Housing and Planning Bill

Written evidence submitted by the Retirement Housing Group (HPB 38)

Starter Home Initiative and Retirement Housing


There appears to be ambiguity in the Bill as currently drafted as to whether the requirement for the provision of starter homes will be in addition to or instead of affordable housing. This has negative implications for the financial viability of housing developments, the progress of Local Plans and the progress of current planning applications including applications for development of specialised retirement housing. The provision of retirement housing is recognised in National Planning Policy Framework and Guidance as desirable. To require starter homes on the same site is not appropriate and will discourage downsizing and the expansion of the retirement market to meet growing demand. Exempting retirement housing from starter homes requirements would overcome this difficulty.

1. Paras 1-7 of the Housing and Planning Bill give the Secretary of State the power to require  that for all applications for residential development above a certain size there must be a planning obligation (under section 106 of the 1990 Act) securing a certain proportion of starter homes on the site.   The regulations may also specify that certain types of residential development should be exempt, or that certain areas should have a higher starter home requirement, or that local planning authorities should have discretion about certain requirements.

2. It is unclear from the wording of the Bill whether this requirement is in addition to or instead of existing affordable housing requirements.  These two different interpretations would have very different impacts on the financial viability of housing developments.

3. It is also unclear whether this amended requirement will have any impact on Community Infrastructure Levy charges, which, in the case of those already in place, will have been costed against an entirely different affordable housing regime.

4. Retirement Housing Group (RHG) members are concerned that any requirement to provide starter homes (which must be sold to purchasers aged under 40) would be extremely disruptive if applied to sites where it is proposed to develop specialised retirement housing.  Such schemes, whether sheltered or Extra Care accommodation, are financially more challenging to develop than general housing due to a range of factors including the "unsaleable" communal space provided and the need to complete the entire development before any properties can be sold or let and occupied. It is suggested that Retirement Housing schemes should be exempted from any requirement for the provision of starter homes.

5. RHG believes that uncertainty about how the starter home regime will work in practice will impede production of Local Plans and make it more difficult for our members to reach agreement with local authorities about schemes which are currently going through the planning process. The immediate effect will be to reduce new housebuilding and slow down Local Plan production.

6. RHG also believes that, given the shortage of retirement housing in England and Wales and the prevalence of under-occupancy among older households (51% of all households aged 65 and over are under-occupying by two or more bedrooms [1] ) it is just as important to require schemes to provide retirement housing to stimulate mobility in the housing market as it is to require provision of Starter Homes. Consideration should be given to how additional provision of retirement housing can be encouraged.

The Retirement Housing Group (RHG) is membership organisation comprising retirement housing developers and housing managers in both private and housing association sectors. Its ex officio members include the charity, the Elderly Accommodation Counsel.


November 2015



Prepared 17th November 2015