H6 - Loss of Older Persons' and Specialist Housing Provision

Comment

Dear Sirs, As the market leader in provision for sheltered housing for sale to the elderly, McCarthy and Stone Retirement Lifestyles Ltd considers that with its extensive experience in providing development of this nature, it is well placed to provide informed comments on the aforementioned document insofar as it affects or relates to housing for the elderly. For your convenience, please find attached our comments with regards to the consultation. Thank you for the opportunity to comment. MCCARTHY & STONE RETIREMENT LIFESTYLES LTD. RESPONSE TO CONSULTATION ON THE FAREHAM LOCAL PLAN REVIEW Thank you for the opportunity to comment on the consultation papers for the aforementioned document. As the market leader in the provision of sheltered housing for sale to the elderly, McCarthy and Stone Retirement Lifestyles Ltd considers that with its extensive experience in providing development of this nature it is well placed to provide informed comments on the Local Plan Proposed Submission consultation, insofar as it affects or relates to housing for the elderly. My Client would like to commend the authority’s decision to include a standalone policy (Policy H5: Older persons housing and specialist housing provision) to promote the delivery of specialist accommodation for older people and for acknowledging that the borough is experiencing an increasingly ageing population. Notwithstanding this we have some concerns with the Local Plan Review and for the impact that some of the policies and supporting text may have on the delivery of specialist accommodation for older people. The National Planning Policy Framework stipulates that the planning system should be ‘supporting strong, vibrant and healthy communities’ and highlights the need to ‘deliver a wide choice of high quality homes, widen opportunities for home ownership and create sustainable, inclusive mixed communities. Local Planning Authorities should plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community… such as… older people’ (emphasis added). The National Planning Practice Guidance reaffirms this in the guidance for assessing housing need in the plan making process entitled “How should the needs for all types of housing be addressed? (Paragraph: 021 Reference ID: 2a-021-20140306) and a separate subsection is provided for “Housing for older people”. This stipulates that “the need to provide housing for older people is critical given the projected increase in the number of households aged 65 and over accounts for over half of the new households (Department for Communities and Local Government Household Projections 2013). Plan makers will need to consider the size, location and quality of dwellings needed in the future for older people in order to allow them to move. This could free up houses that are under-occupied. The age profile of the population can be drawn from Census data. Projections of population and households by age group should also be used. The future need for older persons housing broken down by tenure and type (e.g. Sheltered, enhanced sheltered, extra care, registered care) should be assessed and can be obtained from a number of online tool kits provided by the sector. The assessment should set out the level of need for residential institutions (use class C2). But identifying the need for particular types of general housing, such as bungalows, is equally important” (My emphasis). The ‘Housing White Paper: Fixing our broken housing market’ clearly signals that greater consideration must be given to meeting the needs of older persons’ in Local Plans stipulating that: ‘Offering older people a better choice of accommodation can help them to live independently for longer and help reduce costs to the social care and health systems. We have already put in place a framework linking planning policy and building regulations to improve delivery of accessible housing. To ensure that there is more consistent delivery of accessible housing, the Government is introducing a new statutory duty through the Neighbourhood Planning Bill on the Secretary of State to produce guidance for local planning authorities on how their local development documents should meet the housing needs of older and disabled people. Guidance produced under this duty will place clearer expectations about planning to meet the needs of older people, including supporting the development of such homes near local services82. It will also set a clear expectation that all planning authorities should set policies using the Optional Building Regulations to bring forward an adequate supply of accessible 9housing to meet local need. In addition, we will explore ways to stimulate the market to deliver new homes for older people.’ (Para 4.42) (My emphasis). The document confirms that the borough has an ageing population, and states that this is more so than the national average. In line with the rest of the country, the document identifies in paragraph 1.35 an acceptance that the demographic profile of the Borough is projected to age. The largest proportional increases in the older population are expected to be of the ’frail’ elderly, those aged 85 and over, who are more likely to require specialist care and accommodation provided by Extra Care accommodation. It is therefore clear that the provision of adequate support and accommodation for the increasingly ageing demographic profile of the Borough is a significant challenge. Unless properly planned for, there is likely to be a serious shortfall in specialist accommodation for the older population in the borough, which will have a knock on effect in meeting the housing needs of the whole area and wider policy objectives. Specialist accommodation for the elderly, such as that provided by McCarthy and Stone, will therefore have a vital role in meeting the areas housing needs. We would advocate that the Council continues in taking a positive approach in seeking to provide appropriate accommodation to meet the needs of its ageing population within the Local Plan. We consider that the best approach towards meeting the diverse housing needs of older people is one that encourages both the delivery of specialist forms of accommodation such as sheltered / retirement housing and Extra Care accommodation. We commend the council for the inclusion of Strategic Policy H5: Older persons housing and specialist housing provision which seeks to meet the need for accommodation for the elderly population in the borough. We would like to highlight the advice provide in the Housing in Later Life: Planning Ahead for Specialist Housing for Older People toolkit. This toolkit was developed by a consortium of private and public organisations with an interest in housing for the elderly and encourages a joined up approach to planning, housing and social care policy both in the collection of evidence and the development of specialist accommodation for the elderly. A copy of this document has been appended for your convenience. Whilst we appreciate that no one planning approach will be appropriate for all areas, an example policy is provided that, we hope, will provide a useful reference for the Council: “The Council will encourage the provision of specialist housing for older people across all tenures in sustainable locations. The Council aims to ensure that older people are able to secure and sustain independence in a home appropriate to their circumstances and to actively encourage developers to build new homes to the ‘Lifetime Homes’ standard so that they can be readily adapted to meet the needs of those with disabilities and the elderly as well as assisting independent living at home. The Council will, through the identification of sites, allowing for windfall developments, and / or granting of planning consents in sustainable locations, provide for the development of retirement accommodation, residential care homes, close care, Extra Care and assisted care housing and Continuing Care Retirement Communities.” Para 5.15 introduces the principle of the use of a clawback or overage clause where development fails to provide any or an offsite Contribution in lieu of affordable housing at a lower rate than set in Policy H2. We consider the requirement for a review mechanism would be in clear contravention of the PPG (paragraph 17, Reference ID: 10-017-20140306) which makes clear that ‘planning applications should be considered in today’s circumstances’ unless a scheme phases delivery over a medium or longer term. This principle is further confirmed by paragraph 10 of the Government’s ‘Section 106 Affordable Housing Requirements Review and Appeal’ guidance document and RICS Professional Guidance GN 94/2012 Financial Viability in Planning (para.3.6.4.1). We are dealing here with a proposed development of apartments which needs to be built a single phase because of the need for all apartments to have access to common communal areas. There are a number of recent appeal decisions have make it clear that a planning obligation seeking to require a compulsory reappraisal in these circumstances is not compatible with Regulation 122 of the CIL Regulations. In light of the above we consider that the proposed review mechanism if applied to ‘single phased’ development schemes is both contrary to the PPG and would not accord with the provisions of Regulation 122 of the Community Infrastructure Levy 2010. Of considerable concern too, is the nature of the review. Whereas in accordance with policy, and all good practice in order not to stifle or prevent development, nor to effectively impose a tax

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