Response to new government guidance – Housing for older and disabled people

Background

On 26 June 2019 the Government published new guidance to assist councils to plan to meet the housing needs of older and disabled people.  It becomes part of the National Planning Practice Guidance (NPPG) and is therefore to be taken into account in drawing-up planning policies and deciding planning applications.

Retirement Villages’ Response

Retirement Villages Group Ltd welcomes the new guidance, which provides helpful reinforcement and expansion of existing policy and guidance and should be a major wake-up call to the many local planning authorities who have failed to properly understand and plan for these needs.  It has the potential to usher-in a sea-change in attitudes and significantly boost delivery.

The new guidance describes meeting the housing needs of the growing number of older people as critical.  The ageing population is arguably the biggest trend impacting on the changing needs of the population.  For the first time it recognises clearly in Government guidance the problems perpetuated by failing to provide sufficient suitable accommodation and by contrast the benefits to individuals and society of taking action.  As the guidance stresses, unsuitable housing can isolate people whilst offering a better choice of accommodation can help people live independently for longer, better connected to their communities, with improved mental health.  As the guidance confirms, it can also reduce costs to the social care and health systems.

The new guidance helps identify how all new development can be made to be more inclusive, accessible and adaptable for all including those with dementia, which is a challenge that goes well beyond housing.  It also addresses the full range of housing options for older and disabled people including making sure general needs housing better meets changing needs.

Importantly, the Government recognises that there is no one-size-fits-all solution but rather the mix of housing response should reflect the diverse range of needs, including varying health and lifestyles.  Many people will want and be able to live independently in a home of their own and that could mean their existing home, a new accessible general market home or one of a range of more specialist options which provides supported independence with varying levels of support, amenity and care.  When care needs become more significant the ailing home-care system means that staying-put can be impossible for many people.

Local authorities are now required to determine the varying needs of people who will be approaching or reaching retirement over the period of their local plan as well as the existing population.  The guidance signposts online toolkits such as Shop@, provided by the Housing LIN as a way of assessing the future needs of older people by tenure and type.  This is dangerous territory, however, since the Shop@ tool and others can produce very misleading results, something recognised by its authors.  Used in their default setting such tools simply grow existing levels of provision in-line with projected growth in the population of older people and hence where existing provision is inadequate they can be used to generate a set of figures which would only perpetuate that situation.  This weakness in the tools was identified in a recent appeal decision (APP/H2265/W/18/3202040) where the SHMA relied-upon by the council in determining the application and to inform their emerging local plan projected a need for no extra care housing for sale, on the basis that there was none at present.  As is clear from the new guidance, councils should assess whether the needs of the existing population are being adequately met and since the general pattern across the country is that provision fails to meet needs simply continuing in the same vein is not an appropriate or adequate response.  For the same reason, benchmarking against levels of provision elsewhere also has limited relevance.

The guidance stops short of requiring councils either to allocate specific site or to monitor delivery against needs, making both optional, but it does cite the benefits of doing so, particularly where an unmet need is identified.  However, they are now required to set clear policies to address the identified needs and councils are told they need to provide for specialist housing for older people where a need exists.  They may also set out how proposals for different types of housing will be considered.  Policies should also be based on a proportionate assessment of viability, which for some forms of specialist housing will be very different to standard market housing.

In practice there are few locations where there is not a significant under provision and an inadequate future pipeline of specialist accommodation for older people, so most councils will need to identify the range of needs and set out how they will be met.  Furthermore, the new guidance requires councils to take a positive approach to schemes that propose to address an identified unmet need – hence decision-makers must now grapple with the scale of the need and the adequacy of supply and give specific weight to the issue where there is an existing or likely future shortfall.  This is in addition to counting delivery of specialist housing against housing requirements, as clarified by the guidance.

On the thorny issue of Use Class the new guidance advises councils that they must consider whether proposals would be C2 or C3 taking into account factors such as the level of care and scale of communal facilities provided.  This will come as a surprise to those in local authorities who take the view that specialist housing for older people which provides all of the facilities for independent living cannot be considered C2 irrespective of care and communal facilities i.e. proponents of the ‘front door test’.

Support in the guidance for the application of the HAPPI design standards is welcome in the drive to ensure increasing quality alongside quantity of specialist accommodation whilst the opportunity for senior co-housing communities is exciting and a step on from Retirement Villages’ approach which actively involves residents in shaping the social life and activities which are so important in its developments.

The government has set out its position clearly in the context of the current chronic under supply of specialist housing for older people: meeting existing and future needs is critical and action is needed.  We look forward to seeing the effect of this ripple though the planning system.

Guy Flintoft

Planning Director, Retirement Villages