Paragraph 65 b) of the Framework makes clear that proposals for specialist accommodation should be exempt from providing at least 10% of properties for affordable home ownership, stating: “Exemptions to this 10% requirement should also be made where the site or proposed development: b) provides specialist accommodation for a group of people with specific needs (such as purpose-built accommodation for the elderly or students)”; Government policy is therefore clear that specialist accommodation should be exempt from this affordable housing policy requirement.
The proposed development at Branch Lane and Long Lane, Comberton would include a mix of C3 general needs dwellings and Use Class C2 Extra Care accommodation. The provision of affordable housing contributions will need to be assessed with this consideration in mind and as such the policy approach must support the separate assessment of affordable housing contributions on these types of mixed-use sites. For example, the Council’s proposals under Policy H/AH for mixed-tenure schemes including Build-to-Rent elements may be subject to making up any shortfall in affordable homes across the remainder of the development. Without prejudice to the justification for that position, Policy H/AH must be clarified to ensure that similar arrangements will not be applied to mixed-use sites incorporating specialist housing for older people.
Proposed Policy H/AH also sets out that on sites of 10 or more dwellings 40% of new homes will be required to be affordable, except where: there can be a proportionate reduction as a result of vacant buildings being re-used or re-developed (as set out in national planning policy), the development is solely for Build to Rent, the development is for some types of specialist accommodation that fall within Use Class C2, or the development is solely for residential caravans. Further clarification is required as to which types of specialist accommodation that fall within Use Class C2 would be exempt in light of the Framework and Planning Practice Guidance.
Retirement Communities providing for Extra Care take the form of a “core building” and containing a mix of service and residential uses and surrounding purpose designed specialist accommodation.
The village core will provide a number of communal facilities focussed on facilitating wellness and typically comprise up to 25% of its floorspace as non-saleable space. This includes the communal and care facilities available to its residents. These facilities may vary from village to village but will always include a minimum level of communal provision.
The specialist accommodation will be carefully designed to incorporate features that allow for practical living for older people and the delivery of care and assistance safely within that setting, which can be increased over time as necessary.
The proposed site would provide a mixed-use development with part of the site including the following features which suggest that some of the site falls within Use Class C2:
• The development provides for specialist housing that caters for the specific needs of older persons
• The care village provides a wide range of communal facilities to promote physical and mental health and wellbeing, including a wellness spa, restaurant, meeting spaces/library, transport services, landscaped grounds, back offices and staff facilities
• The accommodation would provide for specialist features including level access, maximised natural daylight, internal room layout, connectivity to staff
• The development would provide specialist management services including a village manager, wellbeing navigator and reassurance response co-ordinated through the central reception;
• An extensive review process to identify Registered Domiciliary Care Providers to provide Personal Care to residents
• Restriction of use through a legal agreement so that units are only used for Class C2 purposes in perpetuity
In this regard, Integrated Retirement Communities which provide Extra Care housing fall within use Class C2 of the Use Classes Order.
For the reasons outlined above, the delivery of Affordable Housing on Extra Care sites is typically challenging, which is why paragraph 10-007-20190509 of the PPG states that viability may need to be considered on schemes where particular types of development are proposed which may significantly vary from standard models of development for sale (for example housing for older people). Whilst an initial purchase may be discounted, the ongoing service charge for access to the village’s services and facilities cannot be discounted. It would also not be possible to discount the cost of care for residents within units provided as affordable tenures. It is considered that these practical issues should be addressed within policy as otherwise it could be difficult to implement and be ineffective.
The integrated retirement community/Extra Care model predominantly operates on the sale of individual units as part of a managed development. Care packages are purchased either from the operator or by a third-party care provider. This differs from care homes which are sold or let to an operator with individual residents paying for their room, board, and care.
The integrated retirement community/Extra Care model also differs from more general development in that they incorporate a significant level of facilities which results in the net to the total gross floorspace being significantly poorer than in traditional/general housing needs. This means that such schemes have a substantially lower amount of saleable floorspace compared with traditional developments and such schemes will also require the additional costs of lifts and specially adapted bathrooms and other such facilities appropriate to the target age group and level of care.
At paragraph 10-007-20190509 of the PPG, it states that: “Where up to date policies have set out the contributions expected from development, planning applications that fully comply with them should be assumed to be viable. It is up to the applicant to demonstrate whether particular circumstances justify the need for a viability assessment at the application stage. Policy compliant in decision making means that the development fully complies with up-to-date plan policies”.
The PPG continues to outline that: “Such circumstances could include, for example, where development is proposed on unallocated sites of a wholly different type to those used in the viability assessment that informed the plan; where particular types of development are proposed which may significantly vary from standard models of development for sale (for example built to rent or housing for older people), or where a recession or similar significant economic changes have occurred since the plan was brought into force”.
The First Proposals set out that the Plan will be subject to a viability assessment at each stage of plan making, including a whole plan viability assessment that will accompany the draft plan and be updated at subsequent stages of plan making. It adds that current evidence indicated that securing 40% affordable homes is deliverable across Greater Cambridge taking account of other development costs assumed so far but will be kept under review as the plan progresses.
The Viability Assessment that supports this consultation, paragraph 2.45 sets out that the Council have appraised generic retirement living or sheltered housing schemes typically delivered by developers such as McCarthy and Stone or Churchill retirement living, and these have been included within the residential typology rather than a separate element which therefore means it becomes tied up with Class C3 for viability purposes.
It is considered that the evidence base has failed to assess the different typologies available for the provision of specialist housing for older people by only appraising generic retirement living or sheltered housing schemes. The evidence is not reflective of the viability of schemes which seek to deliver Extra Care provision. The Councils evidence should therefore assess a range of typologies including Extra Care schemes up to 200 units to consider the viability of these developments to come forward.
The Viability Assessment should also consider the provision of affordable housing on such type of schemes as it is often the case that Affordable Housing is unlikely to be viable for Extra Care schemes.
It is imperative that careful consideration is given to the forms of specialist accommodation which relate to older persons’ housing and the different types of accommodation that can be provided as these can vary significantly.