Written evidence submitted by Anchor Hanover [FPS 074]

1. Is the current planning system working as it should do? What changes might need to be made? Are the Government’s proposals the right approach?

• It is Anchor Hanover’s view that the current planning system is not fit for purpose. It is often convoluted, varies wildly in policy-terms from area to area, and results in outcomes and decisions that are often questionable.

Simplification of local plans

• Anchor Hanover supports the simplification of Local Plans on the condition that there is enough time to identify local needs and to involve the community without delaying development plans
• We have, for some time, been calling for the inclusion of specialist older people’s housing, including retirement and Extra Care housing, in Local Plans.
• As the UK’s population ages, an increasing number of older people are occupying housing which is unmanageable and unsuitable to their needs. With this has come pent-up demand for specialist housing which has been increased by the Coronavirus pandemic. 
• Recognition of specialist housing in Local Plans would help to address this pent-up demand, reducing pressure on local services, helping older people to remain part of their local communities and contributing to the economy whilst freeing up larger, family-sized housing for younger generations.
• With this, any simplification of Local Plans must ensure that there is sufficient opportunity for the needs of the local area to be assessed and for the community to input into the plan.
• We agree with the proposals for a 30-month statutory timescale for local plans. However, as we have stated above, any timescale on Local Plans must allow for a full needs’ identification process.
• This must take into account local demand for specialist housing and include consideration of land for development of this type of housing.
• There should also be sufficient time for assessment of the reduced need for housing resulting from larger houses freed up by older people according to the number of retirement properties built in an area.
• Research from Professor Les Mayhew found that each additional retirement property released an excess of 2.25 bedrooms per property, meaning that fewer units of general housing are required. This could be an uplift in delivery rather than being seen as alternative to general needs provision.

Streamlining of development management policies

• The risk of this streamlining is the lack of a suitable mix of development unless dictated as a top down process.
• There is a need for Local Authorities to identify local needs and allocate land appropriately.
• We support the recommendations made in ARCO’s and the County Councils Network’s 2020 report, Planning for Retirement: How retirement communities can help meet the needs of an ageing population, calling for the introduction of a new classification for retirement housing.
• As the report highlights, there is considerable confusion with regards to retirement communities as they combine elements of the C2 class for residential institutions and C3 for dwelling houses.
• A new C2R classification would better enable Local Authorities to include retirement housing in Local Plans, helping to address the lack of diversity in development which currently exists and increase the quality of the retirement properties being delivered. ? Can we check on this? The C2R seems to suggest 24/7 on site care/support and we are not doing that in new developments due to Board decision not to be the care provider and move away from traditional ‘extra care’ style development

Affordable housing and infrastructure

• We are concerned that proposals to consolidate community contributions and payments for affordable housing will reduce the number of affordable homes delivered through Section 106 agreements.
• The Planning White Paper does not clarify if the new levy would see contributions towards affordable housing ring-fenced in the same way currently seen by Section 106 agreements.
• Should these changes go ahead, the threshold set in the new Community Infrastructure Levy must be low enough so that it does not provide a barrier to delivering new homes.
• The operating margins of specialist housing are lower than many other developments. Any changes to Section 106 agreements and the current Community Infrastructure Levy must reflect this and be set at a level that allows for development.
• The operating margin of specialist housing is lower than many other developments. Any changes to Section 106 agreements and the current Community Infrastructure Levy must not be a barrier to specialist housing development.
• When setting this levy, it is vital that the benefits of specialist housing, particularly Extra Care, on health and wellbeing, in reducing the strain on public services including the NHS and its contribution to economic growth and diversification are taken into account.
• Anchor Hanover’s and Sonnet Impact’s 2020 report, The social value of an Anchor Hanover tenancy, highlighted the benefits of Anchor Hanover services alone to the NHS and residents alike.
• The research found that:
• The social value of an Anchor Hanover supported tenancy is at least £2,800 per year per resident. This is in addition to the £3,400 in social value delivered for an older person in a general needs social tenancy.
• The average resident who uses out financial assistance and advice service, BeWise, which helps with bills management and access to benefits, is £6,000 per year better off.
• Through tackling loneliness, we save the NHS and other public services around £3,000 per year per resident.
• Our Extra Care services save public services £6,700 per year per resident through providing care and tackling issues such as malnutrition and physical inactivity.
• We believe the Infrastructure Levy should aim to capture more value.
• The Community Infrastructure Levy is based on land value and profits. If you bid on land knowing the costs to be met such as Community Infrastructure Levy and Section 106 agreements then offers can be made accordingly on land and the overall offer.
• Like specialist housing, affordable housing should be ‘ring-fenced’.
• Anchor Hanover welcomes the recognition of supported housing in the Affordable Homes Programme – 10% of the of the money allocated for discounted rented homes – though further measures must be taken to ensure more specialist housing is built and across a wider tenure range to reflect changing levels of home ownership.
• Along with recognition of specialist housing in local plans, Anchor Hanover supports the recommendations of ARCO’s Too Little? Too Late? Housing for an ageing population report.
• These include: putting ‘last time buyers’ on an equal footing with first time buyers in terms of Stamp Duty Land Tax, with properties up to £300,000 nil banded.
• A government strategy which takes a joined-up approach to housing and health to help recognition of the benefits of specialist housing to the NHS and care services as well as the wider economy.
• House-building priorities must change to cater for affordable housing to meet the demand for downsizing amongst older people.
• Models that defer costs until housing equity is released should be encouraged and monitored for transparency of costs to residents and returns to investors.
• Independent guidance about the financial aspects of downsizing should be available to cover all aspects of the purchase process. The Money and Pensions Service is a possible vehicle for this.

2. How can the planning system ensure that buildings are beautiful and fit for purpose?

• Anchor Hanover agrees with the Government’s proposals to introduce design guides and codes.
• Developers and operators should follow guidance on design, including Housing our Ageing Population Panel for Innovation (HAPPI) principles, with Local Authorities providing encouragement to them through appropriate funding and conditions applied through the planning system. The HAPPI principles do not just apply to the initial design of homes but also to their adaptability should improvements be necessary.
• Design and adaptability are the keys to enabling independence and poorly designed, inaccessible housing can impact on confidence and further isolate individuals in their own homes.
• We believe the keys to successful design are:
• Hard design: creating wider doorways, accessible rooms designed for improved mobility, kitchens and bathrooms that enable independence.
• Environment, inside and outside the home: reducing distractions, and where possible keeping stimuli to a minimum and enabling familiarity.
• Soft design: taking into account the auditory impact of surfaces, the use of tactile and visual cues as reminders, labelling, grab rails.
• Adaptability: allowing for improvements which take into account the potential future needs of residents and that many may wish to remain in their homes.
• Appropriate housing enables people to live as part of a community. Good design can encourage people living with complex needs such as dementia to experience the community around them while also attracting support from the community for the housing scheme.
• Anchor Hanover supports the introduction of a new authority to support good design and high-quality development.
• It is crucial that design coding and quality control is set against the need for delivery rather than against the design code established by one person.
• However, Anchor Hanover disagrees with proposals to introduce a ‘fast track for beauty’. We are concerned as this appears similar to a “twin-track” approach that risks favouritism and the use of capital to acquire approval. All design should be suitable and against parameters.
• We are also concerned that concern for beauty standards may translate into a focus on outwards appearance rather than other crucial aspects to older people such as size, space and accessibility standards. 

3. What approach should be used to determine the housing need and requirement of a local authority?

• We believe that a standard method for establishing housing requirements (that takes into account constraints) should be introduced. However, in terms of specialist older people’s housing, this standard method must include recognition of the range of needs of older people and tenure (more older people own homes than younger generations, for example) and not just the number in the community.
• As our society ages, the needs and expectations of those in later life are changing. The Coronavirus pandemic, a time when many older people have been more reliant on the home environment than ever before, has brought many of these needs to light.
• In Anchor Hanover services, we are seeing a growing number of residents who, for economic reasons, are still working often living alongside much older residents – some of whom are over 100 years old.
• This brings a number of challenges in terms of the services we provide. It is therefore vital that a thorough assessment be carried out which includes engagement with the local community.
• Specialist housing for older people is often underestimated by the current formula which considers workplace-based median earnings. With the overwhelming majority of those in need of specialist housing now retired, this formula often overlooks their needs.
• The formula must be revised so that either a specific calculation of median pension earnings in an area is taken into account, or a standard calculation introduced to ensure that a percentage of housing with care for older people and affordable housing with care for older people is provided.
• Without the above, there is a risk it is driven by consultees (care commissioning authority) who want ‘extra care’ rented accommodation but have little financial / societal driver for other forms of older persons housing and accommodation. Such an approach results in an under-supply of housing for older people who are in better financial circumstances, forcing them to remain in larger properties which are less well-suited to their needs.
• Housing need cannot only be decided by local care or housing teams who, in our experience, are often focussed on providing sufficient levels of affordable general needs housing and have no experience of older people’s housing.

4. What is the best approach to ensure public engagement in the planning system? What role should modern technology and data play in this?

• Local communities should be engaged in Local Plans however this should be in line with agreed parameters around volume, location, design and build standards. This will help to avoid the delays often seen to proposals for development in certain areas.

5. How can the planning system ensure adequate and reasonable protection for areas and buildings of environmental, historical, and architectural importance?

• Anchor Hanover agrees that the legislative green belt and Areas of Outstanding Natural Beauty should be protected. We would however, like to see what impact this has on town and city centre conservation areas. How can these be developed or improved if there is a blanket protection? Often these are attractive areas and include small pockets of land for limited volumes of development.

6. What progress has been made since the Committee’s 2018 report on capturing land value and how might the proposals improve outcomes? What further steps might also be needed?

• We believe that, if introduced, the Infrastructure Levy should aim to capture more value.
• The Community Infrastructure Levy is based on land value and profits. If you bid on land knowing the costs to be met such as Community Infrastructure Levy and Section 106 agreements then offers can be made accordingly on land and the overall offer.

October 2020