Written evidence from the Retirement Housing
Group of the Home Builders Federation (ARSS 70)
SUMMARY
RSS policies were beginning to recognise the importance
of providing housing suitable for older people. This recognition
must be carried forward into National Planning Guidance;
A planning hiatus has arisen following the revocation
of RSSs and CLG must clarify the role of local authorities until
the new framework is put in place;
under the proposed new planning system housing targets
must not be the only criterion for granting planning permission.
Criteria-based approvals should supplement the policy numbers;
Local Enterprise Partnerships should support National
Planning Guidance which recognises the housing needs of an ageing
population and they should encourage local planning authorities
to include suitable policies to provide such housing in their
development plans;
it is difficult to evaluate the effect of the New
Homes Bonus until 20 October when the outcome of the Spending
Review is known but it must be structured in such a way that local
communities see that it brings them direct benefits, unlike S.106
Agreements, which clearly did not address that problem or overcome
local opposition; and
in the light of the rapid growth in the number of
older people as a proportion of the population consideration should
be given to extending the proposed 125% incentive for social housing
to specialist housing for older people to ensure an adequate supply
of housing in the longer-term.
THE IMPLICATIONS
OF THE
ABOLITION OF
REGIONAL HOUSE
BUILDING TARGETS
FOR LEVELS
OF HOUSING
DEVELOPMENT
The widespread recognition at national policy level
of the need to plan for an ageing and growing population (evidenced
by PPS 3; "Lifetime Homes; Lifetime Neighbourhoods"
and the Housing our Ageing Population: Panel for Innovation
(HAPPI) Report)(1)
was gradually being reflected in many regional
spatial strategies, which were starting to acknowledge demographic
trends and support the provision of suitable accommodation for
an ageing population. Local planning authorities were required
to take such regional policies into account when drawing up Core
Strategies/Local Development Frameworks and no doubt they would
have done so in due course. However as many have yet to be adopted
it is difficult to assess how far that has been, or will be, taken
into account at local level in future.
This is a significant issue for local plan-making.
Demographic modelling shows that many areas have high and growing
numbers of older people. For example, in May the ONS published
the 2008-based Sub-national Population Projections estimates(2)
showing that 16% of the English population was over 65 in 2008,
rising sharply to 2033, with some local authorities registering
over 40% by then (West Somerset, Berwick on Tweed, South Shropshire
and West Dorset, Rother and North Norfolk).
We therefore hope that the National Planning Framework
that government is to put before Parliament will not ignore the
beneficial policy developments in RSSs, such as the recognition
of the need to plan for housing for older people, and that this
is included in the national guidance to which local planning authorities
should have regard.
Following the revocation of RSSs, we hope that local
authorities will recognise existing national guidance and the
extensive work carried out regionally and sub-regionally when
they revise current plans or draw up new ones. However the hiatus
caused by the revocation of RSSs and the confusion created by
the abolition of the regional tier is a concern, with Government
issuing no clear interim guidance for local planning authorities
on how to proceed during the transitional period. Many local authorities
have suspended the plan process or asked to withdraw plans so
they can consider the implications of the potential changes to
the system, and take these into account in preparing the consultation
documents. For example, Hart DC said it wanted to avoid any decisions
being taken that were later proved to be unsound or unnecessary.
There could be a hiatus of at least four years if
some local authorities suspend local plans until a) the new planning
system completes its Parliamentary process and comes into effect
and b) replacement plans are drawn up and adopted.
Because of the current policy confusion neither local
authorities nor retirement housing developers are clear how to
proceed. If this situation persists for any length of time there
will be a significant hiatus in the development pipeline.
We therefore urge that that, as well as relying on
the New Homes Bonus, Ministers issue fuller guidance under the
new system to ensure local authorities know how to calculate housing
numbers, even if they are totally responsible for the actual number,
and that the criterion for determining planning applications will
not be based simply on numbers but will also include the absence
of harm to the plan to enable acceptable windfall sites to be
developed.
LOCAL ENTERPRISE
PARTNERSHIPS
CLG and BIS propose that Local Enterprise Partnerships,
which should include groups of upper tier authorities, take over
responsibility for planning and housing, local transport and
infrastructure from RDAs and provide strategic leadership
at sub-regional level.
On 14 July Housing Minister Grant Shapps said: "We
are scrapping regional planning... removing the regional tier
of Government...Regional Spatial Strategies and top-down housing
targets. Instead, through Local Enterprise Partnerships, we are
placing responsibility for economic development with the people
who really understand the challenges and opportunities their area
faces."
So how large a role will LEPs have on housing and
planning matters? Will they be adequately funded to play an effective
part at sub-regional level? Will they undertake research and issue
information and guidance to local planning authorities?
We believe that their role should include the identification
of the housing and social care needs of ageing populations in
their sub-regions and the provision of an appropriate framework
for policy implementation at local level.
Planning magazine commented
on 3 September "...a clear blueprint for what LEPs should
be doing, how they will do it and how their performance can be
judged is noticeable by its absence...Without thinking through
these basic ideas, ministers risk being forced to intervene further
down the line. Without a proper remit, there will be no proper
results."
Government has said that more information about the
new sub-regional LEP structure will be available after the Spending
Review in October. We hope this includes details of their relationship
with local planning authorities and whether this will ensure that
there is appropriate cooperation between local planning authorities
on matters formerly covered by regional spatial strategies.
We would urge Government to devise such a blueprint,
together with a framework to evaluate performance, before the
Spending Review and any public announcement on LEPs, and we look
forward to learning more about their role, funding and relationship
with local planning authorities in the expectation that it will
support positive policy making in this area.
NEW HOMES
BONUS
We are also invited to comment on the likely effectiveness
of the Government's plan to incentivise local communities to accept
new housing development, and the nature and level of the incentives
which will need to be put in place to ensure an adequate long-term
supply of housing.
It is difficult to judge the likely effectiveness
of the Bonus because there has been little additional detail provided
since Conservative Policy Green Papers Nos. 9 and 10 were published
in 2009.
Policy Green Paper No. 10 said: "...we will
match the additional council tax raised by each council for each
new house built for each of the six years after that house is
built" and "We will therefore consult on how to build
on and augment our council tax incentive scheme in order to increase
the incentive for councils to deliver affordable houses."
Recently CLG Minister Bob Neill commented (8 September) that the
new homes bonus scheme would include funding at 125% for social
or other affordable housing. It could reasonably be argued that
a similar, enhanced, incentive for local authorities who supported
specialised housing schemes for older people should also be given
serious consideration, bearing in mind the need to provide for
our rapidly ageing population. If the building of more such properties
were encouraged by local planning authorities, older people could
remain independent for longer, with a better quality of life,
thereby relieving the burden on NHS, welfare and social services
and freeing up family-sized homes for families.
It is very important that any incentive scheme is
seen by local communities to be bringing them directly-related
benefits arising from new development in their area. If there
has been concern in the past that S.106 Agreements have failed
to deliver this then the Bonus must identify and resolve the problem
if, as the Government intends, it is to overcome opposition and
win supporters for development.
We would welcome further information on how the New
Homes Bonus will work and how this will related to the Government's
revised proposals for a Community Infrastructure Levy which they
say, together, will "send a very clear signal that local
authorities that choose to go for growth...will receive substantial
extra funding for doing so."(3)
We would be pleased to supply more information to
answer further questions if the Committee would find this helpful.
REFERENCES
(1) The Government-commissioned HAPPI (Housing
our Ageing Population: Panel for Innovation) to produce a Report
which was published in December 2009, recommending that "Central
Government prioritises the building of new homes for our ageing
population as a key component of its housing, health and care
policies".
(2) Subnational Population
Projections (SNPP) for England Statistical Bulletin—2008-based
www.statistics.gov.uk/statbase/Product.asp?vlnk=997
(3) Housing Minister Grant Shapps' letter of
9 August to local authority leaders formally announcing the New
Homes Bonus.
September 2010
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