Q131. What are your views on the Council’s proposed policy on specialist housing for older people?
Q132. Are there any alternatives or additional points the Council should be considering?

Although we are supportive of the sentiment of policy HOU9: Specialist Housing for Older People we have concerns with regard to several elements of the policy:

1. Prioritising extra care housing over retirement living or sheltered housing unless it is demonstrated that the site is unsuitable for an extra-care or housing with care scheme, or that there is an identified need for the proposed accommodation type in that location

We have concerns with regard to the policy wording that seeks to prioritise extra care housing over retirement living or shelter housing. We believe the evidence supporting this assertion is not robust especially given the large increase in the older population projected and the critical need to provide housing for older people as detailed in Paragraph 001 Reference ID: 63-001-20190626 of the PPG was updated to include a section on Housing for Older and Disabled People that 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” (emphasis added).

It is well documented that the UK has an ageing population. Life expectancy is greater than it used to be and as set out above by 2032 the number of people in the UK aged over 80 is set to increase from 3.2 million to 5 million (ONS mid 2018 population estimates).

It is generally recognised (for example, within the Homes for Later Living Report September 2019). That there is a need to deliver 30,000 retirement and extra care houses a year in the UK to keep pace with demand.

The age profile of Rother can be drawn from the 2018 population projections from the Office for National Statistics. This advises that there were 30,500 persons aged 65 and over in 2018, accounting for 31.9%% of the total population of the Council area. This age range is projected to increase by 15,014 individuals, or 49.2%, to 45,514 between 2018 and 2043. The population aged 65 and over is expected to increase to account for 41.1% of the total population of Rother by 2043.

In 2018 there were 8,922 persons aged 80 and over, individuals who are more likely to be frail and in need of long-term assistance. The number of people in this age range is forecasted to increase by 8,255 individuals, or 92.5%, to 17,177 between 2018 and 2043. The population aged 80 and over is anticipated to represent a higher proportion of Rother ’s residents, accounting for 9.3% of the total population in 2018 and increasing to 15.5% by 2043.

It is therefore clear there will be a significant increase in older people and the provision of all types of specialist housing for older people to meet the needs of the elderly demographic should be supported not just extra care housing.

For clarification, the policy is supported by the Rother and Hastings Housing and Economic Development Needs Assessment Update, DLP, 2023 (‘HEDNA’). The full methodology is detailed in Appendix E of the study. This uses a number of sources of evidence including 2021 census data, the Mayhew report, research as to whether the British want to live in integrated retirement communities and a study entitled ‘unlock the retirement opportunity in a post-pandemic world’. This also considers a variety of prevalence rates. Overall, we are concerned as to how some of these sources have been interpreted and how this has impacted the need figures resulting in the identification of a large need for extra care housing and an existing over-supply of sheltered housing. As an example, para 3.1 of the HEDNA states that ‘The Mayhew Review (2022) suggests that the need for extra care housing would be the following a) 10K homes a year baseline, b) 30K homes a year minimum, c) 50k homes a year target’. However, our understanding is that these figures are for all elements of retirement housing, not just housing with care and therefore this has been misinterpreted. Another example is the research associated with ‘whether the British want to live in integrated retirement communities’. The Council should note that this is a specific element of research into Integrated Retirement communities (IRC) and that IRC’s tend to be a very high-end produce with a number of additional support services such as swimming pools and spas that are more exclusive and potentially skews the result but assume the question is related to all retirement housing.

This misinterpretation of research has resulted in the study concluding that there is a trend in choice away from retirement living housing / sheltered housing towards extra care housing and has resulted in the overly large need for extra care housing being identified with conversely the identification of an existing over-supply of sheltered / retirement living housing. This appears to be on the basis that people will choose to remain in their existing family home until their care needs are so acute they need care. This has resulted in the prevalence rates for sheltered housing (ownership) to drop from 140 per 1000 by the SPRU in 2022 to 25 per 1000 in 2023 (see table 3, appendix E of the HEDNA). This is well over a 400% change from the original SPRU model and causes concern regarding the robustness of the model. We would therefore recommend that the council delete the following wording from policy HOU9 in order to ensure all forms of specialist housing for older people are supported and a preference is not expressed within the policy.

Schemes providing extra-care housing or housing with care will usually be prioritised over retirement living, sheltered accommodation or age-restricted general market housing74 , unless it is demonstrated that the site is unsuitable for an extra-care or housing with care scheme, or that there is an identified need for the proposed accommodation type in that location.

2. The requirement for specialist housing for older people to also deliver affordable housing in accordance with policy HOU2 (affordable housing)

Please see our response to questions ‘Q116. What are your views on the Council’s proposed policy on affordable housing?’ And Q117. Are there any alternatives or additional points the Council should be considering?’ In response to policy HOU2.

3. The requirement to for specialist housing for older people to comply with the 10 key design criteria set out in the HAPPI principles and other recognised design standards and guidance relevant to older people’s housing.

As well as requesting a minimum number of homes to be built to M4(3) and M4 (2) standards the plan is asking for specialist housing for older people to meet the 10 design criteria set out in the HAPPI principles. However the council should note that paragraph 1 of the PPG “Housing: Optional Technical Standards” (March 2015) states:

The government has created a new approach for the setting of technical standards for new housing. This rationalises the many differing existing standards into a simpler, streamlined system which will reduce burdens and help bring forward much needed new homes. The government set out its policy on the application of these standards in decision taking and plan making in a written ministerial statement’.

This effectively means that the application of Lifetime and Wheelchair Home Standards has been superseded by the Optional M4 standards and the M4(2) standard is broadly equivalent to lifetime Homes (see Governments Consultation on Raising Accessibility standards July 2022). In addition, many of the HAPPI principles such as daylight, balconies and space are now controlled by the requirements of the building reregulation and other planning requirements and therefore the guidance if referred to at all within the policy should be seen as an aspiration and not a requirement with a recognition that many elements have been superseded by or creates a tension with the building regulations.