Communities and Local Government CommitteeWritten evidence submitted by McCarthy & Stone

Summary

McCarthy & Stone provides 70% of retirement and extra care schemes built for purchase by older homeowners in the UK. The average age of residents is in the late 70s and apartments include varying levels of care, management and support. Since 1977, McCarthy & Stone has delivered approximately 1,000 developments and nearly 50,000 apartments.

Retirement housing is affected more adversely by building’s regulatory burden than any other form of development. The impact of national building regulations on this type of accommodation to date has been overlooked because of the unique nature of older people’s housing.1 Given the real benefits of this form of accommodation to residents and communities, as well as the rising numbers of older people and the increasing demand for better housing choices for the elderly, McCarthy & Stone is calling for a national review of all regulatory burdens that unduly affect specialist housing for older people.

With regard to this inquiry, McCarthy & Stone feels that Part P of the Building Regulations (which refer to electrical installations) is effectively redundant. McCarthy & Stone’s schemes are already built to IEE regulation Standards, which is a mandatory requirement and well above the needs of Part P of the Building regulations. Part P is inadequate and results in additional costs, paperwork and time for providers. It is one example of how the national regulatory burden negatively affects the delivery of an important form of care and accommodation for older people.

Introduction

What is specialist housing for older people?

1. Specialist housing for older people includes retirement apartments (similar to Category II Sheltered Housing) and extra care schemes. It enables older people to maintain home ownership while having access to varying levels of care and support. Each apartment within a scheme has its own front door, a residents’ lounge, communal laundry, lifts, a House Manager and camera entry systems—they are designed to promote independent living in a secure environment and offer an ability to meet and socialise and possibly the preparation of meals and a dining room.

2. McCarthy & Stone’s three scheme types are:

(i)Retirement Living (since 1977)—Similar to traditional “Category 2” type sheltered housing. Now built to Lifetime Homes Standards. It includes a House Manager, lounge, communal “laundry”, CCTV and camera entry system, guest suite and lifts to all floors. Residents have active, independent lifestyles in a safe but private environment. The average resident age is approximately 78.

(ii)Extra Care (Assisted Living) (since 2000)—McCarthy & Stone has 42 Assisted Living schemes, either open or in planning, making us one of the largest private Extra Care providers in the UK. These dwellings are as above but are designed to full wheelchair housing standards and widths, and include more services such as 24-hour attendance, a restaurant, lounge and one hour per week of domestic assistance, with additional domestic and care packages available. The average age is approximately 83. Schemes are managed by a CQC-registered joint venture between McCarthy & Stone and Somerset Care.

(iii)Extra Care (Tailored Care Living) (since 2011)—McCarthy & Stone’s first scheme at Littlehampton, West Sussex, was released for sale in summer/autumn 2011. It is similar to the above, but with assessment of care needs/packages on entering, with assisted bathing, treatment rooms, spa and hairdressing facilities. It is a direct alternative to traditional residential care but with home ownership retained. Residents are in their mid 80s and will generally be frailer and with specific care needs at the point of entry.

3. Ownership for each of these schemes is self-funding through the release of the £980 billion that older people hold in housing equity. There is no reliance on state funding.

4. However, although the number of people aged over 65 will grow from 10 million to 16.7 million by 2035,2 the UK has built just 105,000 specialist retirement homes for ownership, significantly less than other developed countries. Half of new household growth by 2026 will be by those aged over 65. On of the historic reasons for under-supply in retirement housing is because of the high regulatory burden which serves to increase cost and complexity of delivering what is already a tricky market in which to succeed.

Part P of the Building Regulations

5. Part P of the Building Regulations—the subject of this inquiry—deals with electrical installation and safety in dwellings. It was introduced primarily to control the DIY-type electrical works carried out on refurbished buildings, although it is a requirement that actually affects all forms of development. This submission refers to electrical installations rather than gas installations as few McCarthy & Stone developments use gas.

6. In our view, Part P is effectively redundant and not relevant to new build schemes as the requirements of the Institute of Electrical Engineers’ (IEE) far surpass its regulations. However, McCarthy & Stone still has to complete all of the paperwork for Part P as well as for the IEE. It is therefore forced to comply with two forms of regulations for the same piece of work.

7. All electrical work undertaken by McCarthy & Stone must be to IEE regulation Standards (BS 7671:2008+A1:2011 Requirements for Electrical Installations: BS 7671:2008 Incorporating Amendment No 1: 2011: IET Wiring Regulations) and is mandatory, including all works and parts of works being carried out by NICEIC Approved contractors. This is well above the requirements of Part P.

8. Part P does have some value with refurbishment and does provide some safety cover for DIY type electrical matters. However, in speaking with governing bodies, anecdotally there is a consideration that DIY activities are not truly being covered by Part P so it is not doing its job.

9. It is worth noting that, where gas is used for heating apartments as opposed to houses, the cost burden is much higher as fire and building regulations impose more onerous conditions in order to provide safe use. We agree with these extra measures but it does or can cost substantially more.

Why the burden is higher on retirement housing

10. Retirement housing is a significantly different form of accommodation to traditional house building, yet regulations follow a one-size-fits-all approach. Examples of these differences and the impact this has on regulations are noted below.

11. Sites for retirement housing are often small, relatively high density and close to town centres and amenities as these are the areas where older people wish to live. Residents tend to be in their late 70s and early 80s and therefore have different design requirements to traditional home owners. Developers must deliver a lifestyle, not just a building, so schemes are specially designed, including bespoke doors and windows. They also include care, management and support teams and other facilities such as treatment rooms. Communal space such as residents lounges, restaurants, function rooms and health areas are not usually supplied within other forms of housing, yet in retirement housing, they are extensive and usually account for up to 30% being “non-saleable” floor space.

12. These are some of the differences, and there are many examples in national building regulations where they are not recognised, including:

(a)The Code for Sustainable Homes provides credits for cycle storage and for the ability to work from home, but residents in retirement schemes are on average in their late 70s and usually neither work nor cycle.

(b)The Floods and Water Management Act 2010 requires developers to provide on-site Sustainable Urban Drainage systems (ie underground water storage tanks), but while this is fine for house builders on edge of town sites with sufficient space, it is near impossible to provide in dense urban areas.

(c)Secured by Design certificates require residents’ front doors to be designed to a specific safety standard, but residents’ front doors in McCarthy & Stone apartments are within the scheme and open onto secure internal corridors. In addition, the wider scheme also has a robust security perimeter, camera entry door and a House Manager. There is no need to provide such heavy-duty and expensive doors within a scheme.

13. These are just some examples of the burden. Many others can be provided.

Conclusion

14. McCarthy & Stone welcomes the inquiry into Part P of the building regulations. It would also like to see a wider national review of how the regulatory burden impacts adversely on the building of new homes for older people.

January 2012