design ensure that someone would not choose a bungalow within the CCRC unless they were in need of this lifestyle.
6.0 THE SEQUENTIAL TEST
6.1 The Search Area
As stated in the Spatial Team’s comments the search area corresponds to the catchment area from which the need is identified. In Section 3.0 above the need was clearly identified within a Primary Catchment Area extending to some 11.6 miles from the site as derived from a market analysis by Carterwood. The selection of this catchment area reflects research undertaken by Carterwood in association with the Association of Retirement Community Operators (ARCO) into where CCRC residents originate from. This research, ‘Extra Care Housing – where do residents come from?’ identifies on Page 2 that 70% of residents will come from within a 10 mile radius of a subject site. The need within this Primary Catchment Area was further endorsed by comparison with need assessed on corresponding Wiltshire Community Areas as also set out in Section 3.0 above.
All of this recognises that the catchment area for a CCRC is distinctly different than for say conventional housing. For the latter a prospective purchaser might be prepared to look at a very wide County area whereas for a CCRC the prospective residents largely do not want to move very far and wish to stay within the area that they have been living in for probably all their adult lives. A smaller number may be moving to be close to family already living in Warminster. Thus residents of Warminster and the immediate surrounding area wish to remain in the Warminster area as do those with family living locally and with neither wishing to look at a site elsewhere in Wiltshire even if one is available. Hence the strong need for extra care/CCRC accommodation in Warminster where there is currently no similar existing scheme.
Thus the selected Sequential Test Search Area matches the Primary Catchment Area where the Need is clearly identified.
6.2 Availability of Sequentially Preferable Sites
6.2.1 The Sequential Test carried out by CJS Planning identified no sites of a sufficient size to accommodate the development that were available in real world terms. If a site is not available in that there is no reasonable prospect of it delivering the proposed development it can be regarded as unsuitable. The concept of suitability has been tested through the courts. In the Supreme Court judgement in Tesco v Dundee City Council (2012) which referred to Lord Hope’ comment that the sequential test criteria “are designed for use in the real world in which developers wish to operate, not some artificial world in which they have no interest in doing so”. Of all the sites, potentially of a suitable size, evaluated in the Sequential Test none were available. For instance the large site in Westbury with the benefit of outline planning consent has been discounted by the submitted Sequential Test as it is not available in the real world. On enquiry with the current owners it is being sold for housing on an unconditional planning basis because of the extant outline planning permission.
6.2.2 It must also be recognised that CCRCs have specific site criteria over and above a conventional residential site in terms of surrounding environment, accessibility for staff and relatives and proximity to facilities for residents. Again the site in Westbury is an example as it is not a suitable site for a CCRC because of location being on the western edge of the town near to the railway line and a trading estate. Retirement schemes need to be located in pleasant residential neighbourhoods close to amenities and the Westbury site doesn't meet the criteria for retirement housebuilders or Care Village developers. Also, the town itself has a relatively small indigenous population, when compared to Warminster and it already has a leasehold (Market) scheme in a far better central location in the town.
6.3 Disaggregation
6.3.1 As stated above the whole ethos of a CCRC is to create a community of likeminded people. All of whom, including the bungalow residents, contribute via service charges to support the development. This cannot be achieved if individual components within the development were disaggregated onto disparate sites within the wider area.
6.3.2 Disaggregation has a significant impact on viability and the ability of service providers to deliver meaningful care and support to vulnerable older residents or to provide an extensive range of facilities such as a wellness suite. For example as stated above a stand-alone scheme of 50 extra care apartments would not be able to financially support a wellness suite leaving residents with reduced basic facilities.
6.3.3 It is clear that the integral nature of the CCRC provides a choice of accommodation, access to wider communal facilities, access to different levels of care and beneficial social interaction for older people all with a viable economy of scale in a sustainable location for which a single site is essential.
7.0 THE EXCEPTIONS TEST
The Exceptions Test calls for a balance between the public benefit derived from the development and the risk of flooding to the development. The wider public benefits are listed above and set against this is the minimal risk. The extent of the flood plain has been re-evaluated by the Environment Agency following modelling work undertaken by HR Wallingford. Whilst the western and eastern parts of the site, the Public Open Space, fall within Flood Zones 2 and 3 the central section containing the development will, following implementation of the development, be within Zone 1 and therefore outside of the 1 in 100-year flood plain. There will therefore be a minimal risk of any flooding.
8.0 THE MEDICAL CENTRE
8.1 It is widely accepted that there is a need within Warminster for new larger primary health care facilities even before the closure of the Smallbrook surgery and which has now further increased this need. The Planning Statement submitted with the planning application contained an email at the end of the document from Medcentres who have been instrumental in discussions with the NHS in relation to securing the future of primary care in Warminster of which the proposed new medical centre at Grovelands has been an integral part. Medcentres are well respected and experienced facilitators in the delivery of health care facilities for local GP practices. Working with the Ace team, similarly experienced in delivering such facilities within an extra care environment the proposed new surgery at Grovelands is deliverable and deliverable now.
8.2 In terms of location the site proposed is better related to the existing urban area and more accessible than that proposed within the local centre for the WWUE. In addition it can be delivered now whereas the local centre within the WWUE is unlikely to be developed for some time. It is also recognised that in reality there is capacity for two medical centres to serve the Warminster area.
9.0 THE WEST WILTSHIRE URBAN EXTENSION.
9.1 Achieving a mixed and balanced community is a central tenet of planning policy and is reflected in Policy CP45. The CCRC will be an important component in achieving this aim in the western part of Warminster. The emphasis in the West Wiltshire Urban Extension is on the provision of general needs housing. Whilst the Masterplan envisages an element of extra care it is questionable whether this will be delivered and in any event proportionately it would not achieve a balance that reflected the demographic breakdown of the population. Nevertheless the identified need set out in Section 3.0 above would still not be satisfied by both the proposed CCRC and the suggested 60 units on the WWUE.
9.2 In addition a new housing development is not a good location for either an extra care or CCRC scheme as realistically these need to be within established residential areas such as Grovelands Way. This is because the older residents clearly have a limited life expectancy and it is not reasonable to be living on a large building site in their final years. This is particularly relevant to the WWUE where the phased development of circa 1500 houses and the local centre will require ongoing construction for many years to come. So an extra care scheme on the WWUE would need to be planned towards the end of the phasing not now in contrast to the immediately deliverable CCRC proposal for Grovelands Way.
9.3 The communal facilities within the CCRC will be available to the wider community and will be of particular benefit to the future residents of the WWUE as well as the existing residents of the Grovelands Estate. Similarly, the future residents of the CCRC will use the facilities available within the Local Centre to be developed as part of the WWUE, thus enhancing the viability of those facilities.
9.4 The CCRC will complement rather than compete with the services to be offered in the proposed Local Centre, widen its market and thus enhancing its viability. Businesses within the Local Centre will be able to sell their services to the CCRC. For example the hair salons within the CCRC will not be fully staffed and instead are intended to be used by a hairdresser from an established local business visiting on certain days a week. Businesses will also be able to provide services within resident’s homes with the economy of being able to visit multiple residents on the same site.
10.0 CONCLUSION
10.1 The principle of a CCRC is in accordance with Core Strategy Policy CP46. It is accepted that there is a genuine and evidenced need for specialist housing for vulnerable older people in Wiltshire and within the catchment area for Warminster in particular. The CCRC is designed and managed to exclusively cater for the care needs of such people. It creates a close-knit community of likeminded people with communal facilities and care services provided to everyone. It is not open market housing and as such does not fall within Class C3 of the Use Classes Order.
10.2 There are no other available sites suitable for a CCRC within the catchment area of identified need in this part of Wiltshire. The CCRC is a single planning unit where the main purpose is the delivery of care to people in need of care.
10.3 For the reasons set out in the Planning Policy Statement and its addendums the proposals comply with Development Plan Policy and in accordance with Section 38(6) of the Planning and Compulsory Purchase Act 2004 planning permission should be granted.
SUPPORTING DOCUMENTS ‘Extra Care Housing – where do residents come from?’ by Associated Retirement Community Operators (ARCO) and Carterwood Continuing Care Retirement Communities’ (CCRC’s) which was produced on behalf of the Joseph Rowntree Foundation and the Planning Officers Society ‘Strategic Housing for Older People (SHOP) analysis tool by Housing Lin ‘More Choice, Greater Voice a toolkit for producing a strategy for accommodation with care for older people February 2008 by the Communities and Local Government in association with Care Services Improvement Partnership (CISP). APPENDIX 1
Wiltshire Population 2011
Wiltshire and Community Area Population Estimates and Projections 2001 to 2026: Trend based Note: Demand for Enhanced Sheltered is 20 units per 1,000 aged 75 and over, or 65 and over in the Tables below and 25 per 1,000 for Extra Care.
Warminster CA Trowbridge CA Westbury Age 2016 2021 2026 Age 2016 2021 2026 Age 2016 2021 2026 65-69 1,580 1,430 1,670 65-69 2,520 2,320 2,770 65-69 1,170 1,030 1,200 70-74 1,320 1,520 1,380 70-74 1,980 2,430 2,240 70-74 920 1,140 1,000 65-74 2,900 2,950 3,050 65-74 4,500 4,750 5,010 65-74 2,090 2,170 2,200 75-79 1,060 1,230 1,420 75-79 1,480 1,850 2,270 75-79 700 870 1,070 80-84 840 910 1,070 80-84 1,130 1,270 1,610 80-84 530 610 760 85-89 510 610 680 85-89 680 830 950 85-89 340 400 470 90+ 330 370 460 90+ 410 480 610 90+ 220 250 320 75-90+ 2,740 3,120 3,630 75-90+ 3,700 4,430 5,440 75-90+ 1,790 2,130 2,620 65-90+ 5,640 6,070 6,680 65-90+ 8,200 9,180 10,450 65-90+ 3,880 4,300 4,820
Mere Tisbury Bradford on Avon Age 2016 2021 2026 Age 2016 2021 2026 Age 2016 2021 2026 65-69 450 440 480 65-69 560 520 570 65-69 1,410 1,270 1,230 70-74 410 460 450 70-74 470 550 520 70-74 1,090 1,360 1,230 65-74 860 900 930 65-74 1,030 1,070 1,090 65-74 2,500 2,630 2,460 75-79 320 400 450 75-79 420 440 520 75-79 890 1,020 1,280 80-84 250 200 370 80-84 340 380 400 80-84 640 780 900 85-89 190 200 250 85-89 220 260 300 85-89 410 480 590 90+ 110 140 180 90+ 100 140 180 90+ 290 310 380 75-90+ 870 940 1,250 75-90+ 1,080 1,220 1,400 75-90+ 2,230 2,590 3,150 65-90+ 1,730 1,840 2,180 65-90+ 2,110 2,290 2,490 65-90+ 4,730 5,220 5,610
Combined Community Areas aged 75 and over Combined Community Areas aged 75 and over 2016 2021 2026 2016 2021 2026 Warminster 75-90+ 2,740 3,120 3,630 Warminster 75-90+ 2,740 3,120 3,630 Trowbridge 75-90+ 3,700 4,430 5,440 Trowbridge 75-90+ 3,700 4,430 5,440 Westbury 75-90+ 1,790 2,130 2,620 Westbury 75-90+ 1,790 2,130 2,620 Mere 75-90+ 870 940 1,250 Mere 75-90+ 870 940 1,250 Total 9,100 10,620 12,940 Tisbury 75-90+ 1,080 1,220 1,400 Demand - Enhanced Sheltered 20 Bradford on Avon 75-90+ 2,230 2,590 3,150 Demand - Extra Care 25 12,410 14,430 17,490 Total Demand - ES+EC 45 410 478 582 Demand- ES+EC 45 558 649 787 Current Provision 104 104 104 Current Provision 209 209 209 Net Demand 306 374 478 Net Demand 349 440 578
Combined Community Areas aged 65 and over Combined Community Areas aged 65 and over 2016 2021 2026 2016 2021 2026 Warminster 65-90+ 5,640 6,070 6,680 Warminster 65-90+ 5,640 6,070 6,680 Trowbridge 65-90+ 8,200 9,180 10,450 Trowbridge 65-90+ 8,200 9,180 10,450 Westbury 65-90+ 3,880 4,300 4,820 Westbury 65-90+ 3,880 4,300 4,820 Mere 65-90+ 1,730 1,840 2,180 Mere 65-90+ 1,730 1,840 2,180 Total 19,450 21,390 24,130 Tisbury 65-90+ 2,110 2,290 2,490 Demand - Enhanced Sheltered 20 Bradford on Avon 65-90+ 4,730 5,220 5,610 Demand - Extra Care 25 Total 26,290 28,900 32,230 Demand - ES+EC 45 875 963 1,086 Demand- ES+EC 45 1,183 1,301 1,450 Current provision 110 104 104 Current Provision 209 209 209 Net Demand 765 859 982 Net Demand 974 1,092 1,241
Current Provision of Extra Care / Enhanced Sheltered Location Operator Units Chantry Court, Westbury Quercus 64 Florence Crt, Trowbridge OSJCT 40 Avonpark Village, Bath Ret. Villages 99 Total Units 203 Close Care Units adjacent to Care Home Courtyard, Sutton Veny Sutton Veny 6
Total Enhanced Sheltered, Extra Care & Close Care Units 209 APPENDIX 2
The Elderly Accommodation Counsel classifications of housing for older people are as follows: -
Sheltered housing: Schemes / properties are included where some form of scheme manager (warden) service is provided on site on a regular basis but where no registered personal care is provided. A regularly visiting scheme manager service may qualify as long as s/he is available to all residents when on site. An on-call-only service does not qualify a scheme to be included in sheltered stats. In most cases schemes will also include traditional shared facilities - a residents' lounge and possibly laundry and garden.
Enhanced sheltered housing: Schemes / properties are included where service provision is higher than for sheltered housing but below extra care level. Typically, there may be 24/7 staffing cover, at least one daily meal will be provided and there may be additional shared facilities.
Extra care housing: Schemes / properties are included where care (registered personal care) is available on site 24/7.
Residential care: Where a care homes is registered to provide residential (personal) care only, all beds are allocated to residential care.
Nursing care: Where a care homes is registered to provide nursing care all beds are allocated to nursing care, although in practice not all residents might be in need of or receiving nursing care.
The bungalows and chalets that are now proposed within the CCRC application fall within the Enhanced Sheltered Housing Category as they have full access to the 24/7 staffing regime and the facilities within the main Extra Care hub.
Table A below using the ‘norm’ ratios per 1,000 of population persons aged 75 and over, of 20 and 25 for Enhanced Sheltered and Extra Care Housing respectively for Catchment Area A.
Table A: Demand for Private Extra Care and 2017 2020 2023 Enhanced Sheltered Units – Catchment Area A – applying the “norm” rates from: ‘More Choice, Greater Voice’. Population of people aged 75 and over 15,556 17,510 20,342 Demand based on Housing LIN Shop@ Toolkit & 311 350 407 ‘More Choice, Greater Voice’ prevalence ratio of 20 persons per 1,000 of the population aged 75 and over for Enhanced Sheltered Housing Demand based on 25 persons per 1,000 of the 389 438 509 population aged 75 and over for Extra Care Housing Total Demand for Enhanced Sheltered Housing and 700 788 916 Extra Care Housing Current Supply of Enhanced Sheltered and Extra 203 203 203 Care Housing within Catchment Area A Net Need / Shortfall of Enhanced Sheltered 497 585 713 Housing + Extra Care Housing within Catchment Area A Proposed Supply at Grovelands Way, Warminster 91 91 91 91 units private extra care / enhanced sheltered ( 46 apartments and 45 bungalows / chalets) Balance of Net Need after subject CCRC 406 494 622 development of 91 (apartments and bungalows / (497-91) (585-91) (713-91) chalets excluding Affordable Extra Care units Allowance for on-site Social / Affordable Housing 39 39 39 provision of Extra Care in accordance with Planning Policy and Housing Officer Consultation (first application) Advice Balance of Net Need after deduction of Private / 367 455 583 Market and Affordable Enhanced Sheltered Housing (bungalows and chalets) and Extra Care Housing (46 Market and 39 Affordable) within CCRC scheme
Note that in this Table (above) and those below we have deducted the current proposed private Extra Care and Enhanced Sheltered supply at the CCRC development at Grovelands Way as opposed to the original 50 private Extra Care units when the Planning Statement was first produced (for the first application).
Table B below uses the same ‘norm’ ratios as Table A above based on the population figures for the 4 corresponding Wiltshire Community Areas for persons aged 75 or above.
Table B: Demand for Private / Market Extra Care 2016 2021 2026 Units – Community Areas: Warminster | Westbury | Trowbidge | Mere – 4 No. Population of people aged 75 and over 9,100 10,620 12,940 Demand based on ratio of 20 persons per 1,000 of the 182 212 259 population aged 75 and over – for Enhanced Sheltered Demand based on ratio of 25 persons per 1,000 of the 228 265 324 population aged 75 and over for Extra Care Housing Total Demand for Enhanced Sheltered and Extra Care 410 477 583 Housing – summation of the above two rows Current Supply of Enhanced Sheltered and Extra Care 104 104 104 Housing within Catchment Area A Net Need / Shortfall of Extra Care / Enhanced Sheltered 306 373 479 Units Proposed Private / Market Extra care units including 91 91 91 apartments (46) and bungalows / chalets at Grovelands Way, Warminster site Balance of Net Need after subject CCRC development 215 282 388 excluding Affordable Extra Care units Allowance for on-site Social / Affordable Housing provision 39 39 39 of Extra Care in accordance with Planning Policy and Housing Officer Consultation (first application) Advice Balance of Net Need after deduction of Private / Market 176 243 349 and Affordable Enhanced Sheltered Housing (bungalows and chalets) and Extra Care Housing (46 Market and 39 Affordable) within CCRC scheme
Table C below uses the same ‘norm’ ratios as Table A above based on the population figures for the 4 corresponding Wiltshire Community Areas for persons aged 65 or above.
Table C: Demand for Private / Market Extra Care 2016 2021 2026 Units – Community Areas: Warminster | Westbury | Trowbidge | Mere – 4 No. Population of people aged 65 and over 19,450 21,390 24,130 Demand based on ratio of 20 persons per 1,000 of the 389 428 483 population aged 65 and over – for Enhanced Sheltered Housing Demand based on ratio of 25 per 1,000 of the population 486 535 603 aged 65 and over – Extra Care Housing Total Demand for Enhanced Sheltered and Extra Care 875 963 1,086 Housing applying above ratios per 1,000 of 65 + population Current Supply of Enhanced Sheltered and Extra Care 104 104 104 Housing within Catchment Area A Current supply of Close Care (Sutton Veny) 6 6 6 Total Current Supply of Enhanced Sheltered, Extra Care 110 110 110 and Close Care (bungalows) Net Need / Shortfall of Extra Care / Enhanced Sheltered 765 853 976 / Close Care Units Proposed Private / Market Extra care units including 91 91 91 apartments (46) and bungalows / chalets at Grovelands Way, Warminster site Balance of Net Need after subject CCRC development 674 762 885 excluding Affordable Extra Care units
Proposed On-site Affordable / Social Extra Care Housing 39 39 39 units – in accordance with Planning Policy and Housing Officer Consultation (first application) Advice
Balance of Net Need after subject CCRC development 635 723 846 including Affordable Extra Care units
APPENDIX 3
Chantry Court Manager: Chantry Lane, Westbury, Wiltshire, BA13 3FE. View on a map Manager: Quercus(Westbury) Ltd, Chantry Lane, Westbury, Wiltshire BA13 3FE Telephone: 01373 828828. Update
Type(s): Enhanced sheltered housing. Update info Add vacancies Properties: 68 flats, bungalows, cottages. Built in 2009. Sizes 1 bedroom, 2 bedroom, 3 bedroom.
Services: Retirement Village scheme with resident management staff (24 hours, 7 days) and community alarm service.
Facilities: lift, lounge, dining room, restaurant, laundry, guest facilities, garden, conservatory, activities room, cafe, hairdressing salon, bar/pub, library, assisted bathing facility.
Accessibility: Whole site accessible by wheelchair. Access to site easy. Distances: bus stop 200 yards; shop 100 yards; post office 1 mile(s); town centre 500 yards; social centre 500 yards.
Lifestyle: Social Activities include: Full events schedule, organised by Manager. Some meals available. New residents accepted from 55 years of age. Both cats & dogs generally accepted.
Tenure: Tenure(s): Leasehold and Rent (market).
Manager's Visit the website www.chantrycourt.com. notes:
Info updated: 13/02/2012.
Properties available Re-sale: a palatial 2 double bedroom penthouse which is wheelchair accessible and set within the small chantry court development. Offers in Excess of £350,000. Please contact our Retirement Homesearch sales team, as above. (Notified 14/08/2017).
Additional resources
Photos:
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Page 2 Created: 27/09/2017 10:20:19 Web link: http://www.housingcare.org/hc/link-info-159541.aspx Map link: http://www.housingcare.org/hc/link-map-159541.aspx
Created: 27/09/2017 10:20:19 Page 3 Florence Court Manager: Rutland Crescent, Trowbridge, Wiltshire, BA14 0FH. View on a map Manager: The Orders of St John Care Trust, Wellingore Hall, Wellingore, Lincoln LN5 0HU Telephone: 0800 988 8133 Memberships Email: [email protected].
Type(s): Extra care housing.
Properties: 40 flats. Built in 2011. Sizes 2 bedroom.
Services: Extra Care scheme with on-site care staff, non-resident management staff (24 hours) and community alarm service.
Facilities: lift, lounge, dining room, guest facilities, garden. Update
Lifestyle: Scheme for, or of particular interest to: residents of Trowbridge or Update info have a local connection. New residents accepted from 55 years of Add vacancies age.
Tenure: Tenure(s): Rent (social landlord) and Leasehold and Shared Ownership.
Manager's Florence Court is located on the outskirts of the county town of notes: Trowbridge. This modern building comprises 40 two-bedroom luxury apartments designed for independent living with the reassurance of care and support from our professionally trained, friendly staff team.
The apartments have a spacious lounge/dining area, with adjoining modern kitchenette area. The "wet room" style bathroom is equipped with hand rails, a shower, wash hand basin and toilet, and is accessible from both the master bedroom and the entrance foyer of the flat.
The scheme has a beautifully decorated lounge and dining area, with meals being provided by an outside caterer; and the lounge opens out on to a large patio area and landscaped gardens. There is also a hairdressing salon, an activities room, and a shop, proposed cinema room; while events take and activities occur on a regular basis; such as Coffee Mornings, church services, music and seasonal celebrations.
Care provider: The Orders of St John Care Trust.
Info updated: 02/04/2013.
Created: 23/09/2017 15:44:28 Page 1 Properties available Check with Manager above - none notified to EAC.
Additional resources
Care service http://www.cqc.org.uk/location/1-252257173 inspection report:
Photos:
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Created: 23/09/2017 15:44:28 Page 5 Avonpark Village Manager: Winsley Hill, Limpley Stoke, Bath, Avon, BA2 7FF. View on a map Manager: Retirement Villages Ltd, 1st Floor, Brunswick House, Regent Park, 297-299 Kingston Road, Leatherhead, Surrey KT22 7LU Memberships Telephone: 01372 383 950 Email: [email protected].
Type(s): Enhanced sheltered housing, Close care housing. Update Properties: 99 flats, cottages. Built in 1994 and renovated in 2011. Sizes studio, 1 bedroom, 2 bedroom, 3 bedroom. Includes mobility and Update info wheelchair standard properties. Add vacancies Services: Extra Care scheme with on-site care staff, non-resident management staff (24 hours).
Facilities: lift, lounge, dining room, restaurant, laundry, guest facilities, garden, conservatory, activities room.
Accessibility: Access to site fairly easy. Distances: bus stop 200 yards; shop 0.5 mile(s); post office 0.5 mile(s); town centre 2 mile(s); social centre 2 mile(s).
Lifestyle: Frequent Social Activities include: bridge, concerts, visiting speakers, drink parties, excursions to theatres and places of interest, shopping trips, organised by management. Some meals available. New residents accepted from 55 years of age. Both cats & dogs generally accepted.
Tenure: Tenure(s): Leasehold and Rent (market).
Cost: Re-sale prices from around £135,000 (studio), £180,000 (1 bed), £245,000 (2 bed), at Nov 2016.
Manager's Avonpark Village has been established as a community in its own notes: right, and part of the wider community around Bath, for more than a decade. Since its acquisition by Retirement Villages Ltd in 2010 Avonpark Village has undergone an extensive programme of modernisation externally and internally. Staff remain dedicated to providing an excelllent level of care, support and service to all residents. The facilities include a convenience shop, restaurant, lounge, conservatory, activity room, hair salon, and regular GP surgery. Properties are independently owned. Some offer supported living/close care. Care and support can be bought in when required.
Created: 26/09/2017 18:34:40 Page 1 Care provider: Village Community Care Limited.
Info updated: 02/07/2012.
Properties available Check with Manager above - none notified to EAC.
Additional resources
Care service http://www.housingcare.org/downloads/facilities/care-service-inspection-reports/... inspection report:
Photos:
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Page 4 Created: 26/09/2017 18:34:40 Web link: http://www.housingcare.org/hc/link-info-82179.aspx Map link: http://www.housingcare.org/hc/link-map-82179.aspx
Created: 26/09/2017 18:34:40 Page 5 The Courtyard Manager: Sutton Veny House, Sutton Veny, Warminster, Wiltshire BA12 7BJ. View on a map Manager: Sutton Veny House Ltd, Sutton Veny House, Sutton Veny, Warminster, Wiltshire BA12 7BJ Telephone: 01985 840224. Update
Type(s): Age exclusive housing, Close care housing. Update info Add vacancies Properties: 6 bungalows. Built in 1997. Sizes 1 bedroom, 2 bedroom. Includes mobility and wheelchair standard properties.
Services: Community alarm service.
Facilities: Garden.
Accessibility: Access to site easy. Distances: bus stop 150 yards; shop 2 mile(s); post office 2 mile(s); town centre 4 mile(s); GP 2 mile(s); social centre 2 mile(s).
Lifestyle: Regular social activities include residents can attend the activities at Sutton Veny House free of charge, if they wish. Some meals available (all meals are available at the care home if needed at a charge). New residents accepted from 65 years of age. Both cats & dogs generally accepted (with written permission).
Tenure: Leasehold.
Manager's Village setting in 25 acres of grade 2 listed country house. Personal notes: care plans adapted to suit individual needs.
Care provider: BML Healthcare Ltd.
Info updated: 05/08/2008.
Properties available Check with Manager above - none notified to EAC.
Additional resources
Photos:
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Page 2 Created: 07/03/2013 22:30:11 Web link: http://www.housingcare.org/hc/link-info-82923.aspx Map link: http://www.housingcare.org/hc/link-map-82923.aspx
Created: 07/03/2013 22:30:11 Page 3 APPENDIX 4
Spatial Planning - Response to Officer Consultation Date: August 2017 Planning application: 17/05360/OUT The comments of Wiltshire Spatial Planning can be summarised as follows: 1. The evidence of need for the type and amount of specialist accommodation proposed should be discussed with the Council’s housing and adult and social care teams, to determine whether criteria vii of CP46 is satisfied in this regard.
In response: In commenting on the previous scheme (16/08425/OUT) the Housing Commissioning Team identified a need for additional Extra Care accommodation. There was not, however in their opinion, a need for sheltered housing. The current proposals therefore substituted additional Extra Care accommodation for the sheltered housing previously proposed. The comments of the new Housing Development Officer received on 6th September state that she can no longer support on-site affordable extra care accommodation. In order to comply with Policy CP43 she would look to a financial contribution in lieu. The Adult Care Team also identified a need for additional specialist and/or dementia care beds. The Care Home proposed will provide specialist/dementia care to meet this need. The proposals are policy compliant in terms of Policy CP43 – Providing Affordable Housing and CP46 in terms of a genuine and evidenced need. With regard to the evidence of need the Housing Development Officer has pointed out that the Wiltshire Council’s Housing Strategy 2017-22 is only in draft and should not be quoted from. However the quote below is purely factual. THE STRATEGIC HOUSING FOR OLDER PEOPLE ANALYSIS TOOL (SHOP) 2.1 The SHOP Tool provides the following estimates on accommodation designated for Older People in Wiltshire. For Extra Care it estimates a current supply of 172 with an estimated demand of 1103 rising to 1677 by 2025. For registered care the estimated supply is 3988 with a demand of 4851 rising to 7381 by 2025. 3.0 WILTSHIRE’S OLDER PEOPLES DEVELOPMENT STRATEGY (WOPDS). 3.1 In December 2010 Wiltshire Council commissioned an Older People's Development Strategy (WOPDS) and, as part of the brief, the Consultants (Peter Fletcher Associates) produced a strategic modelling tool (the divert model) which enabled commissioners to model the future accommodation and support needs of older people until 2026. One product of this exercise identified the need for 1,136 units of Extra Care housing across the County. The WOPDS Strategy also highlighted that the delivery of over a thousand units of Extra Care accommodation could not be achieved by the Council alone. 4.0 CONCLUSION 4.1 The Wiltshire Housing Strategy 2017 to 2022 –states that the number of people aged 75 and over will increase by 68% (from 45,400 in 2015 to 76,400 in 2025) (page 7 - 3rd bullet). There is further breakdown of this on page 20 for the age cohorts 55-74 and 75 plus and the percentage changes of 20% and 68% respectively. Whilst different periods and age cohorts are used nevertheless this confirms to demographic data set out in paragraph 5.6 of the Planning Policy Statement. We have made reference in Section 5 below to the benefits and economies of scale that a CCRC scheme can bring to the delivery of sustainable and affordable extra care accommodation when compared to stand alone schemes to which the Housing Development Officer is referring to in terms of voids within existing housing stock. Both service providers and service users stand to gain from the economies of scale that a CCRC scheme can bring. Thus in our opinion on-site provision within a CCRC is a viable economic solution compared to an off-site contribution now suggested by the Housing Development Officer. Moreover the registered social providers who were engaged by the Council in the production of the housing strategy reinforced the need for Wiltshire Council to have CCRC schemes in addition to Extra Care. That allows registered social providers to develop mixed tenure schemes whereby the surplus for sales of private units can be used to subsidise the affordable elements.
2. Without any specific design element to include on-going care the proposed retirement bungalows/chalet bungalows do not qualify as specialist accommodation under CP46 and the justification for this part of the scheme is unclear. There is also uncertainty over how occupancy conditions could be enforced. In response: The comment does not reflect the wording of CP46 which is clearly aimed at all forms of accommodation for vulnerable and older people as is demonstrated by the highlighted extracts for Policy CP46 set out below: 6.53 Wiltshire has an ageing population, more so than the national average, and this needs to be taken into account when planning for new housing. This strategy plans for the care of the elderly within their local communities, so people can continue to enjoy life in their own homes for as long as possible. If and when this is no longer possible, there is need to ensure there are alternative facilities where people can continue to enjoy living in their local area with the level of care they require provided. 6.54 Core Policy 46 seeks to address the issue of an ageing population, which is particularly important in Wiltshire, by ensuring that there is adequate specialist accommodation, such as extra care housing. Core Policy 46 Meeting the needs of Wiltshire’s vulnerable and older people The provision, in suitable locations, of new housing to meet the specific needs of vulnerable and older people will be required. Wherever practicable accommodation should seek to deliver and promote independent living. Older people Housing schemes should assist older people to live securely and independently within their communities. Developers will be required to demonstrate how their proposals respond to an ageing population. Specialist accommodation The provision of sufficient new accommodation for Wiltshire’s older people will be supported, including: i. Nursing accommodation ii. Residential homes iii. Extra-care facilities Nowhere does CP46 refer to any specific design elements, minimum levels of care or indeed excludes other forms of accommodation such as bungalows. By contrast it encourages ‘alternative facilities’, ‘living in the local area’, ‘promoting independent living’, ‘living securely’ and ‘sufficient new accommodation’. All of which is delivered by the proposed CCRC at Grovelands Way. This is recognised in the previous response from Spatial Planning in relation to 16/08425/OUT where the only issue debated was one of the defined age for an ‘older person’. Firstly stating ‘However the age of an ‘older person’ is important with respect to the 42 age restricted bungalows/chalet bungalows (Class C3)’. Secondly concluding that ‘The Wiltshire Core Strategy was informed by evidence of the need within the SHMA and therefore consideration should be given to limiting the scheme to persons over the age of 65 given the definition of an older person in both government guidance and the SHMA to remain in line with the state pension age’. The very fact that the accommodation is age restricted means that it is specialist accommodation and not general needs. There is more to specialism than a tangible design element, such as a choice of accommodation, a safe and secure environment, a community of likeminded people, access to supporting facilities, location within a wider mature community, ease of access to wider facilities, 24 hour emergency call, a minimum provision of domiciliary care and access to optional care packages. Many of these mean that all of the properties will be subject to a higher service charge than would be expected of general needs housing which by definition qualifies all of the properties as specialist accommodation as residents would not choose to move into such accommodation and pay such service charges unless they were in need of what is offered. This has been recognised by Inspectors in appeals debating the need for age restrictions. Notwithstanding all of the argument set out above there are indeed further physical design elements of the proposed bungalows which reinforce their specialism. All bungalows, including the chalet bungalows, have large ground floor bedrooms with en suite facilities providing for ground floor living and adaptability for hoist access between bedroom and bathroom. All have the same design standards as the extra care apartments with wider doorways, raised power sockets, accessible light switches and 24-hour emergency call. The bungalows either have small rear gardens circa 6m in depth for ease of maintenance or open onto communal grounds. The latter are maintained as part of the service charge just as they are for the extra care apartments. The private rear gardens are not fenced off with high fencing but instead low hedging such that although they are private they are part of the grounds of the development and residents may choose to have the gardens maintained by the communal gardeners. With regard to further justification for the bungalows as set out in paragraph 5.6 of the Planning Statement forming part of the application there are 165,730 people in Wiltshire aged 50+. which is around 36.6% of the total population of Wiltshire and there are 78,690 people aged 65+, around 17.4% of the total Wiltshire population. Evidenced by the Estate Agent’s Davis & Latcham – who have currently 67 enquirers registered with their Warminster Office for a bungalow whilst there were just 15 available (as at June 2017). Concerns over enforceability are unfounded as, is normal with extra care developments, this will be ensured by covenants and can also be the subject of a planning condition or obligation. All leaseholders / service users residing at the CCRC scheme whether they choose to live in one of the Extra Care apartments or in the bungalows or chalets, will each be legally obligated under the terms of their lease to pay their due proportion of the annual service charge that includes: a. The provision of 24-hour on-site staffing – via a Principal Estate Manager supported by a team of 5 Deputy House Managers and Administrative Support as necessary within the staff rota. b. A Registered Domiciliary Care Manager – employed by the Management Company (most probably operating as a not-for-profit company) – the costs of whom are shared equally amongst the leaseholders – this would be the 45 retirement bungalows / chalet bungalows and the 46 extra care apartments making a total of 91 units; and potentially if there is one overall Provider responsible for the scheme as a whole including the social extra care then there would be an additional 39 units bringing the total to 130 end users; c. All of whom would contribute equally to the costs of providing the 24-hour staffing and the Registered Domiciliary Care manager and supporting staff providing direct Personal Care, Practical Support and Housekeeping services to each of the users. Of which typically each user is obligated to pay a baseline of 1 ½ hours per week within the service charge and can purchase any additional services as they so require to meet their needs. d. Provision for on-site catering including the cost of the catering staff and waiters and the running costs associated with such a facility.
All of the above and the planning submission demonstrates ‘how the proposals respond to an ageing population’ in accordance with CP46 as highlighted in the wording reproduced above. 3. The catchment area of search for the Sequential Test should be discussed with the Housing and Social Care teams to ensure that this aspect of the sequential approach has been properly applied. In response: The area of search encompasses the whole of Wiltshire and therefore the whole extent of Housing and Social Care’s remit. Thus, the area of search corresponds with the catchment area matching the evidence of need put forward to justify the development. Whilst it is accepted that there is likely to be a small element of need from geographical areas immediately outside the administrative boundary of Wiltshire (such as Frome) to promote sites within such areas would not meet the needs identified by Housing and Social Care.
4. The test of availability should be determined on whether the alternative site is available to accommodate the proposed development, not whether it is available to a particular developer. In response: This is fundamentally wrong. If a site is not actually for sale nor is there a reasonable prospect of it coming onto the market then it is not available. The WWUE is just such an example. The site is contracted to Persimmon and Hannick Homes who intend to develop it for general needs housing. Neither developer has any intention of promoting a CCRC and this has recently been confirmed in discussions with the LPA. Whilst their outline planning application makes reference to a use within Class C2 in the Planning Statement the nature or extent of the use is not specified other than by a vague reference in paragraph 3.13 to extra care being included in the Local Centre along with a number of other uses. It is also noted that Core Policy 46 is not referred to in the policy matrix at paragraph 4.14. There is insufficient land identified within the Local Centre to accommodate a CCRC. It suggests a quantum of 60 affordable extra care units which from our experience would require a site area of circa 1.0 ha. However, the site area allocated for the whole of the Local Centre is only 1.3ha (para 3.12) and thus clearly insufficient for the affordable extra care in addition to all of the other uses envisaged for the Local Centre set out in para 3.13 including the health centre. It is interesting that at para 3.13 it is stated ‘The local centre has been designed (our emphasis) to accommodate a range of…’ when clearly there has been no design or understanding of what is required. The approved master plan drawing is little more than a land use diagram with absolutely no detail on the site layout of specific uses. We reiterate that there is no reference to private extra care, registered care homes or alternative accommodation for older people such as bungalows all of which are being provided by the proposed CCRC at Grovelands. We would point out that the site area of the proposed CCRC is 4.8 ha and suggest that this would never be delivered as part of the WWUE when they can only allocate 1.3ha to the local centre itself. Indeed, we are aware that in recent detailed negotiations between the WWUE developers and the LPA from which revisions to their current planning application are imminent there has been no mention of a CCRC or allocation of a larger site area for specialist accommodation. But then the objective of the WWUE is rightly to deliver the priority of a range of conventional housing not a specialist development which opportunity now presents as being deliverable at Grovelands. Finally, and notwithstanding the above the older residents of a CCRC by definition have a limited life expectancy and therefore it is important for them to move into an established environment. The WWUE will be under construction for years (as per the programme in their planning submission) and the timing of the Local Centre cannot be guaranteed. The Grovelands site is in a mature established area with immediate access to existing bus services and the new convenience store.
5. Officers do not agree with the applicant’s argument that the site should be considered as a single planning unit and that the CCRC can be disaggregated. Response: The relevant legal authority is Burdle and Williams v SSE and New Forest DC [1972] 1 WLR 1207. The tests for determining the planning unit established in that case start with the unit of occupation and turn on the concept of physical and functional separation. Bridge J (as he then was) suggested three broad tests for determining the appropriate planning unit. A useful working rule is that it should be assumed that the unit of occupation is the appropriate planning unit, unless and until some smaller unit can be recognised as the site of activities which amount in substance to a separate use both physically and functionally. In the House of Lords decision in Westminster Council v. British Waterways Board [1985] AC 676; [1984] 3 WLR 1047; [1984] All ER 737; [1985] JPL 102, Lord Bridge said: ‘…The concept of a single planning unit used for one main purpose to which other uses carried on within the unit are ancillary is a familiar one in planning law. But it is a misapplication of this concept to treat the uses or uses of a single planning unit as ancillary to activities carried on outside the unit altogether’.
The CCRC has one main purpose and that is to provide care for people in need of care. Other uses within the planning unit are ancillary to that main purpose.
In terms of the economics of provision and the reason a CCRC cannot be disaggregated the total annual service charges for a CCRC scheme will be in the order of £550,000 PA to £700,000 PA dependent on whether the social extra care is included within the service management model for this CCRC or managed separately by a RSL Provider. If it is treated separately then that scheme will itself have a service charge set at around £350,000 PA – hence the economies of scale when a scheme of this nature is managed by a single Service Provider – mainly because the costs of running the Core management and Care staff that between them provide the essential 24-hour cover are shared by a larger group of people.
The additional weekly Personal Care, Practical Support and Housekeeping Services are directly proportional to the number of end users; for example for 130 service users there will be an additional 195 hours of contracted care and support services to be provided every week (Monday to Friday) by the Service Provider the costs of which are recovered through the annual service charge from the end users, who in turn are legally obliged to pay their due proportion.
Looking at the economies of scale for both the Service Providers and Service Users alike, a single planning unit CCRC scheme of 91 units (46 + 45) will have an annual service charge at say £550,000 PA, which means an approximate annual cost per end user apportioned equally (although there is likely to be some variation between units relative to number of bedrooms) of between £6,050 PA or, £505 PCM / £116 PW. Whereas, for single planning unit of 130 end users and an estimated annual service charge of say £700,000 PA this would mean an annual cost to each end user, on a straight apportionment basis, of £5,385 PA, or £450 PCM / £104 PW.
If one were, as the Spatial Planning Officer seems to suggest in his para. ‘Separation of Uses’ to fragment the CCRC scheme by having, for example separate stand-alone Extra Care schemes then each of the schemes would require their own full complement of staff both to provide the Core 24-hour services and the weekly support services rotas and, each would require a minimum annual scheme service charge in the order of £350,000 to £375,000 PA making the cost for each end users :- a. Assessed on a 39 social extra care scheme at around £8,975 PA / 747 PCM / £170 PW b. Assessed on a 46 unit private extra care scheme of around at around £8,152 PA / £680 PCM / £157 PW
Moreover, there are significant economies too for local businesses who may be contracted to provide services to the CCRC scheme, which because of its scale makes service provision much more sustainable in the short, medium and longer term, whether it be for local hairdressers using the facilities within the health and wellbeing suite, for example on two days or three per week for hairdressing or, for other local therapists to make similar use of this multi- functional space to provide say massage, podiatry, chiropody and other such services more economically. Simply because there is likely to be sufficient custom on a pre-booked arrangement to justify a local business person delivering those services within say an 4 to 8- hour booking of the facility. If the schemes are disaggregated then the economies of scale for service providers and service users alike will suffer as a consequence, often to the point of complete failure and cancellation of non-core / essential service provision – and, that in turn leads to less engagement with the local community and greater isolation for the end users around day-to-day social integration with those providers who are outside of the scheme.
This applies equally to social and leisure activities management where the size of the scheme is directly proportional to the number of activities that can be arranged on a regular and sustainable basis for the benefit of service providers and users alike.
The specialist dementia care home also brings service provision benefits when such a facility forms part of the single planning unit as it brings on-site a Registered care provider and whilst there needs to be a separate Registered Domiciliary Care Manager to that of the Care Home Registration and administration itself, nonetheless there are obvious economies of scale in administrative support services to be derived from having such a facility alongside the Domiciliary care services activities, notwithstanding the benefits for users who, for example as a couple where one might need specialist dementia care whilst the other spouse can continue to reside within the CCRC apartments or chalet / bungalow on the same site making visiting that much easier on a daily basis.
Finally, when developing the Wiltshire Housing Strategy many Registered Providers were supportive of the need specifically for CCRC schemes compared to stand-alone Extra Care schemes and, that is directly as a consequence of the economies of scale that can be derived from having a larger community of end users who between them collectively contribute to and share the costs of the essential core service provision across a wider number of people.
6. A new Doctor’s surgery is proposed to be sited within the Local centre as part of the WWUE, which would seem much more readily and widely accessible.
Response: As stated in the consultation response the most recently published IDP recognises that Warminster is an area where there is pressure on local health services and that proposed development must support development of local primary healthcare facilities. The inclusion of the Doctor’s surgery as an integral part of the CCRC fulfils this requirement. Moreover, it is deliverable now and not at some unspecified date in the future. There have been ongoing detailed discussions with the Smallbrook Surgery with regard to NHS funding to develop a new surgery at Grovelands. Smallbrook Surgery has now been forced to close increasing the need for an immediate solution to the under capacity of Surgery space in Warminster.There is also the option of private funding. In any event the opportunity to grant a consent for a new deliverable Medical Centre now should be recognised regardless of the current state of funding which invariably follows a definite consent rather than a vague proposal like the WWUE. Nevertheless, it is recognised that both existing practices in Warminster currently occupy unsatisfactory premises. In summary, a health centre could be provided on both the CCRC site and the WWUE and both opportunities should be welcomed. However, at this time it is only the CCRC which is able to deliver a health centre both commercially and physically. There is a pressing need for this to be delivered as soon as possible and with a planning consent firm negotiations can take place on funding for a local practice in Warminster to relocate to the Groveland site. Whereas for the WWUE the delivery of a health centre remains unknown in terms of commercial viability and timing.
The Grovelands site is more readily and widely accessible than would be the case of a surgery sited, at some time in the future within the WWUE.
7. Development proposals near to the CWS would need to consider buffering along with favourably long-term management of it.
Response: The proposals include an adequate buffer to the CWS which will be the subject of a long-term management plan. The very nature of a CCRC ensures the long-term protection and maintenance of the buffers as part of the managed communal grounds. Furthermore, the application ensures the protection of the CWS and ongoing discussions with the Council indicate that both the CWS and Public Open Space will all be managed by the Council. It is understood that there is no ecological objection to the application.
8. Advice should be sought from the Council’s leisure and ecology teams to determine the acceptability of the proposed relocation of the play area to an area informally used for car parking within the CWS. Response: There is no objection in principle from the Public Open Space and Play Officer subject to clarification on certain details which have now been addressed. The suggestion that should this application be approved, a condition/obligation is included to ensure that the new open space and play area are provided to at least the standard of the existing is accepted. It is further understood that the Ecology Officer does not object to the location. In summary: The Alternative Site Assessment covers the catchment area within the remit of Housing and Social Care and tests all sites which are genuinely available to deliver the proposed development. The wording of Policy CP46 is quite clear in that it encompasses all forms of accommodation for vulnerable and older people including bungalows. Whilst the WWUE may include provision for extra care housing the developer of that site has no intention of delivering it and in any case the site set aside for such a development is too small to accommodate a viable scheme. The WWUE is not therefore available. Whilst the WWUE does make provision for a doctors’ surgery there is an accepted need for two surgeries in Warminster and the Groveland site can deliver one now whereas the WWUE site is clearly long term. 6th September 2017 APPENDIX 5
Housing - Response to Officer Consultation
Date: 08.09.17
Planning application: 17/05360/OUT
The consultation response from Wiltshire Housing on the affordable element of the proposed development is not credible given planning policy, acknowledged need and the recent planning history of this site. The points are dealt with in detail below and summarized as follows:
1. Core Policy 43 clearly states ‘Only in exceptional circumstances, where it can be proven that on-site delivery is not possible, (our emphasis) will a commuted sum be considered.’ Affordable extra care can be easily accommodated on this site as proposed so there is no justification for a commuted sum as requested. 2. There is a clear need for all tenures of extra care accommodation to address the issue of an ageing population in Wiltshire as set out in Core Policy 46. The need is quantified by using the recommended ‘Strategic Housing for Older People Analysis Tool (SHOP)’ as attached. 3. The applicant has gone to great lengths and expense to satisfy the request for on site extra care accommodation as part of the proposed development following the previous planning refusal in 2016 and it is totally unreasonable of Wiltshire Housing to change their position at this late stage. 4. No evidence has been provided of the alleged ‘voids’ in existing extra care schemes or the reasons for them or why this should prejudice the delivery of much needed NEW modern extra care accommodation. 5. No evidence has been provided to either justify the request for a commuted sum or indeed the quantum suggested which is exorbitant. 6. The Wiltshire Council’s Housing Strategy 2017-22 is a valid document as it is within the public domain and therefore carries weight. Even more so because the quotes from it in the planning addendum are purely factual.
The comments of Wiltshire Housing can be summarised as follows:
1. In commenting on the previous scheme (16/08425/OUT) the Housing Commissioning Team identified a need for additional affordable Extra Care accommodation. There was not, however in their opinion, a need for sheltered housing. The current proposals therefore substituted additional Extra Care accommodation for the sheltered housing previously proposed. The comments of the new Housing Development Officer received on 6th September state that she can no longer support on-site affordable extra care accommodation because “in more recent correspondence with Adult Care colleagues it has been brought to our attention that there have been other affordable extra care schemes, delivered in the Wiltshire area which on occasions have experienced unexpected voids.” Moreover, “Adult Care are currently undertaking a review of the Older Persons Accommodation Strategy“ and therefore “Until this review is concluded the Council is unable to commit to delivering any more extra care schemes for the affordable sector as this would be a potentially significant financial risk to the Council. As a consequence we are unable to support affordable extra care on this proposed development at this point in time.”
In response: Unexplained ‘voids’ within existing affordable extra care schemes are not a justification for summarily departing from on site delivery of new affordable extra care accommodation for which there is a clear and evidenced need supported by planning policy. Nor should any ongoing reviews delay or limit such accommodation when clearly the outcome of such a review may conclude that the reasons for the voids do not detract from the need to provide new on site affordable extra care accommodation. Indeed to prevent, delay or limit the delivery of such accommodation based on a mere reference to ‘voids’ is to prejudice the objectives of planning policy CP43 and CP46 without due reason. Instead we submit that Wiltshire Housing should be focussing on the overwhelming need for affordable extra care accommodation and how this can be delivered. The Strategic Housing for Older People (SHOP) analysis tool as attached identifies the quantum of extra care units needed as follows:
2015: 1362 - 885 rent and 477 lease. 2020: 1614 - 920 rent and 694 lease. 2025: 2013 - 1006 rent and 1006 lease. 2030: 2292 - 963 rent and 1329 lease.
In 2014 there was an under supply of -87% and three years later there remains a chronic under supply even without the above increases in demand.
The demographics of an ageing population and the need for specialist accommodation is also contained in National Planning Policy Guidance.
The PPG provides guidance on how Councils should express the need for different types of housing in their Local Plan, stating:
‘Local planning authorities should ensure that the polices in their Local Plan recognise the diverse types of housing needed in their area and where appropriate, identify specific sites for all types of housing to meet their anticipated housing requirement. This could include sites for older people’s housing including accessible mainstream housing such as bungalows and step-free apartments, sheltered or extra care housing, retirement housing and residential care homes(our emphasis). Where local planning authorities do not consider it appropriate to allocate such sites, they should ensure that there are sufficiently robust criteria in place to set out when such homes will be permitted.’
The guidance for Housing and Economic Development Needs Assessments confirms that in assessing housing need plan makers should examine current and future trends of a number of factors including the proportion of the population of different age profile. With regard to housing for older people, the PPG goes on to state that:
‘The need to provide housing for older people is critical given the projected increase in the number of households aged 65 and over accounts for over half of the new households (Department for Communities and Local Government Household Projections 2013). The age profile of the population can be drawn from census data. Projection of population and households by age group should also be used. 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 the so wish. Supporting independent living can help to reduce the cost to health and social services, and providing more options for older people to move could also free up houses that are under occupied. The future need for specialist accommodation for older people broken down by tenure and type (e.g. sheltered, enhanced sheltered, extra care, registered care) should be assessed and can be obtained from a number of online tool kits provided by the sector. The assessment should set out the level of need for residential institutions (Use Class C2) (our emphasis). 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. Local authorities should therefore identify particular types of general housing as part of their assessment.’
The SHOP analysis used above is one of the tool kits referred to in the PPG.
In addition to other documents already submitted with regard to both the Spatial Planning and NHS consultations it is also useful to refer to a recently published report by the Local Government Association, Housing our Ageing Population a copy of which is attached. Below are a few relevant extracts:
‘The number of people aged over 65 is forecast to rise over the next decade, from the current 11.7 million people, to 14.3 million by 2025, a 22 per cent rise. This means that one in five of the total population will be over 65 in 10 years’ time, which will become one in four by 2050.’
‘In the UK, the vast majority of over 65s currently live in the mainstream housing market. Only 0.6 per cent of over 65s live in housing with care1, which is 10 times less than in more mature retirement housing markets such as the USA and Australia, where over 5 per cent of over 65s live in housing with care.’
‘The number of older people that have some form of care need is significant, with almost half of people over 65 currently living with a limiting long term illness (LLTI) or disability. It is forecast the number of over 65s with an LLTI whose day-to-day activities are significantly limited will reach three million by 2025, a rise of almost 30 per cent.’
Clearly there can be no doubt concerning need and therefore why the proposed on site affordable extra care accommodation should be welcomed and supported by Wiltshire Housing.
The applicant has revised a previous planning submission at considerable expense to specifically incorporate affordable extra care accommodation in the current scheme as requested by Wiltshire Housing in previous consultations. To change this position now at a very late stage in the planning process is unreasonable and prejudicial to the applicant.
There is no ‘potentially significant financial risk to the Council.’ It is not suggested that the affordable extra care must be delivered by the Council. It is for the applicant to deliver that accommodation through a range of different mechanisms which will include through negotiation with Registered Providers. The applicant has already engaged with a number of Registered Providers but until a planning consent is issued these negotiations cannot progress. Reference is made in Section 5 of the response to the Spatial Planning consultation about the benefits and economies of scale that a CCRC scheme can bring to the delivery of sustainable and affordable extra care accommodation when compared to stand alone schemes to which the Housing Development Officer is referring to in terms of voids within existing housing stock. Both service providers and service users stand to gain from the economies of scale that a CCRC scheme can bring. Thus in our opinion on-site provision within a CCRC is a viable economic solution compared to an off-site contribution now suggested by the Housing Development Officer. Moreover the registered social providers who were engaged by the Council in the production of the housing strategy reinforced the need for Wiltshire Council to have CCRC schemes in addition to Extra Care. That allows registered social providers to develop mixed tenure schemes whereby the surplus for sales of private units can be used to subsidise the affordable elements.
2. “our affordable housing requirements do not appear to fit with the concept of the scheme being proposed as a Continuing Care Retirement Community” It is proposed that the requisite affordable housing is provided by way of an off-site financial contribution.
In response: Paragraph 50 of the NPPF which states: “To deliver a wide choice of high quality homes and where local authorities have identified that affordable housing is needed, set policies for meeting this need on site, unless off-site provision or a financial contribution of broadly equivalent value can be robustly justified.” Policy CP 43 which states: ‘Only in exceptional circumstances, where it can be proven that on-site delivery is not possible, will a commuted sum be considered.’ There are no exceptional circumstance that would justify a financial contribution. As the applicant is proposing on-site provision in accordance with Policy CP43 and is satisfied that that affordable Extra Care accommodation can be delivered then clearly it would be contrary to Policy CP43 for the LPA to accept a financial contribution in lieu.
10th September 2017