Draft Charging Schedule and Draft Regulation 123 List

Whilst the proposed rates for extra-care specialist housing for older people are a considerable improvement on the previously proposed schedule the two rates proposed £45psm on greenfield sites and £25psm for brownfield sites still represent a disincentive to the development of this type of property.

Extra-care developments must include several communal spaces if they are to follow the DOH model. These include at least a communal lounge, dining room (and a kitchen that is substantial enough to provide a hot meal each day for all residents), a laundry and a guest room. Addition facilities such as an activity room, fitness suite are highly desirable.

The purchase price or rent of the individual apartments cannot be increased to cover the full cost of providing these spaces.

Secondly, the on-site staff costs for these developments are substantial and can only be recovered when all apartments are sold or rented and all service charges being paid. The shortfall is a substantial cost to the development.

Thirdly, the building of this type of property cannot be phased in the way standard residential construction can be phased. The entire development must be completed before apartments can be sold.

These additional costs add significantly to the overall cost of extra care housing and the viability assessment did not properly take these costs into account. There is substantial evidence that older people in this type of accommodation reduce costs to both social services and the NHS and so the CIL schedule should be encouraging not discouraging such developments.

This has the potential to be helpful for extra-care housing development in the event that a CIL for extra-care housing is introduced.