NATIONAL INTERNAL SPACE STANDARD

McCarthy & Stone built its first development in 1977 and over the past 38 years the Company has specialised in the design, construction and management of specialist accommodation for older people developing a wealth of experience in this particular sector. Extensive research both at pre and post-occupation has been conducted to provide accommodation that is tailored to meet the specific needs of its residents.

In light of the above, it is often highly problematic when local planning authorities seek to impose design standards that have been prepared for 'general needs' housing on specialist older person's accommodation.

Aspects of the proposed National Space Standards are, of course desirable for all forms of
accommodation and McCarthy and Stone aligns itself with best practice wherever feasible. In the majority of instances a standard Retirement Living or Assisted Living unit would comfortably exceed the National Space Standards for both 1 bedroom and 2 bedroom flats.

In many instances rigid standards on design and space could be challenging, and in many cases unfeasible, in the highly constrained town / edge-of-centre locations which are best suited for older persons' housing. Such standards would also have a material impact on the already finely balanced viability of these developments and in some cases prevent them coming forward.

We also note that the National Space standards do not provide a quantum of floorspace for 2 bedroom flats occupied by two individual's and older person's accommodation is not by definition occupied by families, so a two bedroom flat would never be occupied by three people. The standards would therefore appear to be onerous in their requirements for older person's housing.

The recently published Housing White Paper: Fixing our Broken Housing Market reflects our concerns, with Government 'concerned that a one size fits all approach may not reflect the needs and aspirations of a wider range of households' (para 1.55) and the Government has committed to reviewing the National Space Standards accordingly.

In light of the imminent review of the National Space Standards we consider that any decision to implement such standards on new development is applied flexibility, particularly to specialist forms of accommodation or constrained urban sites.

ACCESSIBLE AND ADAPTABLE HOMES

McCarthy & Stone develop purpose built older persons' accommodation and as such they exceed the requirements of Policy DHG2. We have no objection to the proposed standards accordingly.

SPECIALIST HOUSING FOR OLDER PEOPLE

McCarthy and Stone welcome the proactive stance the Council has taken in seeking to provide appropriate levels of accommodation to meets the needs of its aging population.

In selecting sites for elderly persons' accommodation careful consideration should be given to locational criteria including: Topography, Environment (including safety and security). Mobility, Services and Community Facilities, As such, suitable sites for specialist accommodation for the elderly are difficult to find and tend to be located within, or adjacent to town or local centres. It is therefore hi ghly unlikely that the majority of development sites will be suitable for specialist accommodation for the elderly, particularly on urban extension sites where access to goods and services may be limited.

Specialist accommodation for the elderly also usually provides an element of care and communal facilities at an additional cost to the developer. This requires a critical mass of residents in order to be feasible and small scale developments of specialist housing for the elderly could not be realistically asked to provide or maintain such facilities. It is therefore unrealistic to expect the provision of specialist accommodation for the elderly to be met piecemeal in general needs housing developments.

We therefore consider that aspirations for larger sites to provide an element of specialist accommodation, as intimated in OPTION A and OPTION E, to be impractical.

We appreciate that the Council wishes to increase the level of housing stock that meets the needs of older people. It is however more realistic for the Council to stipulate a requirement for a proportion of houses in larger development sites be built to a standard that is suitable for the elderly. This is addressed in draft Policy DHG2.

The provision of housing suitable for the elderly would not, by itself, address the diverse housing needs of the elderly in Rather, Accordingly a variety of specialist accommodation for the elderly should also be encouraged, through either allocated or appropriately located windfall sites. We support the OPTION B, OPTION C and OPTION F accordingly.

We are happy to assist the Council in the determining appropriate targets for these forms of accommodation but would recommend the Housing LIN'S SHOP@ tool as a useful starting point for any assessment.

Thank you for the opportunity to comment