Recommendation
To be consistent with national policy, positively prepared, effective and justified para 5.41 should be amended as follows:

Amend para so it reads 5.41 as follows:

5.41. The Housing and Economic Development Needs Assessment (HEDNA) 2022 estimates the greatest population increase in the district by 2039 to be those in age groups 75 and over. To support an ageing population there should be provision around 2,369-3,317 units of specialist housing to meet the needs of older people delivered in Chichester over the plan period. This amounts to around 132-184 units per annum some 17% to 24% of all homes. Suitable housing options for the differing needs of individuals, include:
• age restricted general market housing,
• Retirement living or sheltered housing,
• extra care housing or housing with care,
• residential care homes and nursing homes

Para 5.41 - Housing for older people
Thank you for the opportunity to comment on the Chichester Local Plan 2021-2039 Proposed Submission Draft (Regulation 19) consultation. McCarthy Stone is the leading provider of specialist housing for older people.
Para 5.41 identifies that the Chichester Housing and Economic Development Needs Assessment, 2022, Iceni (HEDNA) ‘estimates the greatest population increase in the district by 2039 to be those in age groups 75 and over’. The paragraph then continues to confirm the kind of housing that may be suitable and this includes ‘Sufficient adaptable and/or accessible market housing stock so that those wishing, to remain in their own homes can do so as their needs change, Smaller homes, for those wishing to downsize, and bungalows, Extra care housing, for those able to live relatively independently but requiring onsite support, Care homes, for those needing additional support’.
Government’s policy, as set out in the revised NPPF, is to boost significantly, the supply of housing. Paragraph 60 reads:

“To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.”
The revised NPPF looks at delivering a sufficient supply of homes, Paragraph 62 identifies within this context, the size, and type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies including older people.

In June 2019 the PPG was updated to include a section on Housing for Older and Disabled People, recognising the need to provide housing for older people. Paragraph 001 Reference ID: 63-001-20190626 states:

“The need to provide housing for older people is critical. People are living longer lives and the proportion of older people in the population is increasing. In mid-2016 there were 1.6 million people aged 85 and over; by mid-2041 this is projected to double to 3.2 million. Offering older people a better choice of accommodation to suit their changing needs can help them live independently for longer, feel more connected to their communities and help reduce costs to the social care and health systems. Therefore, an understanding of how the ageing population affects housing needs is something to be considered from the early stages of plan-making through to decision-taking” (emphasis added)

Paragraph 003 Reference ID: 63-003-20190626 recognises that:

“the health and lifestyles of older people will differ greatly, as will their housing needs, which can range from accessible and adaptable general needs housing to specialist housing with high levels of care and support. For plan-making purposes, strategic policy-making authorities will need to determine the needs of people who will be approaching or reaching retirement over the plan period, as well as the existing population of older people.”

Thus, a range of provision needs to be planned for. Paragraph 006 Reference ID: 63-006-20190626 sets out:

“plan-making authorities should set clear policies to address the housing needs of groups with particular needs such as older and disabled people. These policies can set out how the plan-making authority will consider proposals for the different types of housing that these groups are likely to require. They could also provide indicative figures or a range for the number of units of specialist housing for older people needed across the plan area throughout the plan period..”

Need for Older Persons’ Housing
It is well documented that the UK faces an ageing population. Life expectancy is greater than it used to be and as set out above by 2032 the number of people in the UK aged over 80 is set to increase from 3.2 million to 5 million (ONS mid 2018 population estimates).

It is generally recognised (for example The Homes for Later Living Report September 2019). That there is a need to deliver 30,000 retirement and extra care houses a year in the UK to keep pace with demand.

The Chichester HEDNA, 2022 update, Iceni, April 2022 at paragraph 8.43 identifies that ‘In total, the older persons analysis points towards a need for around 2,369 to 3,317 units over the 2021-39 period (132-184 per annum) – the older person need equates to some 17-24% of all homes needing to be some form of specialist accommodation for older people’.

It is therefore clear there will be a significant amount of specialist housing required to meet the needs of older people over the plan period and the provision of suitable housing and care to meet the needs of this demographic should be more of a priority of the emerging Local Plan in order for it to be positively prepared, effective and consistent with national policy. Para 5.41 should therefore be amended to identify this need.

Para 5.41 also identifies the kinds of housing that may be suitable to meet the housing needs of older people. However, these differ to the PPG on ‘housing for older and disabled people’ that at Paragraph: 010 Reference ID: 63-010-20190626 defines the different types of specialist housing for older people as being ‘age restricted general market housing, Retirement living or sheltered housing, extra care housing or housing with care, residential care homes and nursing homes’. Para 8.23 of the Chichester HEDNA also uses the definitions within the PPG. Therefore, to be consistent with national policy and the plans own evidence the definitions used in para 5.41 should also be amended to ensure consistency with national policy and to not eliminate an important element of older persons housing that being retirement living or sheltered accommodation.