(b) Do you agree with the policy approaches to: adoption of the optional Building Regulations standards for accessible and adaptable housing? If not, what changes would you wish to see?

Agreed with Option A for access to housing and housing standards.
Access Standards - agree with Policy A for all residential to be built to the new standards ie properties that can be easily adapted.
Ticehurst is a service centre but has a high level of older person housing. Bungalows within development sites would provide opportunities to remain within the community

The Government internal space standards already comprise a material planning consideration and so there is no need to also introduce a new Local Plan policy duplicating such standards so delete draft Policy DGH1 as not being reasonably necessary.

The Building Act 1987 already provides "Access Standards" and so as not to unnecessarily constrict development no mandatory policy requirement should be imposed to require a higher standard.

Option D should be followed.

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

a: Reluctantly agree, although consider the national internal space minimum standards to be too small.

b: Agree, seems about right.

c: Tentatively agree with all options, although think the wording is too vague and needs firming up. Where's the detail?

AmicusHorizon own Extra Care schemes, older person schemes, affordable rented and shared ownership . We've several schemes for specialised older persons are not always able to re let due to location so end up with voids. The affordability of the specialised units are expensive for both the residents and provider.
Yes to (a) National Internal Space Standards(Option A)
Yes to (b) to Option B
No to (c) 5% at M4(3) (a)- needs consideration on a scheme by scheme basis dependent on location.
Potential end users identified prior to planning approval the Occupational Therapists work with the developer and relevant parties on design.

9a - Option A
9b - Option A
9c - Option D

National Space Standards assist with developers to fully understand requirements of development. This creates a level playing field when it comes to land values to avoid the possibility of sites becoming unviable. Building Regulations should be the driving force for accessible and adaptable housing. This is because amendments to BR wouldn't mean that planning policy had caught up. Turning to older persons housing, this should be judged on a site by site basis. In some circumstances it may not be appropriate to require elderly housing to be provided.

Internal space - option A - adopt standard
Accessibility - Option A - adopt standard
Seniors accommodation - no - lifetime homes standard

The minimum standards are appallingly low by any decent yardstick for living. If any house has a garage, that garage is usually the largest room in the house.

We would urge Rother to lobby for higher standards.

For accessibility, we would prefer Option C.

For older persons, we see merit in all options indicated. Specifically, given the ageing population:
Option A - should be set at 80 dwellings;
Option B - care homes should be spread, not all concentrated, say in Bexhill. Targets for other accommodation for the elderly should reflect as near as can be, census figures, on the basis that older people would wish to stay local to their communities, as well as indeed people with caring responsibilities ;
Options D and E - unless specified, developers will not build bungalows , so a target must be set, in line with census information;
Option F - possibly near to the hospital facilities.

All developments should meet the national internal space standard - Option A space standards.
Agree with Option C access standards.
Re Specialist Housing for Older People:
Ticehurst (a service centre) already has more than enough accommodation for old people (Newington Court, The Old Coachworks, Cross Lane House, Cross Lane Gardens, Downash House). But other places could benefit (e.g. Robertsbridge, which has none). There is a risk, in setting district-wide targets, that care provision ends up in the wrong place, therefore reject Options B and C. Options A, D, E and F all have some merit, warrant further research.

NCS would apply option C for affordable housing standards
NCS agrees with adoption of internal space standards
NCS agrees with preferred option for accessible & adaptable homes.
NCS would adopt option D,E & F for housing for older people

On average, homes built in the UK have smaller room sizes than other Western European countries, so we welcome imposition of minimum internal space standards.

On accessibility, we wish to see Option C (higher standard) even though the scope for sites of 50+ are limited in rural areas, but we would wish to see older people have the opportunity to live in appropriate accommodation in their home villages if possible.

Specifically regarding options for Older People, we feel that suitable options for rural developments would be your options A, C, D, E, especially as Robertsbridge is a rural service centre.

a) Yes, minimum internal space standards should be adopted.
b)Yes, I agree with the policy DHG2
c) I believe a proportion of market housing should be targeted at older people with maybe a small proportion of affordable housing targeted. Housing for older people should be intermixed to form a proper community.

We agree with at least the minimum space standards of the PPG, but would wish to see these exceeded wherever possible, and particularly in the one and two bedroom categories, given that our space standards are lower than the rest of Europe.

We support the adoption of optional Building Regulations standards for accessible housing, as acknowledged by our Policy HO5, 'thereby to enable (the elderly and people with disabilities) to remain independent and within the community for as long as possible'.

We therefore agree as a minimum 9(a) and 9(b), and on 9(c) favour options D and E.

Fairlight Parish Council comments:

All three are agreed to be appropriate as baseline policies for Rother. However local communities, especially those developing Neighbourhood Plans, may wish to adjust them to meet the needs of their local communities as part of the Neighbourhood Planning process.

In Fairlight the age profile means that a higher proportion of properties will need to cater for enhanced access and be adaptable embracing the design for life principle.

Question 9 relates to the adoption of new optional technical housing standards issued by the Government. It also relates to RDC's proposal to require a % of dwellings for "older people".

Access Standards- The DaSa proposes to require 25% of new dwellings to meet the enhanced access standard M4(2) of the Building Regulations, with an additional 5% being built to M4(3)(a) on sites of 50+ dwellings. The DaSA acknowledges that this policy approach will impact on viability, however no viability assessment has been published which demonstrates that RDC has fully considered the implications.

Notwithstanding the need for a Local Plan viability assessment, the flexibility provided in the wording of the draft policy, which allows for non-compliance where the applicant can demonstrate that it is not practical or financially viable to deliver the standards is welcomed. However, it is considered that reference should be also made to instances where site-specific circumstances prevent enhanced accessibility or adaptable standards from being met. In this regard the PPG Paragraph: 008 Reference ID: 56-008-20160519) states:

Local Plan policies should also take into account site specific factors such as vulnerability to flooding, site topography, and other circumstances which may make a specific site less suitable for M4(2) and M4(3) compliant dwellings, particularly where step free access cannot be achieved or is not viable. Where step-free access is not viable^ neither of the Optional Requirements in Part M should be applied.

Older Peoples Housing (Adult Social Care)

HOUSING Page 35

(b) adoption of the optional Building Regulations standards for accessible and adaptable housing?

Yes. Option C - developments of 11 or more requiring 25% M4 (2) housing and developments of 50 or more requiring 5% M4 (3). The research and evidence to support this policy is significant both at a local and national level.

It is not clear whether the adoption of optional Building Regulations standards is specific to affordable housing development or a blanket policy for all developments. It may be that different Building Regulations standards could be adopted specifically for affordable development on the basis of accessibility needs of those on the Councils housing register.