REDACTED

as previous

Whilst the principle of providing this type of housing is good, there is no evidence that in PP29 or PP17 that housing for an aging population will be provided.

These need to be affordable

West Bergholt Parish Council supports this policy, as evidenced see attached West Bergholt’s Housing Needs Survey, November 2025.

There does not seem to be much provision for sheltered housing for adults with issues, or for care leavers, or older people to be supported while living independently yet I note that large developments should be demonstrating the provision for each estate.

P101

The ICB understands the need for new care facilities and facilities for an aging population and is supportive of this policy in general. The ICB is keen for CCC and all LPAs to understand the impact care facilities have on primary care services due to the way in which patient appointments are made within that setting. Primary care services spend multiple hours per week attending the various care homes within their respective Primary Care Networks (PCNs) seeing patients and this can’t be mitigated through usual physical infrastructure increases via s106. This results in more appointments being done away from the surgery and less availability in the surgeries for standard appointments.

There are possible locations that could accommodate more specialist accommodation than others and working together to identify these areas could be a useful way of trying to mitigate the impacts on PCNs going forward.

Care homes (including Extra Care and other Older People’s accommodation) should not be built in Flood Zone 2 or 3 areas unless effective flood proofing and evacuation plans which do not involve emergency services are in place.

Stanfords Colchester LLP has submitted detailed representations on this draft policy; please refer to the attached document.

Anchor Hanover, England’s largest provider of specialist housing and care for older people, supports the inclusion of a specific policy on older persons’ housing and one that supports all types of housing for older people. Given the significant and growing need, the policy should also include a clear numerical delivery target to ensure needs are met over the plan period.

We are concerned that the proposed policy applies stricter criteria to older persons’ housing than to general needs housing, which could limit delivery despite strong evidence of need. These criteria should therefore be removed to ensure the policy is effective and supports delivery.

We welcome the requirement for developments of 500+ homes to include provision for older people. The policy should take account of the minimum viable scale for specialist older persons’ housing, which in Anchor’s experience is at least 65 units.

The Council’s Local Housing Needs Assessment (Paragraph 8.28) shows that the Colchester City area has a severe shortage of specialist accommodation. However, noting the significant national need for such provision even this may be an underestimate.

Considering the severe shortage of specialist housing and care in the Colchester City area this policy doesn’t do enough to increase the amount of specialist housing and care provision in Colchester. The plan’s approach to meeting the area’s housing need is heavily skewed towards standard/non-specialist housing.

Requiring specialist housing to be located within settlement boundaries, or limiting the requirement to deliver specialist housing to schemes of over 500 dwellings within the Colchester Urban area can never deliver the level of specialist housing that is required to meet current, let alone future levels of need for specialist older people’s housing and care.

The kind of approach that is required to prevent continued and exacerbated specialist housing need in the Colchester City area is allowing specialist housing to be built outside but well related to (in most cases adjacent to) settlement boundaries of Growth and Opportunity Areas, Large Settlements and Medium Settlements. An example of such an approach can be found in the neighbourhood plan for Thurston, Suffolk (Policy 1: Thurston Spatial Strategy).

In addition, the plan should make allocations specifically for specialist housing (as the alternative strategy suggests). This will give certainty about the delivery of a minimum level of specialist housing. Contrary to what is stated this need not prevent specialist housing being delivered in a range of locations unless an illogical approach to allocation is taken AND because allocating sites for only part of the need would still allow other sites to come forward in a range of locations in line with need/demand through our proposed “well related to settlement boundaries” provision.

Proposed change(s):

The part of the policy that currently reads:

b. located within settlements;

should be replaced with:

b. well located in relation to settlement boundaries of Growth and Opportunity Areas, Large Settlements or Medium Settlements;

The following text should then be added to the policy:

Proposals for specialist older people’s housing and care will be permitted on land adjacent to but outside of settlement boundaries provided they comply with other relevant policies in this plan.

The following text should also be added:

In order to guarantee provision of specialist older people’s housing and care, this plan will allocate specific sites for such uses.

Suitable allocations for specialist older people’s housing and care should then be included within this policy or within Policy ST5. These allocations should include Land north of Colchester Road and east of Maltings Park Road, West Bergholt (site submitted: 7 March 2025 by NEEB Holdings Ltd, grid reference: TL 96887 27560, site area: 2.5 hectares). Detailed site assessment work shows that this site could deliver:

• 40 – 75 older people’s dwellings and more than 40% open space; or
• a 65 bed care home, 20 older people’s dwellings and more than 40% open space.

While HBF welcomes the support for the provision of specialist accommodation the Council should be seeking to identify sites that support such development rather than rely on sites of 50 dwellings or more to provide such development. The Council needs to engage with the developers and providers and specialist accommodation and work with them to identify appropriate sites rather than rely on more speculative approaches to meeting the needs of older people.

With regard to the requirement for 5% of market homes to and 10% of affordable homes to be built to part M4(3) of the building regulations it is notable that the council have chosen to base their assessment of need on data relating to individuals who use a wheelchair both inside and outside the home rather than just those who use a wheelchair inside the home and who will require it to be built to part M4(3). The figures are quite different with only 0.7% of owner occupier using a wheelchair both inside and outside the home. While HBF recognise the need for some home to be built to part M4(3) where required there is a danger that the council’s assessment over estimates the demand for such homes. HBF would suggest the council reconsider the evidence and examine need on the basis of those who use a wheelchair inside the home.

See full text of the attachment for each policy which in some cases add extra information that couldn't be included fully in the rep summary.

see attached