Issue and Options 2023

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Q-H2-3: How should South Warwickshire best address the specialist needs for older people? Thank you for the opportunity to comment on the South Warwickshire Local Plan Issues and Options consultation. McCarthy Stone is the leading provider of specialist housing for older people. Please find below our comments on the consultation, which specifically addresses the need for specialist housing for older people. The Issues and Options consultation at Table 11, page 105 identifies a need of 234 dwellings per annum for both housing with support and housing with care. This has been derived from the Coventry & Warwickshire Housing and Economic Development Needs Assessment (HEDNA), Final Report, Iceni, November 2022. Page 105 of the consultation document , continues to question that ‘Given the high level of needs of older people, consideration may need to be given to where older people housing schemes are located and what the implications an increasing older population may have on the provision of health and social care services’. The best approach towards addressing the diverse housing needs of older people is for the plan to allocate specific sites to meet the needs of older people that are in the most sustainable locations close to key services as well as including a standalone policy actively supporting the delivery of specialist older people’s housing in the Market Towns and Larger Villages and other locations with good access to services and facilities for older people. Developers of older people’s housing schemes should not be required to demonstrate need given the many benefits that such developments bring and if a quantum is specified this should be regarded as a target and not a ceiling. Given also that such developments “help reduce costs to the social care and health systems” (PPG refers), requirements to assess impact on healthcare services and/or make contributions should be avoided. While we appreciate that no one planning approach will be appropriate for all areas, an example policy is provided that, we hope, will provide a useful reference for the Council: “The Council will encourage the provision of specialist housing for older people across all tenures in sustainable locations. The Council aims to ensure that older people are able to secure and sustain independence in a home appropriate to their circumstances by providing appropriate housing choice, particularly retirement housing and Extra Care Housing/Housing with Care. The Council will, through the identification of sites, allowing for windfall developments, and / or granting of planning consents in sustainable locations, provide for the development of retirement accommodation, residential care homes, close care, Extra Care and assisted care housing and Continuing Care Retirement Communities.” We would remind the Council of the increased emphasis on Local Plan viability testing in Paragraph 58 of the NPPF and that the PPG states that “The role for viability assessment is primarily at the plan making stage. Viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the plan” (Paragraph: 002 Reference ID: 10-002-20190509). The evidence underpinning the Council’s planning obligations and building requirements should therefore be robust. We would also like to remind the Council that the viability of specialist older persons’ housing is more finely balanced than ‘general needs’ housing and we are strongly of the view that these housing typologies should be robustly assessed in the forthcoming Local Plan Viability Assessment. This would accord with the typology approach detailed in Paragraph: 004 (Reference ID: 10-004-20190509) of the PPG which states that. “A typology approach is a process plan makers can follow to ensure that they are creating realistic, deliverable policies based on the type of sites that are likely to come forward for development over the plan period. If this is not done, the delivery of much needed specialised housing for older people may be significantly delayed with protracted discussion about other policy areas such as affordable housing policy requirements which are wholly inappropriate when considering such housing need. National Policy Context 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.” 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.” Therefore, recognising that housing for older people has its own requirements and cannot be successfully considered against criteria for general family housing is important. 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 age profile of south Warwickshire can be drawn from the 2018 population projections from the Office for National Statistics. This advises that there were 59,046 persons aged 65 and over in 2018, accounting for 21.9% of the total population of the population of the two Council areas. This age range is projected to increase by 27,344 individuals, or 46.3%, to 86,39 between 2018 and 2043. The population aged 65 and over is expected to increase to account for 26.2% of the total population of the area by 2043. In 2018 there were 16,819 persons aged 80 and over, individuals who are more likely to be frail and in need of long-term assistance. The number of people in this age range is forecasted to increase by 15,291 individuals, or 91%, to 32,110 between 2018 and 2043. The population aged 80 and over is anticipated to represent a higher proportion of south Warwickshire’s residents, accounting for 6% of the total population in 2018 and increasing to 10 by 2043. This increase in older people and resultant need is confirmed within the Coventry & Warwickshire Housing and Economic Development Needs Assessment (HEDNA), Final Report, Iceni, November 2022Table 14.3, page 306. . It is therefore clear there will be a significant increase in older people over the Plan Period and the provision of suitable housing and care to meet the needs of this demographic should be a priority of the emerging Local Plan. Benefits of Older Persons’ Housing Older Persons’ Housing produces a large number of significant benefits which can help to reduce the demands exerted on Health and Social Services and other care facilities – not only in terms of the fact that many of the residents remain in better health, both physically and mentally, but also doctors, physiotherapists, community nurses, hairdressers and other essential practitioners can all attend to visit several occupiers at once. This leads to a far more efficient and effective use of public resources. Economic A report ‘Healthier and Happier’ An analysis of the fiscal and wellbeing benefits of building more homes for later living” by WPI Strategy for Homes for Later Living explored the significant savings that Government and individuals could expect to make if more older people in the UK could access this type of housing. The analysis showed that: • ‘Each person living in a home for later living enjoys a reduced risk of health challenges, contributing to fiscal savings to the NHS and social care services of approximately £3,500 per year. • Building 30,000 more retirement housing dwellings every year for the next 10 years would generate fiscal savings across the NHS and social services of £2.1bn per year. • On a selection of national well-being criteria such as happiness and life satisfaction, an average person aged 80 feels as good as someone 10 years younger after moving from mainstream housing to housing specially designed for later living.’ Each person living in a home for later living enjoys a reduced risk of health challenges, contributing fiscal savings to the NHS and social care services of approximately £3,500 per year (Homes for Later Living September 2019). More detail on these financial savings is set out within the report. A further report entitled Silver Saviours for the High Street: How new retirement properties create more local economic value and more local jobs than any other type of residential housing (February 2021) found that retirement properties create more local economic value and more local jobs than any other type of residential development. For an average 45 unit retirement scheme, the residents generate £550,000 of spending a year, £347,000 of which is spent on the high street, directly contributing to keeping local shops open. As recognised by the PPG, retirement housing releases under-occupied family housing and plays a very important role in recycling of housing stock in general. There is a ‘knock-on’ effect in terms of the whole housing chain enabling more effective use of existing housing. In the absence of choice, older people will stay put in properties that are often unsuitable for them until such a time as they need expensive residential care. A further Report “Chain Reaction” The positive impact of specialist retirement housing on the generational divide and first-time buyers (Aug 2020)” reveals that about two in every three retirement properties built, releases a home suitable for a first-time buyer. A typical Homes for Later Living development which consists of 40 apartments therefore results in at least 27 first time buyer properties being released onto the market. Social Retirement housing gives rise to many social benefits: • Specifically designed housing for older people offers significant opportunities to enable residents to be as independent as possible in a safe and warm environment. Older homes are typically in a poorer state of repair, are often colder, damper, have more risk of fire and fall hazards. They lack in adaptions such as handrails, wider internal doors, stair lifts and walk in showers. Without these simple features everyday tasks can become harder and harder • Retirement housing helps to reduce anxieties and worries experienced by many older people living in housing which does not best suit their needs by providing safety, security and reducing management and maintenance concerns. • The Housing for Later Living Report (2019) shows that on a selection of wellbeing criteria such as happiness and life satisfaction, an average person aged 80 feels as good as someone 10 years younger after moving from mainstream housing into housing specifically designed for later living. Environmental The proposal provides a number of key environmental benefits by: • Making more efficient use of land thereby reducing the need to use limited land resources for housing. • Providing housing in close proximity to services and shops which can be easily accessed on foot thereby reducing the need for travel by means which consume energy and create emissions. • Providing shared facilities for a large number of residents in a single building which makes more efficient use of material and energy resources. The Council should also note that ensuring that 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.

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Policy Option W2 asks whether Health Impact Assessments should be required to be submitted alongside major development applications. Health Impact Assessments should be reserved for large scale applications and should not be required for single phase Retirement Housing schemes. It is considered that their requirement for single phase schemes would be disproportionate and an unnecessary burden on providers of specialist accommodation for older persons. The Council should note that there is a common misconception that older person’s housing places an additional burden on healthcare infrastructure and therefore if option W2a is chosen any screening or checklist introduced should recognise this and/or the threshold for screening of such housing should be set much higher (say 75 units). There is much evidence to support this such as from the Homes for Later Living report, September 2019 which identifies that ‘Each person living in a home for later living enjoys a reduced risk of health challenges, contributing fiscal savings to the NHS and social care services of approximately £3,500 per year’.

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Policy option B5 looks to introduce an ‘Environmental Net Gain’ policy. This appears to build on the Biodiversity Net gain requirements and incorporate other areas of the environment such air and water quality and carbon capture. The Council should not set a higher environmental target than those already set out by government, the Building Regulations and those set out in the Environment Act 2021. This includes ensuring that the Council does not require BNG above 10%. Any environmental target beyond the current legislation would need to be fully evidenced and justified and ensure it meets the requirements of paragraph 57 of the NPPF and in particular ensure that any requirement is ‘fairly and reasonably related in scale and kind to the development’ (para 57, NPPF).

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The policy option looks at introducing a policy requirement for embodied carbon. As such we would like to remind the Council of the increased emphasis on Local Plan viability testing in Paragraph 58 of the NPPF and that the PPG states that “The role for viability assessment is primarily at the plan making stage. Viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the plan” (Paragraph: 002 Reference ID: 10-002-20190509). The introduction of an embodied carbon policy must not be so inflexible that it deems sites unviable and any future policy needs to ensure this to make sure it is consistent with NPPF/PPG and can justified by the Council. The viability of specialist older persons’ housing is more finely balanced than ‘general needs’ housing and we are strongly of the view that these housing typologies should be robustly assessed in the forthcoming Local Plan Viability Assessment. Additionally, new development will often be far more sustainable in many circumstances including building fabric by use of modern methods of construction but also extending beyond that, such as sustainability through optimisation of use of a site and operational use of carbon. Existing foundations of buildings that have reached the end of their life cycle will seldom be practicable for new buildings and particularly so in the case of much needed specialised housing for older people.

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Policy option C9 looks to introduce an ‘Mitigating Biodiversity Loss’ policy. This appears to be looking at ‘Biodiversity Net Gain’ (BNG)requirements and the policy area should use this term to avoid confusion. The Council should make sure it does not set a higher Biodiversity Net Gain (BNG) requirement for development than that set out in the Environment Act 2021. Requiring BNG above 10% does not meet the tests set out in paragraph 57 of the NPPF and in particular a greater than 10% requirement is not necessary to make development acceptable in planning terms. A 10% requirement should therefore be maintained in order to ensure that the requirement is ‘fairly and reasonably related in scale and kind to the development’ (para 57, NPPF). Although we recognise that the 10% is a minimum it should be for the developer to decide whether to go beyond this figure not the Council. It is important to remember that it is impossible to know what the cost of delivering net gain is until the base level of biodiversity on a site is known and consequently what is required to achieve a 10% net gain. On some sites this may be achievable on site with no reduction in developable area, for others it may require a large proportion of it to be addressed off-site or a significant reduction in the developable area – a far more expensive option that could render a site unviable without a reduction in other policy requirements. The Council should therefore not require a BNG of greater than the 10%.

Issue C4: New Buildings Option C4.1a is our preferred approach. Achieving net zero should be ‘stepped’ in line with Government targets and the proposed changes to the building regulations. This is more desirable as there is considerable momentum from Government in preparing enhanced sustainability standards as it is clear the energy efficiency requirements for domestic and non-domestic buildings will increase sharply in the coming years. Aligning the Council’s requirement for net zero development with those of Government would therefore be pragmatic and more achievable. Were the Council to seek net zero or ask for higher standards than the building regulations from new development from the point of the Local Plan’s adoption then we would remind the Council to include the uplift in build costs for delivering net zero within any forthcoming Local Plan viability assessment and that the PPG states that “Viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the plan” (Paragraph: 002 Reference ID: 10-002-20190509). Therefore, in order for the future plan to be found sound the following should be implemented: • Any future policy should be stepped in line with emerging government targets and requirements and • Ensure the policy is properly assessed within the forthcoming viability assessment Q-C4.2: What scale of development should the requirements apply to? If the proposed policy is stepped in line with the building regulations, the new policy should apply to all new developments. Issue C7: Adapting to higher temperatures The option looks to include a policy that requires new developments to incorporate measures to adapt to higher temperatures such as the use of cool materials and using green infrastructure to create cooling. It is recommended that option C7c is taken forward ‘None of these’. This is because this area is now covered via Part O of the Building Regulations and the plan should not seek to amend or go beyond the building regulations. The Council also need to be mindful of how part O (Overheating) of the building regulations is balanced alongside daylight and sunlight requirements. Issue C8: Adapting to flood and drought events Drainage and water efficiency requirements should remain in line with Government targets and the Building Regulations. Were the Council to seek higher standards than the Building Regulations from new development from the point of the Local Plan’s adoption this would need to be evidenced. We would also remind the Council to include the uplift in build costs for delivering adaptation to flood and drought events that goes beyond the Building Regulations within any forthcoming Local Plan viability assessment and that the PPG states that “Viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the plan” (Paragraph: 002 Reference ID: 10-002-20190509).

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Issue H3: Providing the right size of homes Option 3a is our preferred approach and minimum standards should be considered within the Part 2 plan unless standards can be fully evidenced. Introducing space standards must not be so inflexible that it renders sites unviable and any future policy on these standards needs to ensure it does not affect viability to make sure the Plan is consistent with NPPF/PPG and can justified by the Council. Option H3c asks whether a requirement to meet optional Building Regulations M4(2)/M4(3) as standard should be introduced. We would like to remind the Council of the increased emphasis on Local Plan viability testing in Paragraph 58 of the NPPF and that the PPG states that “The role for viability assessment is primarily at the plan making stage. Viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the plan” (Paragraph: 002 Reference ID: 10-002-20190509). M4 (3) of the Building Regulations and Space Standards have a cost implication and therefore including the requirement for new housing to be built to M4 (3) could make schemes unviable. The Council should also note that ensuring that 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. In addition, as M4 (2) is to be incorporated into the Building Regulations and therefore there is no need for the plan to repeat this element.

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