Is specialist elderly accommodation keeping pace with the South West's ageing population?

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Planning should care, but does it?

Is specialist elderly accommodation keeping pace with the South West's ageing population?

The early 2023 consultation as part of the Levelling-up and Regeneration Bill proposing reforms to national planning policy, along with publication of the 2021 Census data, has refocused minds on the important issue of an ageing population and the urgent need to provide more specialist accommodation for older people. The draft has a specific expectation that, in ensuring needs of older people are met, particular regard is given to retirement housing, housing with care and care homes. This differs from current policy, which does not set the expectation for retirement housing or housing with care to be incorporated when calculating need. The draft National Planning Policy Framework therefore expressly supports the supply of older people’s housing.
 
The urgency of addressing this has been stressed by a report by the BPF and Cushman & Wakefield (Housing for an Ageing Population) with recommendations for the Government’s now launched Housing for Older People Taskforce. The statistics are clear; there are only enough senior housing units to cater for 5.6% of the current over-65 population, with that demographic due to grow by 31% by 2040. The BPF therefore recommends a target of 50,000 new seniors’ housing units to be delivered each year.
 
In 2019, Lichfields produced the Insight Focus ‘Solutions to an age old problem in the South West’, which explored the planning policy context for older people’s housing in the region. This concluded that far more needed to be done to positively plan for this demographic, with new and revised Local Plans coming forward in the region offering valuable opportunities for the development industry to engage with policy makers and champion a step change in the delivery of homes for older people.
 
Four years on, and in the context of this current Government spotlight, this Insight Focus explores what change, if any, has or is occurring in policy, plan making and supply, to help bridge the gap between elderly accommodation provision and an ever-increasing elderly population within the context of a deepening national housing crisis. It also considers where the potential opportunities lie in promoting and better supporting this type of housing through the planning system.
 
  

Population age continues upwards

The 2021 Census data evidences the continuing ageing of the population. In England, more than one in six people (18.4%) were aged 65 years and over on Census Day in 2021 - a higher percentage than ever before – which is predicted to further increase to one in four by 2041. The South West exceeds the average, with 22.3% of its population being over 65 (up from 19.6% in 2011). The region has the highest median age (44 years) in England; in 2011, the largest age group was those aged 45 to 49 and by 2021 this had shifted to those aged 55 to 59. Whilst this is not immediately relevant to care accommodation, it clearly shows that the level of demand is set to increase even more considerably in the next 10-20 years. This trend is also consistent with older age groups in the South West, with the numbers of those aged 65 to 74 and 75 to 84 increasing by 25% and 24% respectively.
 
This demonstrates the critical importance of meeting the substantial and growing housing needs of this population demographic in the South West in particular.
 
 

Headlines

  1. There are only enough specified older people’s housing units to house 5.6% of the current population of over 65’s across the UK.
     
  2. In the South West alone there were 63,000 additional people aged 65+ in the ten years from 2011-2021, an average of 6,300 per annum.
     
  3. In each of the 10 South West LPAs researched in this Insight, an average of only 27 older people’s units were approved annually since Local Plan adoption – a significant under-delivery. 

 

  

Reforms to National Planning Policy

Recognising the increasing need for older people’s housing, the January 2023 reform consultation proposed further support for specialist elderly housing. Chapter 5 of the consultation, ‘More older people’s housing’, set out the government’s commitment to improving the diversity of housing options available to older people and boosting the supply of specialist elderly accommodation.
 
This was reflected in the NPPF consultation document, which included additional expectations that planning policies should specifically reflect the size, type and tenure of housing needed by older people, including retirement housing, housing with care and care homes (para.63). No change to the definition of ‘older people’ was proposed.
 
  

British Property Federation Recommendations 2023

The BPF’s report proposed a target for housebuilders to deliver 50,000 units a year for seniors within the UK. This has been tied to the proposed introduction of a new use class, CR2, specifically for older people's housing. The proposal comes as a response to the vast demand for older people's housing, and continued anticipated growth, whilst also seeking to reduce the ambiguity surrounding the differentiation between C2 and C3 housing for older people. An independent use class can ensure that the specific need for older people’s housing is met by its own targets, and is not tied to 5-year housing land supply.
 
The suggestion of a new use class has the potential to tackle current barriers to provision of older people's housing, including demand around community infrastructure levy and obscurity of specific figures for delivery included within Local Policy plans and monitoring. National Government seems to have a juxtaposing approach to delivery of senior housing, having recently formed the Older People's Housing Taskforce whilst simultaneously proposing to remove housing targets. BPF chief executive comments, "The recent decision to remove housing targets will further constrain delivery at a time when local authorities need to clearly set out allocations for senior housing that reflect local demand." Whilst the decision has not yet made its way into policy, the point stands that the removal of housing targets in general may well reduce pressures to provide the housing suitable for more dependent groups of people, including those in the >65 category.
 
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Policy Approach in the South West

Since the publication of Lichfields’ previous insight (April 2019), six Local Planning Authorities (LPAs) in the South West have adopted new or revised Local Plans: Bath and North East Somerset (BANES); Cheltenham and Gloucester City (under the context of the Joint Core Strategy and emerging Joint Spatial Plan); Mendip (incorporated into the new Somerset Council as of April 2023); Mid Devon; and, Tewkesbury.
 
Although all six of the Local Plans include supportive policies for housing for older people, none include specific requirements to deliver older people’s housing. Of the six, only Mid Devon’s new Local Plan includes an allocation with a specific requirement for ‘extra care housing’. The allocation, Policy CU1, requires the provision of affordable extra care housing under broader affordable housing provision, for older people to live independently with 24 hour care and onsite services. Policies CU6 and CU7 also include the need for extra care housing within the allocations, but don’t include specifics as to the level of care provision.
 
It appears, unsurprisingly, that in recent years little has changed in the local policy approach to support the delivery of older people’s housing in the South West. This demonstrates the need for a national focus on delivering older people’s housing, with the potential reforms to the NPPF necessitating revisions to Local Plans with a focus on need and delivery. This provides a key opportunity to promote land and positively influence local policy.
 
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South West Localised Delivery

To analyse delivery in the South West, Lichfields has reviewed a sample of ten local planning authorities (LPAs). These were selected to include a range of urban, rural and coastal authorities in the region, and avoid a bias of areas with typically older populations (e.g. the coastal regions). Of the LPAs studied, Table 1 shows the population % in each aged 65 and over, and how this has grown in the 10 years to 2021.
 
Table 1: % of total population aged 65 and over
 
LPA
2011 +65
POPULATION %
2021 +65
POPULATION %
% CHANGE – PERCENTAGE POINTS (POPULATION INCREASE/DECREASE)
 
 
Cornwall
21.7
25.3
+3.6 (28,959)
  
 
Torbay
23.6
27.5
+3.9 (6,346)
  
 
Mid Devon
20.4
24
+3.6 (4,035)
  
 
BANES
18.1
19.3
+1.2 (5,583)
  
 
South Gloucestershire
16.9
18.7
+1.8 (9,691)
  
 
Bristol
13
12.9
-0.1 (4,928)
  
 
N Somerset
21
24
+3 (9,367)
  
 
N Devon & Torridge
26.2
26.9
+0.7 (9,114)
  
 
Sedgemoor
20.6
23.8
+3.2 (6,335)
  
 
Mendip
19.5
23.8
+4.3 (6,322)
  

Source: ONS Census data, 2021 and 2011.

 
  

Planning permissions

Having carried out a search of online planning history records, Lichfields has undertaken an initial review of planning permissions granted for elderly housing in each of the sample LPAs in the period from Local Plan adoption to April 2023. These are shown in Table 2. This is then compared to projected need calculated by Lichfields for the period 2021-2033, to understand how projected delivery (subject to these permissions being built-out, which is by no means certain, and a continued trend) compares to need, and giving an initial indication of how an LPA might perform in meeting its need.
  
Table 2: Annual permitted older people’s dwellings by LPA and Lichfields’ projected need in each LPA to 2033.
 
  LPA
Total older people’s dwellings permitted since LP adoption
Local Plan age (years to 2023)
Mean annual older people’s dwellings permitted
Projected annual need until 2033 (from 2021)*
Shortfall against average annual permissions to date
  
 
Cornwall
677
7
96.71
391
2,064
  
 
Torbay
230
8
28.75
88
474
  
 
Mid Devon
10
3
3.33
41
113
  
 
BANES
571
9 (since original, partial update in 2023)
63.44
75
104
  
 
South Gloucestershire
1503
10
150.3
103
-473
  
 
Bristol
298
12
24.83
90
782
  
 
N Somerset
246
5
49.2
111
309
  
 
N Devon & Torridge
98
5
19.6
111
457
  
 
Sedgemoor
11
4
2.75
88
341
  
 
Mendip
174
9
19.33
86
600
  

 

*Data provided by Housing LIN identifies a national average of 170 units of specialist accommodation for every 1,000 people over the age of 75. This comprises 145 units of sheltered accommodation and 25 extra care bedspaces. These figures have been applied to the projected increase in the number of people over the age of 75 in each local authority area between 2021 and 2033 (based on the 2021 census and the 2018-based Sub National Population Projections). The figures presented represent the annualised assessment of future need. In considering these figures, it is important to note that the demand for such facilities is not necessarily limited to people over the age of 75. Many sheltered housing schemes are available for people over the age of 55 or 60 and to the evidence of need based on the increase in the number of people over the age of 75 may serve to under-estimate the true level of need that exists.

 

Based on the average of annual dwellings permitted, of the ten sample LPAs, only South Gloucestershire Council could meet its projected need for older people’s dwellings over the next ten years, should current permission rates continue/permitted schemes be built-out; the shortfalls are very significant.
 
With the exception of South Gloucestershire and BANES, permissions to date show a trend of meeting less than half of the projected annual need to 2033.
 
This initial research evidences substantial under-delivery across the South West and an ongoing and worsening position whereby current need is unmet each year; this gap is only set to widen looking at Lichfields projected need to 2043 (see graph below). Cumulatively, and in the context of an increasing ageing population, this will inevitably lead to a growing crisis in older people’s housing. This  must be urgently addressed by both national and local government through proactive planning policy, decision making and monitoring, as the implications of under-supply are significant and include: a failure to adequately cater for elderly needs; people living in unsuitable and unsustainable accommodation; substantial costs to the NHS and an inability to free-up much needed housing for other population age cohorts, with knock-on impacts on the wider housing crisis.
 

*Data provided by Housing LIN identifies a national average of 170 units of specialist accommodation for every 1,000 people over the age of 75. This comprises 145 units of sheltered accommodation and 25 extra care bedspaces. These figures have been applied to the projected increase in the number of people over the age of 75 in each local authority area between 2021 and 2033, and 2021 and 2043 (based on the 2021 census and the 2018-based Sub National Population Projections).

   

 

Monitoring

Lichfields has reviewed the Annual Monitoring Reports (AMRs) for the sample LPAs. Only three of the ten include permissions granted for C2 units for older people: Sedgemoor, Mid-Devon and South Gloucestershire. These report permissions granted, not delivery. Our projections estimate that, from 2021 to 2033, 1,050 older people’s C2 and sheltered C3 units will be needed in Sedgemoor. However, Sedgemoor’s AMR shows no older people’s C2 units were permitted in 2020/21 – clearly more needs to be done to address need and secure delivery.
 
Cornwall monitors care home bed figures independently of its AMR, although only states the total loss/gain of beds. However, the authority does not monitor sheltered care accommodation. Despite delivering an additional 35 care home beds between 2021 and 2022, the net loss in beds for the period is -314, starkly juxtaposing trends in population data. Their need for care home beds increases by 23 beds per annum.
 
The other LPAs in the sample do not monitor housing for older people within their AMRs.
 
To ensure the needs of the growing population aged 65 and over are met, a consistent approach is needed. This should support a Plan-led approach to planning for and delivering for this important cohort of the population, and in turn freeing up the standard housing stock for the younger demographic. If under-delivery continues and the population continues to age (which it will) then the issue will clearly worsen, and it is necessary that this is given policy attention on a national basis; it has implications across the board.
 
In the absence of supportive policy and proactive allocation, it continues to fall to promoters/developers/providers to demonstrate need and how this differs from standard market housing. This was the approach taken by Lichfields for a recent scheme in Torbay.
 
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Rowcroft Hospice, Torbay

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Between 2011 and 2021, the number of people aged 65-74 in Torbay increased by 23.5%. Torbay’s population has a higher average age than the South West as a whole. There is, therefore, an acute need for older people’s housing. Despite this, Torbay’s Local Plan (adopted 2015) does not include a policy requirement or any allocations to deliver elderly accommodation. Its policy for ‘Housing for people in need of care’ requires proposals for new care homes and extensions to existing care homes to provide “clear evidence of need”. The same approach has been taken within Torbay’s draft Housing policies for the Local Plan Update during Regulation 18 consultation, with no proposed allocations for older people’s housing.
 
In May 2023 Lichfields secured planning permission for the redevelopment and significant expansion of Rowcroft Hospice in Torquay. The scheme will deliver a 14-bed state-of-the-art hospice, a 60-bed specialist dementia care nursing home and 40 assisted living units (C2 Use Class), providing a significant level of support for Torbay’s ageing population. The planning application was accompanied by a detailed ‘Assessment of Need for Specialised Accommodation for Older People’ which provided strong and compelling evidence for each element of the specialist accommodation proposed. This is an approach Lichfields can take to support planning applications. However, the approach should also be applied to policy representations and site promotion at the Plan-level; this goes to emphasise the clear need that exists and how policy should proactively support delivery and not require each proposal to demonstrate ‘clear evidence of need’.
 
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Conclusion

Since Lichfields’ previous Insight Focus was published in 2019, the South West’s population has continued to age, and with it an ever-increasing need for elderly housing which is being significantly underdelivered at the local level. Nationally, the government is beginning to recognise this, establishing the Taskforce, with active lobbying by key groups such as the BPF. Much remains to be done, and the position worsens each year; planning is a critical path to address this chronic issue and there are a number of opportunities here which must be realised. These include:
  
   
1. Preparing detailed and robust evidence to support planning applications for older people’s housing, to ensure the need is fully understood and the benefits given sufficient weight.
 
  
 

2. Preparing representations to Local Plan consultations to demonstrate need for this specific type of housing, the implications for wider housing need/affordability and the importance of setting targets and monitoring permissions and delivery on a consistent basis. Associated policy support based on local need.
 
  
 
 
3. Promoting land to be allocated for this specific housing need, in the context of no.2 above.
 
  
 
 
4. Researching the specific needs of this demographic and the design implications, which would in turn encourage the elderly population to move from ‘standard’ housing into older people’s housing, whether that be in the form of a retirement community, assisted living units, extra-care etc. and open up the wider housing stock for the younger population cohorts, assisting with wider housing need and affordability.
 
  
 
 
5. Lobbying/making representations to the government – through the Taskforce and beyond – to assign older people’s housing its own Use Class, making clear the infrastructure levies and associated planning contributions attributable and therefore providing critical clarity to support the viability and deliverability of this housing type.
 
  

  

  

We would welcome the opportunity to discuss this further with promoters, providers, local authority planners and others to understand how we can work together to proactively assist in facilitating delivery and meeting the needs of this demographic – given the implications for all population cohorts and the wider housing market.
 
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Disclaimer

This publication has been written in general terms and cannot be relied on to cover specific situations. We recommend that you obtain professional advice before acting or refraining from acting on any of the contents of this publication. Lichfields accepts no duty of care or liability for any loss occasioned to any person acting or refraining from acting as a result of any material in this publication. Lichfields is the trading name of Nathaniel Lichfield & Partners Limited. Registered in England, no.2778116

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