Insight focus upload guide

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Insight focus upload guide

The following webpage is a procedural guide to uploading an insight focus to the Lichfields website.

This Insight Focus follows on from Lichfields’ national research, Solutions to an Age Old Problem, in exploring the planning issues and the policy context for older people’s housing in London.
The number of people aged 65 and over in London is expected to increase by 71% between 2019 and 2044, equivalent to 786,600 people. This includes an additional 321,000 people aged 85 and over , almost double the current number (i.e. an increase of 104%)[1] . By comparison, the overall population is anticipated to increase by 20% during this period.
 
All of the 33 local authorities in the Capital are expected to experience significant growth in the number of people aged 65 and over during the 25-year period, ranging from 108% in Tower Hamlets to 38% in the City of London and 48% in Havering, the next lowest. The highest absolute increase is expected in Barnet (44,600 people) and Croydon (39,900).
 
 
       

HEADLINE FIGURES
 
 

 

Need for specialist housing

Most older people live in general housing. However, for a variety of reasons many people will move to specialist housing at some point in their lives. Key factors affecting accommodation choices include the individual’s health, financial position, the desire to be closer to family, the suitability of their current accommodation and the extent to which it can be adapted to meet specific needs.
 
Based on the anticipated population growth of older people in London, approximately 81,800 additional specialist units will be required in the Capital between 2019 and 2044[x].
 

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Types of housing for older people

A wide range of different specialist housing and accommodation products are now available for older people. The most commonly applied categories are summarised in Figure 2:
 
Figure 2 Key types of accommodation for older people

Source: Source: Elderly Accommodation Council National Housing Database (2014)

 
Additional facilities, such as shops, restaurants and recreational facilities are often provided at retirement developments that offer self-contained units.
 
In addition to the types of housing above, whilst not traditionally classed as older people’s housing, there are also park homes (mobile homes): pre-fabricated single-storey homes designed for permanent residence and aimed at older people.
 
  

National planning policy context

 

National Planning Policy Framework

The revised National Planning Policy Framework (NPPF) (February 2019) states that planning policies should reflect the size, type and tenure of housing needed by different groups, including older people .
 
The NPPF defines older people as:
   
“People over or approaching retirement age, including the active, newly-retired through to the very frail elderly; and whose housing needs can encompass accessible, adaptable general needs housing through to the full range of retirement and specialised housing for those with support or care needs.”
(Lichfields emphasis)
 
 

Planning Practice Guidance

The Planning Practice Guidance (PPG) states that the need to provide housing for older people is “critical” . It emphasises that strategic policy makers should consider both how to support older people to live independently and safely in their own homes and should support the provision of specialist accommodation, e.g. sheltered, extra care and registered care. It states that:
“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 … Plan-making authorities should set clear policies to address the housing needs of groups with particular needs such as older and disabled people .

 

Housing Delivery Test

The revised NPPF introduced the new Housing Delivery Test (HDT), an annual measurement of housing delivery, against which local planning authorities are judged, and sanctions applied, in order to boost supply. The first HDT results were published in February 2019. The HDT 2018 Measurement Technical Note states that the delivery of bedspaces in communal establishments, e.g. residential care homes, will be counted towards this test on a pro rata basis . This means that delivery of all types of specialist accommodation for older people will contribute towards local authorities’ housing supply and can help them meet the HDT.

 

Housing for Older People Inquiry

In its response to the Housing, Communities and Local Government Select Committee inquiry into Housing for Older People (2017-19) , the Government emphasised its commitment to “do more to ensure that more homes suitable for older people are being built” . It also recognised the need to provide a better choice of accommodation for older people to “enable them to live independently for longer, improve their quality of life and free up more family homes for other buyers”.

 

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Local planning policy

Lichfields has undertaken a review of the treatment of housing for older people in Local Plans in London. The results of this analysis are summarised in Table 1.
 
Ten of the 33 authorities in London (Brent, Bromley, Hackney, Harrow, Havering, Islington, Lambeth, Lewisham, Sutton and Waltham Forest) publish monitoring information on the delivery of housing for older people.
  
Figure 3: Analysis of Local Plans in London

Source: Lichfields analysis

 
Table 1 demonstrates that whilst relatively few local authorities have allocated land specifically for housing for older people in most authorities there are supportive policy “hooks“ to support planning applications for older people’s housing.
 
If we are to see a step change in the delivery of accommodation for older people, there is a need for stronger local policy to support this type of housing Recommendations for national policy changes are set out in Lichfields’ Insight: Solutions to an age old problem.)
  
Appendix 1 summarises the Local Plan status in each London Borough and identifies the policy measures currently in place to meet the need for housing for older people. It also highlights areas where there may be opportunities to promote sites for housing for older people as part of the Plan-making process. However, many of these plans may need to be revised to reflect national policy changes in the revised NPPF. Hence, there will be opportunities in many areas for the development industry to influence the formulation of new policy that effectively supports the delivery of older people’s housing.

 

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Appeal decisions: Key planning considerations

Lichfields has analysed 23 recent appeal decisions associated with older people’s housing in London (post NPPF).
  

Use Class: C2 or C3?

Traditional residential care homes, where meals and other facilities are provided on a communal basis, will fall within Use Class C2. However, for self-contained housing types such as extra care/assisted living, where some communal facilities and personal care are provided, the distinction is less clear. This was a point of contention in several of the appeals assessed.
 
The assigned use class has financial implications regarding policy requirements and obligations, such as CIL charges and affordable housing requirements. C3 uses typically attract planning obligations, whilst those in C2 do not.
 
The Town and Country (Use Classes) Order 1987 definition of Use Class C2 (Residential Institutions) includes:
 
  1. “Use for the provision of residential accommodation and care to people in need of care (other than a use within class C3 (dwelling houses))”; and,
     
  2. “Use as a hospital or nursing home”.
 
The definition of Use Class C3 (dwelling house) includes the qualifying characteristic that residents form a single household, whether or not care is provided. Article 2 of the Town and Country Planning (Use Classes) Order 1987 defines “care” as personal care for people in need of such care by reason of, inter alia, old age. Personal care has been defined in one appeal as including a broad range of assistance, for example aiding in use of internet, accompanying residents to on-site activities, as well as more traditional means of care. However, most appeals applied a narrower definition of care, e.g. personal hygiene, dressing, feeding.
  

Appeal Decisions in London

Figures 2 and 3 summarises the key factors that were considered by Inspectors to give weight to the developments providing for specialist homes for the elderly in London.
 
Figure 4: Key factors leading to the Inspectors Allowed and Dismissed Decisions

 
Source: Lichfields analysis of appeal decisions relating to older people’s accommodation  

   

Of the 23 appeal cases reviewed 14 were dismissed and 9 were allowed. In the majority of cases dismissed, the reason related to lack of affordable housing provision associated with the C3 use.
 
In many cases general planning principles (e.g. the sustainability of the location) and site-specific factors (e.g. impact on highway safety) were considered to outweigh the benefits of providing accommodation for older people, and the need for specialist housing was not a determinative factor. However, in the case of Wandsworth[1] the Inspector and Secretary of State found that the benefits of a proposal which included MOL within the Appeal site, would not be harmfully affected, would increase its openness and would benefit from the changes proposed. These benefits included its improved mental health facilities, the contribution to housing supply, the provision of land for a school and the overall benefits to the MOL collectively outweigh the level of harm identified and that the very special circumstances therefore justify the loss of MOL.

 

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Summary

Whilst there are policy “hooks” in many adopted Local Plans in London that support proposals for older people’s housing and the new London Plan goes some way to further support the need for homes for older people, far more still needs to be done to plan positively for this rapidly expanding section of the population and meet the need for 81,800 additional specialist units. The preparation of new and future revised Local Plans in London will offer valuable opportunities for the development industry to engage with policy makers and champion the need for a step change in the delivery of homes for older people.
 
There is no evidence to suggest that the benefits of providing older people’s housing will overcome objections that would render a site unsuitable for general residential development. It is therefore important that development proposals for older people’s accommodation are accompanied by robust evidence to demonstrate the need for and the advantages of this specialist type of accommodation. Lichfields’ Carepacity Toolkit can assist in this.
  
 
 

Related products

 

Carepacity

Making the case for care, retirement and sheltered housing
 
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Carepacity

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Making the Economic Case for Development
 
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Sizemix

Securing the right mix in residential development proposals
 
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Sizemix
   

 

 

Footnotes

 

[1] GLA 2016-based household projections, central trend

[2] Assessed using the national standard ratio of 170 units per 1,000 people aged over 75 identified by the Housing Learning and Improvement Network (HLIN).

[3] NPPF, paragraph 61

[4] As at 26 June 2019

[5] Reference ID: 63-001-20190626

[6] Reference ID: 63-001-20190626

[7] Reference ID: 63-006-20190626

[8] The HDT is based on the number of net homes delivered. Bedrooms in communal establishments are included based on a ratio of the average number of adults per household in England from the most recent Census (1.8 in the 2011 Census).

[9] Housing, Communities and Local Government Committee, Housing for Older People: Second Report of Session 2017-19 (9 February 2019)

[10] Government Response to the Second Report of Session 2017-19 of the Housing, Communities and Local Government Select Inquiry Committee inquiry into Housing for Older People (September 2018)

[11] The revised NPPF states at paragraph 212 that plans may need to be revised to reflect national policy changes. However, it sets out at paragraph 213 that existing policies should not be considered out-of-date simply because they were adopted prior to the publication of revised NPPF.

[12] Land at Springfield University Hospital, 61 Glenburne Road, London, Wandsworth (Appeal Ref APP/H5960/A/11/2156427)

 

 

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