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Object

Draft Regulation 18 Sandwell Local Plan

Representation ID: 707

Received: 18/12/2023

Respondent: The Planning Bureau on behalf of McCarthy Stone

Agent: Miss Natasha Styles

Representation Summary:

See main representation for full justification.

Given the increase in the number of older people projected, the significant housing need and benefits that older persons’ housing brings, together with the guidance of the NPPF / PPG, we consider that the need for older people’s housing need must be incorporated into the emerging Local Plan in a more positive manner . The plan should:
• Identify the older persons’ housing need.
• Allocate specific sites to meet the needs of older people and include a standalone policy actively supporting the delivery of specialist older people’s that are in sustainable locations

Full text:

Policy SHO11 – Housing for people with specific needs
Whilst we welcome that the plan has a policy addressing housing for people with specific needs we are concerned as to the negative tone of the policy which implies that specialist housing maybe a nuisance neighbour and feel a more positive stance, especially towards specialist housing to meet the needs of older people should be taken.

The consultation is limited in scope on the provision of specialist housing for older people. However, given the clear evidence, including evidence of older person’s population increase, increased need and the clear guidance of the PPG all detailed below, we consider that providing specialist housing for older people must be positively incorporated into the emerging Local Plan in detail. The best approach towards meeting the diverse housing needs of older people is for the plan to:
1. Identify the older person’s housing need.
2. Allocate specific sites to meet the needs of older people that are in the most sustainable locations close to key services as well as
3. Include a standalone policy actively supporting the delivery of specialist older people’s housing in Sandwell with good access to services and facilities for older people. This should be separate to other specific housing.

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, the local plan should recognise that housing for older people has its own requirements and cannot be successfully considered against criteria for general family housing.

Need for Housing for Older People
It is well documented that the UK has 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, within 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 Sandwell can be drawn from the 2018 population projections from the Office for National Statistics. This advises that there were 49,258 persons aged 65 and over in 2018, accounting for 15% of the total population of the Borough. This age range is projected to increase by 18,645 individuals, or 37.9%, to 67,903 between 2018 and 2043. The population aged 65 and over is expected to increase to account for 18.4% of the total population of the Borough by 2043.

In 2018 there were 13,769 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 6,236 individuals, or 45.3%, to 20,005 between 2018 and 2043. The population aged 80 and over is anticipated to represent a higher proportion of Sandwell’s residents, accounting for 4.2% of the total population in 2018 and increasing to 5.4% by 2043. This increase in older people is confirmed within the Black Country Housing Market Assessment, Final Report, March 2021, HDH Planning Development (HMA) page 180, para 1 that states ‘The disaggregated local housing need projections (set out in Chapter 5) indicate that the population aged 65 or over is going to increase dramatically in Sandwell over the plan period; from 50,001 in 2020, to 67,236 in 2039, a rise of 34.5%. The projections also suggest that there will be an increase in the number of households headed by someone over 65 in Sandwell from 32,857 in 2020, to 46,853 in 2039, an increase of 42.6%. The projections indicate that the proportion of older persons living alone in Sandwell will increase from 46.6% in 2020, to 53.9% in 2039 (HMA)’.

The HMA continues to identify the need for specialist housing for older people, this identifies that ‘To meet local demand rates in 2039, the model identifies a requirement for 1,666 additional units of Sheltered housing for older people and 54 additional Enhanced Sheltered/ Extracare units in Sandwell over the plan period. These are Class C3 dwellings’. Page 181 para 1 identifies that ‘The requirement for 1,720 additional specialist units for older person households represents 6.3% of the total household growth in Sandwell for the period 2020 to 2039.’

The model uses the existing prevalence rate of specialist housing for older people across the Black Country to predict the future needs in the individual Boroughs that make up the Black Country region. It should be noted that this does not then account for any under provision that may exist and this should be considered in any update of the evidence moving forward as need is likely to be greater.

It is therefore clear there will be a significant increase in older people 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 Housing for Older People
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.’

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.

Recommendations

In presenting this submission, it is relevant to note that McCarthy Stone which has traditionally developed retirement housing schemes for the middle market where it has proved more viable to do so, is, through its new “Evolve” housing concept better able to develop in lower value areas, where the market and planning conditions are right, thereby addressing a housing need for older people who have until now, not had this beneficial housing option available to them. The first of these schemes is now underway at Failsworth, Oldham.

Given the increase in the number of older people projected, the significant housing need and benefits that older persons’ housing brings, together with the guidance of the NPPF / PPG, we consider that the need for older people’s housing need must be incorporated into the emerging Local Plan in a more positive manner

The best approach towards meeting the diverse housing needs of older people is for the plan to:
• Identify the older persons’ housing need.
• Allocate specific sites to meet the needs of older people that are in the most sustainable locations close to key services.
• Include a standalone policy actively supporting the delivery of specialist older people’s housing with good access to services and facilities for older people.

Developers of older persons’ housing schemes should not be required to demonstrate need given the significant need identified and 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 older persons housing policy is provided that, we hope, will provide a useful reference for the Council to amend the currently proposed policy:

“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.”