It is essential that the policies of the Greater Cambridge Local Plan set out a clear approach to support the provision of specialist housing for older people. It is a requirement of national policy and guidance that these policies are based on an up-to-date assessment of needs for specialist housing, as a central component of the housing needs of different groups.
The Government has recently published the Social Care White Paper “People at the Heart of Care” (December 2021). The White Paper emphasises the need to expand the choice of housing options available, stating that “today, too many people with care and support needs live in homes that do not provide a safe or stable environment within which care and support can be effective” and notes that specialised housing is likely to offer the best option for support.
The White Paper highlights that the projected demand for supported housing in England is estimated to increase by 125,000 by 2030 and therefore the provision of increased housing options, including specialised housing and the ability to adapt existing homes, is considered to be a key action to help deliver the visions of the Government. Part of achieving this vision includes the provision housing in the “Right Place, at the Right Time”, and there is an emphasis on the intrinsic link between social care and housing and how the care needs of communities need to be effectively planned to sustainably support the changing needs of local populations. To assist with this, over the next 3 years the Government intends to increase the supply of supported housing by supporting providers across the housing sector to develop more options for people in the private housing market.
(i) National Policy Context
National policy and guidance are clear in requiring local authorities to plan to meet the needs of older people and importantly, the PPG confirms that “where there is an identified unmet need for specialist housing, local authorities should take a positive approach to schemes that proposed to address this need” (Paragraph: 016 Reference ID: 63-016-20190626). The PPG also confirms that plan makers should evaluate the tenure, types and size of supply and current stock to assess whether future needs will be met, recognising that, “The need to provide housing for older people is critical as the proportion of older people in the population is increasing” (ID: 63-001-20190626).
The policies in both the current Local Plans which plan for the period from 2018 – 2031 are not sufficient to meet the rising need.
The NPPF updates the definition of Older People contained in the 2012 Framework to state: “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.”
Paragraph 14 contains the following requirement for Planning Authorities: “as a minimum, provide for objectively assessed needs for housing and other uses”.
A fundamental objective of the Framework is the delivery of a wide choice of high-quality homes. The NPPF states at Paragraph 60 that in order 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.”
Paragraph 62 sets out that: “The size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies (including, but not limited to, those who require affordable housing, families with children, older people, students, people with disabilities, service families, travellers, people who rent their homes and people wishing to commission or build their own homes).”
Planning Practice Guidance relating to the Housing Needs of Older People was updated in July 2019 and applies to preparation of the Greater Cambridge Local Plan.
The PPG outlines that Local Authorities will need to count homes for older people as part of their housing land supply (Paragraph: 035 Reference ID: 68-035-20190722).
In the PPG Housing for Older and Disabled People (Paragraph 001) it 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 (our emphasis).”
In the PPG Housing for Older and Disabled People (Paragraph 001) it states: “For plan-making purposes, strategic policy-making authorities will need to determine the needs of people who will be approaching or reaching retirement over the plan period, as well as the existing population of older people”.
The PPG ‘Housing for older and disabled people’ highlights the advantages as: “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.” (Paragraph: 001 Reference ID: 63-001-20190626).
In respect of the evidence to be considered when identifying the housing needs of older people, the PPG states: “The age profile of the population can be drawn from Census data. Projections of population and households by age group can also be used. The future need for specialist accommodation for older people broken down by tenure and type (e.g. sheltered housing, extra care) may need to be assessed and can be obtained from a number of online tool kits provided by the sector, for example SHOP@ (Strategic Housing for Older People Analysis Tool), which is a tool for forecasting the housing and care needs of older people. Evidence from Joint Strategic Needs Assessments prepared by Health and Wellbeing Boards can also be useful. The assessment of need can also set out the level of need for residential care homes.” (Paragraph: 004 Reference ID: 63-004-20190626)
The PPG sets out that a range of specialised provision is available but notes that any single development may contain a range of different types of specialist housing (Paragraph: 010 Reference ID: 63-010-20190626): “There is a significant amount of variability in the types of specialist housing for older people. The list above provides an indication of the different types of housing available but is not definitive. Any single development may contain a range of different types of specialist housing.”
The guidance makes it clear that Local Plans need to appropriately provide for specialist housing where a need exists (Paragraph: 012 Reference ID: 63-012-20190626): “Plans need to provide for specialist housing for older people where a need exists. Innovative and diverse housing models will need to be considered where appropriate.”
The guidance then goes on to state how plan makers will need to account for older people who wish to stay or move to general housing that is already suitable, therefore ensuring that general housing is also sensitive to the needs of an ageing population (Paragraph: 012 Reference ID: 63-012-20190626): “Many older people may not want or need specialist accommodation or care and may wish to stay or move to general housing that is already suitable, such as bungalows, or homes which can be adapted to meet a change in their needs. Plan-makers will therefore need to identify the role that general housing may play as part of their assessment.”
The guidance clearly demonstrates how older people should have a wide choice of options when moving to specialised housing. This will be done through plan-makers considering the size, quality and location of dwellings for older people in the future or for them to move to more suitable accommodation (Paragraph: 012 Reference ID: 63-012-20190626): “Plan-makers will need to consider the size, location and quality of dwellings needed in the future for older people in order to allow them to live independently and safely in their own home for as long as possible, or to move to more suitable accommodation if they so wish”.
The guidance sets out possible criteria for site selection. Despite this, some larger facilities may still be viable and attractive for older persons despite not being close to nearby facilities and amenities (Paragraph: 013 Reference ID: 63-013-20190626): “It is up to the plan-making body to decide whether to allocate sites for specialist housing for older people. Allocating sites can provide greater certainty for developers and encourage the provision of sites in suitable locations. This may be appropriate where there is an identified unmet need for specialist housing. The location of housing is a key consideration for older people who may be considering whether to move (including moving to more suitable forms of accommodation). Factors to consider include the proximity of sites to good public transport, local amenities, health services and town centres.”
There is little guidance on the matter of Use Class and makes no mention of the application or otherwise of affordable housing requirements to developments of specialised accommodation for older people (Paragraph: 014 Reference ID: 63-014-20190626): “It is for a local planning authority to consider into which use class a particular development may fall. When determining whether a development for specialist housing for older people falls within C2 (Residential Institutions) or C3 (Dwelling house) of the Use Classes Order, consideration could, for example, be given to the level of care and scale of communal facilities provided.”
The guidance states that the need for older persons housing should be met (Paragraph: 016 Reference ID: 63-016-20190626): “Where there is an identified unmet need for specialist housing, local authorities should take a positive approach to schemes that propose to address this need.”
(ii) Evidence Base for the Councils’ Proposed Approach
Whilst policy H/SH: ‘Specialist Housing and Homes for Older People’ includes guidance for specialist housing designed to support a variety of groups such as older people, disabled people, people with alcohol or drug dependency, those requiring refuse from harassment and violence, and others who may, for a variety of reasons, be excluded from the local community, this is primarily in the context of provision as part of the general housing mix of new developments to be provided at new settlements and within urban extensions.
The Plan at this stage does also refer to a criteria-based policy similar to that in the adopted Cambridge Local Plan 2018, and the need to ensure that new specialist housing is provided where there is a need, in suitably accessible locations and without resulting in an excessive concentration of such housing. However, this only goes a limited way towards meeting need and there appears to be no current allocations or sites proposed that are specifically defined/safeguarded for older persons housing needs.
Paragraph 8.61 of the ‘Housing Needs for Specific Groups report 2021’ identifies that over all areas assessed within the study there is a significant shortfall of leaseholder housing with support (retirement housing) and also shortfalls of housing with care (i.e., Extra Care and Enhanced Sheltered) for both leasehold and rental tenures.
It is noted that the evidence provided by GL Hearn in the ‘Cambridgeshire and West Suffolk Housing Needs of Specific Groups study (August 2021)’ has been produced to examine the need for specific housing for the 2020 – 2040 period. Section 8 of this evidence provides information on Older and Disabled Persons.
It is noted that the assessment began with the Housing Learning and Improvement Network (LIN) SHOP@ baseline online toolkit for Housing with Care (to include both enhanced sheltered and extra-care housing) of 45 units per 1,000 population aged 75 (comprising 22.5 units per 1,000 as leasehold and rental respectively). The version of the toolkit adopted for comparison purposes in the GL Hearn Evidence comprises the projected “base case” demand at 2030 scenario from the 2013-based ‘Delivering the Detail’ version of toolkit assumptions.
No reference is made to the 2011 version of the SHOP@ Resource Pack which forecast greater representation within the ‘Housing with Care’ component of the sector. More detailed justification for the same assumptions was incorporated with the publication Housing in Later Life: planning ahead for specialist housing for older people, Housing LIN, NHF et al, December 2012. Both sources reflect strong growth in the demand for leasehold retirement housing and the emergence of the Extra Care sector specifically as informing measures to deliberately invert current levels of provision by tenure and to accelerate a shift from policies heavily reliant on traditional are home provision. The equivalent prevalence rate for ‘Housing with Care’ under these sources comprises 65 units per 1000 persons aged 75+, distributed as follows:
• Extra Care Housing: 45 units per 1,000 (30 leasehold; 15 rented)
• Enhanced Sheltered: 20 units per 1,000 (10 leasehold; 10 rented)
However, it is then noted that adjustments were made to this baseline based on evidence concerning the reflective health of the local older population in comparison to the national average which has decreased the prevalence rate by an average of 8% across the Housing Market Area and an estimate of tenure split for housing with support and housing with care (with more affluent areas expecting a higher proportion of specialist housing to be market sector).
The GL Hearn Evidence for Greater Cambridge results in an equivalent prevalence rate for ‘Housing with Care’ of 40 units per 1,000 persons aged 75+ (a reduction of 5 units per 1,000 compared to the 2013 SHOP@ baseline or 25 units if the ‘Housing in Later Life’/SHOP Resource Pack benchmarks are applied.
The rationale for making adjustments to any of the toolkit benchmarks referred to above are summarised in Paragraphs 8.45 and 8.50 – 8.52 of the 2021 Housing Needs of Different Groups Study but these are not justified in isolation.
Paragraph 8.46 identifies the ‘Assessment of Need for Specialist Housing for Older People in Greater Cambridge (Centre for Regional Economic and Social Research (CRESR), November 2017)’. The methodology adopted in the CRESR analysis was not driven by specific outputs for requirements for specialist older persons housing by tenure but did apply assumptions regarding the preferences of older homeowners. The foundation of the methodology adopted in that analysis was to take the median level of current provision of Specialised Accommodation for older people across the one hundred English housing authorities with the highest levels of provision of such accommodation and establish that as the “norm”. Its application to the population of Greater Cambridge was then moderated by considering a number of demographic, social and economic factors that might indicate a variance from the norm.
The model sought to increase the supply of care beds while barely increasing provision for Extra Care and Enhanced Sheltered units. The model also favoured increasing the supply of sheltered housing, which comprises a component of provision of specialist housing for older people less well-suited to meeting needs of an increasing ageing population experiencing greater frailty in later years following retirement. This assumption on the preferences for specialist housing within leasehold tenure is also incorporated within the GL Hearn evidence base.
Care must therefore be taken when comparing the total provision anticipated in the CRESR and subsequent GL Hearn Evidence Base per head of population against other benchmarks per head of population aged 75+. While overall levels may be similar (162 per 1,000 CRESR and 153 per 1,000 in GL Hearn versus 170 per 1,000 in the SHOP@ 2013 baseline) assumptions about the forms of accommodation and care and the tenure profile of that accommodation that will constitute an appropriate strategic response differ markedly.
The CRESR model itself recognises the need for further consideration of the proportion of needs that could more appropriately be met through provision for Extra Care: “Comparing our model’s estimates against those from SHOP@ reveals a very similar estimate of current ‘demand’ for specialist housing (3,422 in our model versus SHOP@’s 3,554) and care beds (2,152 beds in our model versus SHOP@’s 2,299). However, there is a distinct difference between the two models in term of the forms of specialist housing supply required. SHOP@ suggests enhanced sheltered and extra care units should make up approximately one in five specialist units [rising to approximately 1 in 4 within the SHOP@ 2011 and ‘Housing in Later Life’ benchmarks]. Hence it identifies significant deficits in the current supply of extra care and enhanced sheltered accommodation in Greater Cambridge. On the other hand, our model suggests only one in 10 of the recommended supply of specialist units in Greater Cambridge are either enhanced sheltered or extra care. This reflects the fact that our modelling is premised on existing provision in authorities with a high level of overall supply, and where extra care provision may vary in scale. As discussed in Chapter 5, if it is decided that extra care can meet a greater proportion of needs that are currently met in other areas of the system (e.g., in residential care), then this could dramatically change how many units of extra care are required. In addition, future changes in the health of the local population may affect projections for extra care in significant ways.”
The ‘Housing Needs of Specific Groups – Greater Cambridge Addendum’ published in September 2021 considers the up-to-date evidence of housing need in Cambridge and South Cambridge specifically. The addendum notes that the population aged 65+ is projected to see the highest proportionate increase in population.
The current development plan provision for specialist housing for older people falls well below that needed to address the requirements of national policy and guidance despite evidence of the rising need with the projected growth of approximately 55% between 2020-2040 across the HMA.
This work identified the shortfall in housing with care needed in Greater Cambridge when considering housing growth in line with the Council’s ‘medium’ objectively assessed housing need scenario (without prejudice to these representations on housing need). In the Council’s Topic Paper 7 (Housing) this scenario is summarises that the shortfall would be 802 units (leaseholder) considering a demand per 1,000 population of 23 units and 337 (rented) considering a demand per 1,000 population of 17 units as shown in Table 34 of the Final Addendum. A previous draft version of the addendum transposed these figures and incorrectly showed a lower leaseholder shortfall.
Critically, given the departure from established benchmarks and despite the comparisons with the SHOP@ toolkit produced in the CRESR Report, the most recent evidence does not continue to provide up-to-date assessments against relevant alternatives including the ‘Housing in Later Life’ benchmarks for Extra Care or all ‘Housing with Care’ categories.
The Council acknowledges a forecast shortfall in leasehold Housing with Care of at least 802 units at 2041. Table 1 below summarises these comparisons, indicating that under the Councils’ own scenario for housing need the forecast shortfall in leasehold ‘Housing with Care’ is substantially greater – between 780 to 1460 units. This specifically includes a shortfall of at least 1,072 units against the standalone benchmark for Extra Care provision within the SHOP@2011 and ‘Housing in Later Life’ benchmarks.
(iii) Soundness of the Councils’ Proposed Approach
The Council’s Preferred Approach cannot be considered sound. It is clear that further work needs to be undertaken to assess the full scale of need within Greater Cambridgeshire. The following sub-section demonstrates that the approach is not justified; not positively prepared; not consistent with national policy and guidance and not effective. Without prejudice to any future detailed assessment to be prepared on behalf of our client these representations provide a critique of the Council’s approach to demonstrate that the need is greater than the Council’s current evidence supporting the Local Plan proposals suggests.
The Council’s own Topic Paper presents no statement that the First Options proposals intend to provide policies that will meet in full needs for the type and tenure of specialist housing for older people, including against the Council’s own assessment of need. The scope for further work identified is extensive, indicating ongoing activity to amend forecasts of future provision and approaches to the delivery of care. The Councils accept that this may further inform their preparation of planning policies. These representations strongly assert that the provision of increased levels of Extra Care accommodation must form an important component of emerging objectives identified in the work, including supporting independent living and care tailored to individuals’ needs over their lifetime.
It is clear that the estimate of needs for Extra Care in the Housing Strategy are lower than those used in other relevant sources including the @SHOP Analysis Tool which is referred to in Planning Practice Guidance.
The figure of 45 units per 1000 persons comprising specific provision for Extra Care set out in Housing for Later Life has been considered to be a ‘very modest’ assumption in recent Appeal Decisions (PINS Ref: 32658614 – paragraphs 39 and 108) as it reflects just 4.5% of the population of people 75 years of age and over and primarily resulting from the lack of this type of accommodation available. It should be noted that when considering ‘Housing in Later Life Toolkit’ the total ratio for provision for enhanced and extra care housing (which has been grouped in the Greater Cambridgeshire evidence) is a provision of 65 units per 1,000 population.
The Addendum acknowledges that in every demographic growth level option considered, it is estimated that by 2041 there will be a shortfall of both rented and leaseholder housing with care (both extra care and enhanced sheltered accommodation).
It is noted that some of the strategic sites included in the Councils’ adopted Local Plans (2018) do include some provision for specialist accommodation however, delivery of these homes is not definitive as in the majority of the examples provided no information on the actual number of C2 units to be provided is evidenced and in some cases the strategic sites are not delivering any provision.
As a result, there is no attempt within the Councils’ Topic Paper 7 to quantify the identified provision in terms of its potential contribution to reducing forecast shortfall to 2041 as set out in Table 1 above. The Council has provided no other details of any development pipeline available to address the current identified shortfall in 2020.
As set out above it is critical that the Local Plan Review provides a clear approach to meet the needs for specialist older persons housing and recognises the wider benefits of this form of provision. The recent Appeal Decision on land at Little Sparrows, Sonning Common, Oxfordshire (PINS Ref: 3265861) provides a clear example of reasons to ensure that the development plan is not ‘left wanting’ in terms of addressing the need for Extra Care (see paragraph 31). In the Appeal case this reflected a failure to prescribe particular levels of provision by type of accommodation, nor policies to address the need for each notwithstanding the critical need for Extra Care.
This was a situation compounded in South Oxfordshire as a result of the ‘generic approach’ to provision by accommodation type and also that the characteristics and prospects for delivery of specific types of provision within the District’s strategic sites expected to comprise the main source of potential supply. The First Proposals for Greater Cambridge are exposed to the same risks as a result of the reliance on urban extensions and new settlements to meet needs for specialist older persons housing.
It is also relevant to note that in considering the delivery of Extra Care schemes the Inspector (paragraph 117) stated that undoubtedly Extra Care housing operated in a very different market and Extra Care housing providers cannot compete with house builders or with other providers of specialist housing for older people because of the build costs, the level of the communal facilities and the additional sale costs including vacant property costs. The inspector goes onto state: “It seems to me that these factors, all mean that age restricted developments and in particular extra care communities are less viable than traditional housing schemes. Ultimately, age restricted developers are less able to pay the same price for land as residential developers and it is much harder for age restricted developers, and in particular those seeking to deliver extra care, to secure sites for development and meet the housing needs they aim to supply.” (Paragraph 118)
In Paragraphs 121 and 122 the inspector highlights other benefits the scheme would deliver, each of which form relevant considerations for the policies of the Local Plan Review and objectives for sustainable development. These included:
a) Contributing to the overall supply of housing;
b) Savings in public expenditure (NHS and adult care);
c) Creating new employment and other economic investment (construction and operation);
d) Providing new facilities and services further reinforcing the role and function of settlements; and
e) Additional net revenues from Council tax and new homes bonus receipt.
The benefits to individuals and to the Public Good of facilitating a pattern of provision in which ever increasing dependence on Registered Care Home beds is mitigated by an expansion of housing-based care units, such as Extra Care, are well documented.
Gains are principally found in benefits to the Health and Social Care economy and the more effective and efficient use of the stock of general housing. Whilst the majority of older people will continue to live in general housing for the minority identified in our model specialised accommodation will provide a better quality of life and a better match to their needs.
The provision of a more adequate supply of Extra Care for homeowners will provide an environment of choice in which independence can be sustained and transfer to scarce Registered Personal Care Home beds and expensive Registered Nursing Care Home beds postponed or avoided. The development proposed for our client’s land at Comberton will help create a more adequate level of provision for older homeowners and contribute to a more equitable pattern of provision overall.
As identified at paragraphs 5.3 of the ‘Representation by Inspired Villages – to support the practical delivery of much-needed specialist accommodation to meet the needs of an ageing population’ (Appendix 1), the Housing Learning and Improvement Network (LIN) considers that the later living market needs to be made both acceptable and financially viable to enable older people to move from unsuitable accommodation (too large to manage, costly to maintain, poorly located or ill-equipped to deal with changing needs), to better, thoughtfully designed homes in sought-after places.
Frequently local planning authorities overlook the Extra Care model, particularly the scale of an Integrated Retirement Communities (IRC) and instead focus on retirement housing or care homes.
The ‘People at the Heart of Care: Adult Social Care Reform’ White Paper (December 2021) also talks about making every decision about care a decision about housing with the importance of housing and delivering the right housing in the right places being a key theme.
Many retirement living operators find it difficult to compete against the major house builders and smaller operators e.g. McCarthy and Stone when it comes to those sites identified for an element of retirement living as part of wider allocations, and more than often, the size of the site isn’t of sufficient scale for such type of proposals.
It is therefore essential that authorities recognise the different models which exist and plan to meet each of their respective needs.
The site at Branch Lane and Long Lane, Comberton is available to provide high-quality Integrated Retirement Community which provides Extra Care housing to address the need for specialist Extra Care housing for older people whilst also providing open green spaces and community facilities to support the development. The site is sustainably located with good links to existing services and facilities in Comberton as well as links to local bus services and the proposed Greenway to Cambridge, which will provide further sustainable transport options.
The PPG endorses the certainty that can be provided through the allocation of sites to deliver specialist housing for older people including in circumstances where there is an identified unmet need. Relevant considerations including access to health services, public transport and local amenities (ID: 63-013-20190626) together with the proximity of town centres. Age friendly design can also enhance the accessibility of housing for older people and improve the quality of place (ID: 63-018-20190626).
The Extra Care proposals for our client’s site at Comberton perform well against these considerations, which are not accurately considered in the Council’s assessment proforma in terms of recognising the opportunity to deliver specialist housing for older people at this location. Given the substantial uncertainty regarding the scale and nature of provision for these uses at the Councils’ existing and proposed new settlements and urban extensions the HELAA should reflect that other locations sustainably related in relation to the main settlement of Cambridge (in terms of proximity and connections) are likely to perform similarly or better in terms of their potential suitability to meet identified needs.
The policy approach being pursued by the Greater Cambridgeshire Local Plan should therefore reflect the need for site specific allocations for older-persons housing need rather than relying on the larger sites to make provision for such types of housing.