Main Modifications Consultation

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I was trying to submit comments to the Main Modifications Consultation but haven't received the verification code. As I didn't want to miss today's 4pm deadline, I am submitting my comments by email instead. Please see comments below in relation to MM36 -

Anchor Hanover, England’s largest provider of specialist housing and care for older people, encourages the inclusion of a specific policy on older persons’ housing, given the significant and growing need.

The policy should also include a clear numerical delivery target for older persons’ housing to ensure identified needs are met over the plan period.
We welcome a policy which supports all types of housing for older people, as defined in the National Planning Policy Framework.
We recommend making specific site allocations for older persons’ housing, rather than relying on M4(2) or M4(3) standards, which are not tailored to, or reserved for, older people. Allocations should consider the minimum viable scale for such housing. In Anchor’s experience, this is at least 65 units per development.
We recommend that a more flexible approach to housing mix is taken for older persons’ housing. Anchor’s developments typically comprise single apartment buildings with around 70 high-quality social rent homes for older people, mainly one-bedroom apartments. Mixed tenure buildings (e.g. combining social rent with affordable rent or sale) can create market challenges and affect viability. Two-bedroom homes are also difficult to let due to under-occupancy charges and the prevalence of single-person households. Flexibility in tenure and housing mix is therefore essential to ensure the viability and successful delivery of older persons’ housing developments to meet needs. The policy should therefore be amended accordingly.