Chichester Local Plan 2021 - 2039: Proposed Submission

Policy H5 Housing Mix 1.
We support Policy H5 Housing Mix in its provision to allow older person’s housing schemes to provide an alternative housing mix to that detailed within the most up to date Chichester HEDNA, 2022, Iceni.

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.

Recommendation
In order for Policy H8 to be more positively prepared to assist in delivering the substantial need for specialist housing for older people, policy H8 should be amended so that it reads as follows:

Policy H8 Specialist accommodation for older people and those with specialised needs

Specialist housing for older people

All housing sites over 200 units, including those allocated in this plan, will be required to provide specialist accommodation housing for older people.

The Council will also support proposals delivering specialist housing for older people across all tenures in sustainable locations. Specialist housing for older people should be located in in close proximity to everyday services, be well connected by safe and suitable walking / cycling routes or public transport for the intended occupier.

Specialist housing
Proposals for specialist housing, such as homes for, students, HMOs or essential worker accommodation37, and other groups requiring specifically designed accommodation will be supported where the following criteria are met:
1. There is an identified need;
2. It will not lead to a concentration of similar uses in an area that would be detrimental to the character or function of an area and / or residential amenity;
3. It is in close proximity to everyday services, connecting by safe and suitable walking / cycling routes or public transport for the intended occupier;
4. It can be demonstrated that the development is designed to provide the most appropriate types of support for the target resident;
5. It can be demonstrated that revenue funding can be secured to maintain the long-term viability of the scheme (if relevant to the type of accommodation proposed); and
6. The scheme is supported by the relevant agencies (if relevant to the accommodation type to be provided).

Proposals which may result in the loss of specialist needs accommodation will not be permitted unless it can be demonstrated that there is no longer a need for such accommodation in the plan area, or alternative provision is being made available locally through replacement or new facilities.

Policy H8 Specialist accommodation for older people and those with specialised needs

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.

Whilst we are encouraged by ‘Policy H8 Specialist accommodation for older people and those with specialised needs’ we feel that trying to combine a policy on encouraging specialist housing for older people and specialist accommodation has resulted in a confusing policy that is not positively prepared. Given the substantial need for specialist housing for older people identified within the Chichester Housing and Economic Development Needs Assessment, 2022, Iceni (HEDNA) we feel the policy should be redrafted to make it clearer and more consistent with national policy as detailed in our response to policy H5 Housing Mix and specifically paragraphs 001 Reference ID: 63-001-20190626, 003 Reference ID: 63-003-20190626 and 006 Reference ID: 63-006-20190626 of PPG Housing for Older and Disabled People. This should ensure that some of the substantial need for specialist housing for older people is delivered without applicants having to consider policy requirements that would not be relevant for such schemes.

In addition, developers of older people’s housing schemes should not be required to demonstrate need given the substantial need identified.

Recommendation:
The policy should be amended to reflect the building regulations so it reads as follows:

Policy H10 Accessible and Adaptable Homes

On all residential development sites:
a. 5% of affordable housing must meet wheelchair accessibility standards M4(3)((2)(b)) where there is an identified need on the Housing Register and the Council will have nomination rights.

Policy H10 Accessible and Adaptable Homes
The Council should note that ensuring that older residents have the ability to stay in their homes for longer through the provision of wheelchair housing, is not, in itself, an appropriate manner of meeting the housing needs of older people. Adaptable houses do not provide the on-site support, care and companionship of specialist older persons’ housing developments nor do they provide the wider community benefits such as releasing under occupied family housing as well as savings to the public purse by reducing the stress of health and social care budgets. The recently published Healthier and Happier Report by WPI Strategy (September 2019) calculated that the average person living in specialist housing for older people saves the NHS and social services £3,490 per year. A supportive local planning policy framework will be crucial in increasing the delivery of specialist older persons’ housing and it should be acknowledged that although adaptable housing can assist it does not remove the need for specific older person’s housing. Housing particularly built to M4(3) standard may serve to institutionalise an older person’s scheme reducing independence contrary to the ethos of older persons and particularly extra care housing.

The Council should note that M4 (2) is to be incorporated into the Building Regulations and therefore there is no need for the plan to repeat this element and this element should be removed form the plan so as not to repeat other government requirements. The Council should also note that M43b relates to wheelchair accessible housing which can only be required on affordable housing where the Council has nomination rights and this should be clarified so that this is clear to the reader.

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In light of our comments we would recommend that the Council ensure that there is sufficient headroom in the viability of developments and that its policy requirements are robustly tested and the inputs for water neutrality and nitrate neutrality in particular are re-evaluated.

Policy H4- Affordable Housing

The Local Plan is one of an alarmingly limited number of emerging Local Plans that have set a differential affordable housing rate. The policy stipulates that affordable housing requirement of 40% on Greenfield sites and 30% on previously developed land. This is commendable and suggests a greater focus on viability in the Plan making stage. The affordable housing target set out in Policy H4 are informed by the evidence base, namely the Viability Assessment taken by Dixon Searle Partnership, hereafter referred to as the viability assessment. We commend the Council for making the report available at the Regulation 18 stage.

We note that the viability assessment has assessed the viability of the extra care older persons housing typologies and that reference is also made to Sheltered housing typologies. We would recommend caution as the viability assessment clearly shows that specialist housing for older people is only marginally viable using the inputs that Dixon Searle have adopted. We are also concerned that the level of financial contributions attributed to achieving nitrate neutrality and water neutrality are massively underrepresented, we believe that figures could be up to £8k a unit for nutrient neutrality (based on examples requested in other LPAs) and given there are no example of off-site credit systems, a similar figure could potentially be required again for water neutrality. The implications of £157.2 per square metre towards CIL contributions on a 50-unit retirement scheme, in conjunction with the other s106 contributions would be as follows:

• Nutrient Neutrality is £2k per unit = £100k
• Water Neutrality is £2k per unit = £100k
• SPA mitigation - £625 per dwelling = £31,250
• Residual S106 - £1500 per unit - £75k
• A827 contribution £8k (assumed to be per development not per dwelling)

This would mean that there would be contributions of around £974,000 on an average scheme in the south of the District before affordable housing is calculated. This has massive implications for the viability of retirement housing schemes for which there is a critical need in the area, and as we are not confident that the. Figures are appropriate for nutrients and water neutrality, this could mean that some retirement housing schemes are rendered unviable by these inputs.

In light of the above, we would suggest that the Council ensure that there is sufficient headroom in the viability of developments and that its policy requirements are robustly tested and the inputs for water neutrality and nitrate neutrality in particular are re-evaluated.