Memorandum by the Retirement Housing Group
The Retirement Housing Group of the House Builders
Federation consists of retirement housing developers and housing
managers, both RSL and private sector. Its ex officio members
include representatives of the charity, the Elderly Accommodation
Counsel, and the Association of Retirement Housing Managers. The
Advice and Mediation Service (AIMS) of Age Concern is also represented.
Its members are therefore involved in the building, management
and provision of advice on housing for those of retirement age
and over. Such housing ranges from lifestyle properties for the
active, newly retired through to warden assisted housing with
community facilities and design modifications through to very
sheltered housing with high staffing levels and many additional
services and facilities.
The Group has a wide-ranging interest in planning
and management issues, leasehold reform and Government policy
of all kinds, which affect vulnerable groups such as the elderly.
Our Submission looks at the impact of the Housing
Bill on this specialist area of housing. Therefore it does not
seek to comment on housing fitness standards, controls on houses
in multiple occupation, the licensing of landlords or the modernisation
of Right to Buy, but focuses exclusively on the proposal to introduce
a Home Information Pack.
The Retirement Housing Group supports the Government's
desire to achieve openness and transparency in the selling process,
increase certainty, reduce wasted costs and shorten the overall
Whilst the provision of information in a HIP
may help to standardise documentation it seems probable that the
current proposals will do little, if anything, to speed-up the
system and nothing to secure a committed vendor or purchaser,
whilst adding to the costs borne by the vendor.
This, plus the prescriptive nature of the Pack,
is likely to reduce the number of vendors in the total market
and have the effect of reducing the size of the new homes industry,
the output of which is always a direct function of the size of
the total housing market.
On the specific contents of the HIP, our concerns
are for developers and managers of retirement housing (who are
usually involved in re-sales) but primarily for vendors and purchasers
in the market as a whole, who may find any theoretical advantages
of the information provided by the HIP over-ridden by a reduction
in housing choice and the deterrent effect of producing a Pack
of such size and complexity, as currently specified in ODPM's
consultation paper. This is particularly true for elderly vendors
We have two main concerns.
1. The inclusion of detailed contamination
reports will require professional interpretation for purchasers
and this may lead them to have unnecessary concerns as well as
incurring additional costs beyond their normal legal costs. The
current system is that, on production of a satisfactory contamination
report, the NHBC issues a certificate, which specifically covers
contamination and should be satisfactory for all parties.
2. The normal sales pattern on retirement
housing schemes means that the development is usually completed
before sales commence. Normal sales rates mean that the development
is then sold over the succeeding two to three years. Nothing has
changed during that period and therefore the proposal that a Home
Condition Report should be updated after no more than three months
old is an extremely onerous requirement both in the new homes
market and particularly in this market. We would suggest that,
as retirement properties are newly built and covered by the NHBC
ten-year warranty, an exemption or waiver should be placed on
this item for new developments
Our principal concern however is for our purchasers
who are, on average, in their mid 70s. Many of them will have
lived in their existing house for an average of 25 years. They
will experience difficulty in providing many of the items in the
Pack, as these may never have been provided by the original builder,
either to them or to the original purchaser, perhaps fifty years
ago (eg planning consent with drawings, building regulation consents,
which were not usual in the 1950s and 1960s) as well as maintaining
a current Home Buyers Report.
No doubt there will be providers eager to offer
these services, but how much information will be available, at
what cost and what happens if it cannot be found? Is this not
simply creating an unnecessary and burdensome new industry?
Further, the legal responsibility remaining
with the vendor must be clearly defined and understood, as additional
burdens are likely to deter many from selling, further reducing
the release by elderly owner-occupiers of housing that is too
large for them but may be desperately needed by families. This
will perpetuate continuing levels of under-occupation, contrary
to the Government's planning policy recommendations and its desire
to create a more sustainable housing market.
Overall, we do not see any significant benefit
in introducing the proposed Home Information Pack. This, with
the increased amount of information it requires, will reduce the
size of the total housing market, and therefore the choice available
to purchasers, whilst increasing costs and protracting the length
of transactions, contrary to the Government's intention in introducing