Testun llawn:
Thank you for the opportunity to comment on the consultation for the aforementioned document. As the market leader in the provision of sheltered housing for sale to the elderly, McCarthy and Stone Retirement Lifestyles Ltd considers that with its extensive experience in providing developments of this nature, it is well placed to provide informed comments on your 'Local Plan Preferred Options' insofar as it affects or relates to housing for the elderly.
McCarthy and Stone are satisfied that the Local Plan Preferred Option's report indicates that there is a 'need to provide more housing to meet people's needs in the future, particularly those of older people', and that this is clearly identified as an issue within the District. They are particularly pleased that the Local Plan aims to provide 'sustainable levels of growth in the district' by allowing 'providers to meet the special housing needs of the growing number of older people'. However, we are concerned with the distribution of housing, and would strongly encourage policy to express support for the re-development of urban brownfield land. My Client would stress that policy should give brownfield sites precedents over Greenfield sites / edge of settlements.
Furthermore, McCarthy and Stone commend the Local Plan's recognition of the 'need to provide more housing to ensure that the needs of current and future residents are addressed, particularly those of older people'; indicating that the 'the highest rate of projected population growth in the future is expected to amongst those aged 65 and over'. Furthermore, My Client is also pleased that the Local Plan quotes the SHMA's estimation 'that 18.7% of future need is likely to be for specialist housing'.
My client supports the proposed policy PO6: Mixed Communities & Wide Choice of Housing, which states that 'all strategic sites will include Extra Care Housing schemes located close to local facilities'; and that all 'proposals for Retirement Villages and Continuing Care Retirement Schemes will need to meet locational criteria and be accompanied by evidence that the homes/bed spaces meet the needs of the community'. However, McCarthy and Stone would stress that the policy should take into account general sheltered schemes, which will widen the housing choices available for older persons within Warwick District Council
The need for specialist housing for the elderly is expressed within the Strategic Housing Market Assessment (2011), which 'indicates that 9% of market demand (37 homes per annum) will be for specialist housing, particularly for older people'. Critically, the SHMA states that 'around three quarters of older person households are outright owners', and that older households are 'very likely to under occupy homes, with two-thirds living in homes with three or more bedrooms'. The SHMA also stipulates that 'there may be potential for policy to seek to reduce under-occupation by providing support and incentives to households to downsize. This may help to release larger housing for family households in priority need'. This is supported in the SHMA through a later statement that 'over the plan period to 2031 there should however be some potential to release supply of existing family housing by supporting downsizing of older households and providing specialist housing to meet their needs'. Additionally, the SHMA also states that 'the Council should consider inclusion of specific policies for specialist housing within the Local Plan on this basis. McCarthy and Stone would support this and encourage the Council to review and strengthen the policy for specialist housing for the elderly.
Despite the above, McCarthy and Stone is concerned that the draft Local Plan does not provide for the delivery of actual policies. There is clearly an existing and growing elderly population and a need for specialist housing. This is supported within the Local plan which states 'the SHMA estimates that 18.7% of future need [for market housing] is likely to be for specialist housing, of which 9.7% is likely to be for affordable specialist accommodation'.
It is therefore vitally important to address this need, as encouraged in the National Planning Policy Framework (NPPF). McCarthy and Stone would urge that a specific policy for elderly housing be introduced within your Local Plan.
McCarthy and Stone suggest that the following be introduced to positively support the delivery of specialised accommodation for older people including sheltered housing:
"Development proposals for accommodation designed specifically for the elderly will be encouraged provided that they are accessible by public transport or a reasonable walking distance to community facilities such as shops, medical services, places of worship and public open space."
The National Planning Policy Framework
It is necessary to consider the National Planning Policy Framework (NPPF) adopted on March 27th 2012. The NPPF states that at the heart of national policy is 'a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decision-taking'. The Ministerial foreword acknowledges the challenges the country faces in accommodating the growing elderly population, emphasising 'we must house a rising population, which is living longer and wants to make new choices', and 'development that is sustainable should go ahead, without delay - a presumption in favour of sustainable development that is the basis for every plan, and every decision'.
Within the 'three dimensions of sustainable development' (economic, social and environmental), the NPPF stipulates that the planning system should be 'supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations' [emphasis added]. The NPPF calls for local planning authorities to seek out opportunities 'to meet the development needs of their area', and emphasises that 'the Planning system should be pursing sustainable development through widening the choice of high quality homes'.
In addition to this, the Framework highlights the need to 'deliver a wide choice of high quality homes, widen opportunities for home ownership and create sustainable, inclusive and mixed communities. Local planning authorities should plan for a mix of housing based on current and future demographic trends, market trends and the needs of different groups in the community...such as older people' [emphasis added].
To ensure that the Warwick Local Plan is delivered in line with the NPPF, it is important to acknowledge the NPFF's statement that 'local planning authorities should use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market'. Reviewing the evidence within the Local Plan Preferred Options report, there is a clear market need for specialist housing for the elderly within Warwick. The Framework advises that:
'local planning authorities should have a clear understanding of housing needs in their area', and that policy should 'identify the scale and mix of housing and the range of tenures that the local population is likely to need over the plan period which meets household and population projections, taking account of migration and demographic change and addresses the need for all types of housing...including housing for the elderly' [emphasis added].
Furthermore, the Framework stipulates that local policy should cater for 'housing demand and the scale of housing supply necessary to meet this demand'.
It is therefore considered that much needed housing for the elderly should be encouraged, and that appropriate planning policy should play a part in delivering specialist housing to meet an evident housing need.
Policy PO5: Affordable Housing
In response to Policy PO5: Affordable Housing, and the fact that the policy will apply to 'developments which contain self-contained units of accommodation including specialist homes for older people', my Client would highlight paragraph 7.56 within the Local Plan Preferred Options, which stipulates that '18.7% of future need is likely to be for specialist housing...This type of housing is most likely to be for older households'. Therefore, the Local Plan recognises the need for specialist accommodation for the elderly.
A recent report "Housing Markets and Independence in Old Age - Expanding the Opportunities", by Professor Michael Ball of the University of Reading, which was presented at a House Commons launch event in May 2011, should be reviewed. This report, suggests that private sheltered housing for the elderly could be given an enhanced planning status, similar to affordable housing, to encourage sufficient levels of delivery from the private sector to meet existing and future demand, stating that:
'to improve the supply and lower the price of owner occupied retirement housing (OORH), this type of housing should be redefined as the equivalent of affordable housing in terms of negotiations with builders over development charges. Treating all OORH as a form of affordable housing in planning terms, because of its significant personal and community benefits, would help reduce prices and increase availability. However, to impose price or quality caps on part or all of it would damage supply. Rather this proposal suggests that all OORH new build should be given enhanced planning status alongside low-cost home ownership for younger households, which is already treated as a form of affordable housing' (emphasis added).
PO12: Climate Change
McCarthy and Stone are concerned about the inclusion of Policy PO12, and the viability of specialist housing for the elderly if this is enforced. McCarthy and Stone are particularly concerned with the 'requirement that seeks a 20% reduction in carbon emissions from development to include a contribution from renewable and low carbon technologies'. This 20% reduction is not in line with Building Regulations and national policy, which suggest a 20% reduction is only achievable by 2020.
Conclusion
The provision of owner-occupied specialised housing for the elderly will widen the housing choices available for older persons within Warwick District Council. It will allow the local elderly population to move into accommodation that enables them to remain living independently within the community and out of institutions, and therefore continue to contribute to the community, whilst enjoying peace of mind and receiving the support that they need.
McCarthy and Stone stress the need to consider addressing the current and future housing needs of older people within your Local Authority, and for your 'Local Plan Preferred Options' to further acknowledge the role that owner-occupied sheltered housing play in meeting older person housing needs, as well as Extra Care schemes, and in providing housing choice for the wider community by freeing up valuable, under-occupied family homes in the local area.