(c) Do you agree with the policy approaches to: housing for older persons, and the specific policy options highlighted? If not, what changes would you wish to see?

Comments by Rye Town Council on the Rother DC Development and Site Allocations (DaSA) (Local Plan)


1.The 2014 Core Strategy recognised that it needed a Development and Site Allocations Plan [DaSA Plan] (up to 2028) to identify the sites required to meet its provisions and to elaborate certain policies. It would need to tackle two specific issues affecting dwellings: to consider adjusting existing development boundaries to reduce the constraints on meeting targets; to address the shortfall of deliverable sites against the 5-year target.

2. It is noted that the DaSA Plan records the preferred sites across Rother District in two categories:

- sites where no Neighbourhood Plan (NP) is being made
- sites identified in Neighbourhood Plans; Rye is in this category.

4. Rye Town Council has considered the DaSA Plan in its three parts.

- It has NOTED Part A - the Context: (the Core Strategy), with its development requirements (not for review), and related policies. Where NPs are being prepared these are listed (Rye is listed).
- It COMMENTS on Part B - Development Policies as below. Many of these draft policies affect the RNP. Some have argued that it would have been useful to have had these as Rye was drafting its RNP, but we are where we are. We have been specifically encouraged to consider the definitive housing requirements for the Rye Neighbourhood Plan area (Rye targets have already been reconciled by Rother officers) and the policies for Development Boundaries and "Gaps".

- It has NOTED Part C - There are the Site Allocations for those parishes where no NP is being made. The only site allocations in this section relating to Rye are in Rye Harbour which we have considered in the RNP. Also there is discussion of traveller sites including one in Rye.

5. Whereas we had, at first sight, presumed that Part B might conflict with the emerging Rye NP, this is not the case. As agreed, here is the Rye TC comments in consolidated form on the three parts of DaSA.

The Rother District Development and Site Allocations Local Plan

Part A - Neighbourhood Plans (NP) - Rye NP is listed as being drafted. Version 8 emerging plan is on the website. www.ryeneighbourhoodplan.org.uk
Rother Officers have reconciled numbers in the RNP with the DaSA.

Part B Q1 - Water Efficiency -Support approach: adopt standard through Bldg Regs

Part B Q2-4 - Suggest Rye Harbour for turbines and biomass. Solar panels are not mentioned and could be fitted to large industrial and educational buildings in Rye. Support approach - should adopt national guidance standards.

Q5 - Retention of sites of social or economic value - Support approach and proposed criteria for retentions.

Q6 - Equestrian development - Support approach - as drafted

Q7 - Affordable Housing - Support Option B, in line with PPG (None under 10; 30% over 10 dwellings)

Q8 - Access to housing and space standards (Older people) - Support Option E

Q9 - 10 - Custom and self-build housing - 1% of target of 160 houses= 2 for Rye Rye could support 5 homes which is around 3%. Support Option D; a site is identified in Rye NP

Q11 - External residential areas - Support proposed policy

Q12 - Extensions to residential gardens - Support proposed policy

Q13 - Extensions and alterations, including annexes - Support proposed policy

Q14 - Boundary treatments and accesses -Support proposed policy

Q15 - Shopfronts and advertising - Strongly support proposed (more prescriptive) policy

Holiday Sites - Support proposed policy

Q16 - Existing Businesses and Sites - Support proposed policy

Q17 - Landscape and AONB - Support proposed policy

Q18 - Strategic Gaps - Rye-Rye Harbour to be extended Support the proposed definition of strategic gap, but given the unique nature and profile of Rye could be extended to gaps on the Eastern and Western approaches: New Road, Military Road and New Winchelsea Rd

Q19 - Bio diversity and Green Space - Support the policy approach

Q20 - Drainage - Support the policy approach

Q21 - Land Stability - There is a risk of (sandstone) rockfall around Rye. The rock structure is of similar composition to cliff structure of Fairlight / Pett . The risk locations include East, South and West Citadel; land above Military Rd and at Cadborough. Rye should be specifically identified and a similar policy applied to land at risk above and below where historical falls have occurred. Propose inclusion of Rye as for Fairlight and Pett Level

Q22 - Environmental Pollution - Support policy approach

Q23 - Comprehensive Development -Support policy approach

Q24 - Development Boundaries - The RNP proposes two changes to the development boundary of Rye. Policy approach should cater for this.

Part C - Targets
Rye (and Rye Harbour) Overall Targets: 355-400 dwellings (40 in Rye Harbour), 10-20,000 sqm employment. Dwellings Number Breakdown has been agreed with Rother DC Officers:

Total Completions Large Site Small Site Windfall
355 198 22 6 22
Balance: 107

Rye Harbour - Allocation to Rye Harbour - 40 dwellings - Support policy approach; as directed by Rother DC, and for historical reasons, the RNP has text covering the target of 40 dwellings in Rye Harbour (Icklesham Parish)
The 40 are included in the Rye target of 400 as above.

Traveller sites - Traveller Site - Rye Gritting Depot is listed but not a preferred option - Support policy approach

I support Option E

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

People need houses of a reasonable size in which to live. This should be applied across market and affordable housing so as not to discriminate against social housing residents.
Housing for the elderly should be mandatory across market and affordable housing. As sites have been selected, then this requirement can be site specific as to where they are best located for services etc.. However, it does not mean that other development sites must not contribute to the costs of the preferred sites.
Work needs to be done to ensure that developers do not take a 'phased' approach by only registering a smaller site to start with and then increasing the size by a smaller amount each time to ensure that they do not have to meet these standards. If land surrounding a site is put up for development, then the this must be considered as an extension to the original development, and the requirements for house sizes and housing for the elderly must be applied as a total and not as a smaller independent development. This should be in the form of a new policy.

Broadly support the recommendations but with reservations in the absence of any indication what "designed for older people" means. We are of the view that the housing crisis is such that housing design should be as flexible as possible so as to be able to serve more than one sector of the population, e.g. homes that enable the occupiers to be cared for at home as much as possible and as required.

The preferred policy is over prescriptive and over burdensome.

Policy B or D is preferred.

The preferred policy is over prescriptive and over burdensome. Policy B or D is preferred.

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.

Rye Conservation Society agrees to the proposed policy and wording regarding
Residential Internal Space Standards.
Options D, E & F in respect of Housing for old people.
Option C in respect of Self Build and custom built housing.

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".

Housing for older people - The DaSa set out 6 tentative options relating to the provision of housing for older people. Option A, D and E propose to seek a proportion of market and affordable housing to be either housing specifically designed for older people, or housing targeted at older people. The Dasa suggest that these options should be seen as complementary to the existing Core Strategy policy requiring 30% 1 and 2-bed homes in rural areas and to the above proposed policy on accessible and adaptable housing.

No information is provided on what would be required in order for a house to be considered as "specifically designed for older people". However, it is considered that this policy is duplicating the access standards policy above, which, if adopted, would already provide an element of dwellings that are suitable for older people. Anything beyond this would require specific retirement development/care homes type
development. It is not considered 'Justified 'to require a percentage of housing on each housing allocation to be specialist retirement housing.

Older Peoples Housing (Adult Social Care)

HOUSING Page 35

(c) housing for older persons, and the specific policy options highlighted? If not, what changes would you wish to see?
We support Rother's planning approach to meeting the needs of older people.
Additional comments:

* Should Rother adopt the building regulation standards as proposed above it should not need a policy to specify older persons housing in developments of 100 or more as the needs of older persons would have already been met by providing accessible, adaptable homes.

* As well as new developments of residential, nursing, sheltered, Extra Care etc housing Rother needs to factor in losses. Many of the providers' premises in the District are Victorian homes which are difficult to maintain and adapt. Is there the possibility of having a more flexible policy to incentivise care home owners to change use of existing premises and facilitate extensions of small scale units that may be unsustainable?

* The County Council would promote the development of Extra Care housing as an alternative to residential care homes. Although there is a need in rural areas of Rother it is difficult to sustain the design principles of Extra Care in these locations as they are usually not close to facilities etc.

* The County Council would support the development of short term care ready older persons housing that can be used for respite care and to prevent admissions to acute care. This requirement could be factored in to new developments for older persons housing with a requirement to consult with the County Council on requirements for short term placements in the locality.

* It is thought that a policy specifying bungalows for older people would not have much of an impact as that is already the target audience for that style of development. What could be policy led is the requirement to have the infrastructure in place within the vicinity to meet the care/ health needs of the residents in the locality i.e. space provided on the development for mini health hubs etc.