RCA's 38 Days of the Housing White Paper; Day 3...

Everyday for the next 36 days we will be providing a link to our responses to the Government's Housing White Paper; here is our reply to Question 3... 

Do you agree with the proposals to:

a)     Amend national policy so that local planning authorities are expected to have clear policies for addressing the housing requirements of groups with particular needs, such as older or disabled people?

We wholeheartedly agree with a robust and honest approach being taken to the calculation of housing needs for all groups in society.  For far too long people have been living in inappropriate accommodation, often some distance from their families, because a severe lack of appropriate accommodation locally, particularly children and young people with conditions such as Autistic Spectrum Disorder (ASD) and Downs Syndrome.  This has no doubt contributed to situations such as the abuse scandal at Winterbourne View.  We consider that there should be a presumption in favour of housing for severely disabled people or people with particular special needs which override very restrictive policies such as Green Belt.  However, we recognise that this may require a specific amendment to the NPPF with guidelines to assist developers and planning authorities.  Please see the appeal led by RCA Regeneration wherein a housing scheme for people with ASD was permitted in Green Belt: APP/H1840/W/15/3007970.  The Inspector remarked:

“In this case, the totality of the other considerations outlined above clearly outweighs the harm to the Green Belt by reason of inappropriate development and the harm to its openness.  When looked at in the round, the acute and urgent need for such specialised and affordable accommodation for people with ASD, the linkages with the existing Upper Ford Lodge residential care home and the lack of any realistic alternatives mean that very special circumstances exist to justify allowing the development.

We consider that such cases should not have to be made at appeal – the delay and costs impact on the very people such proposals are made to assist.  If properly evidenced, development plans should either contain specific allocations to meet need, or contain appropriately worded development management policies that support such proposals in appropriate locations, including Green Belt if the case is made.

Similarly, the considered provision of sufficiently varied housing options for older people is very much a ‘lottery’ and is dependent on the approach of individual planning authorities.  Given the burgeoning need for housing to meet a very wide range of different needs, it is clear that a ‘one size fits all’ approach to older persons housing will not work.  Some ‘sheltered’ schemes do not allow residents with dementia to live there, which splits up couples prematurely, even if they have bought their own property.  Care villages are becoming more popular, offering a greater housing choice, but remain out of reach for many because care costs need to be subsidised or they ‘avoid’ triggering an affordable housing requirement.  Again, a considered approach to housing for older people from providing downsizer properties (which have the effect of ‘freeing up’ family housing) to a greater number of well-located 1 and 2 bed apartment schemes to sheltered, supported and care home models must be taken.  Developers (including volume housebuilders and housing associations), care operators, charities, the NHS and other healthcare organisations must get together with planning policy officers to set out a clear strategy in every single planning authority area to agree a strategy for choice and improved competition in the market for housing for older people, or risk an ad-hoc reactive approach that will result in provision being patchy and inadequate – as it is now.     

b)     From early 2018, use a standardised approach to assessing housing requirements as the baseline for five year housing supply calculations and monitoring housing delivery, in the absence of an up-to-date plan?

Yes, we agree with this in the absence of any other alternative.  Having direct experience of this in the recent past, we have presented multiple potential OAN scenarios to S78 Inspectors, which take significant time and money in light of there being no up to date plan nor agreed OAN in place.  We are all aware it is not for a S78 Inspector to pre-determine the OAN figure, which we also agree with.  However, an agreed standardised approach should be taken on the basis of whichever yields a higher figure: this will serve to incentivise Council’s to progress plans quickly or face having to calculate 5 year supply against a potentially much higher target.  This may also impact more acutely on stakeholders and politicians wishing to minimise development levels for their authority area or delay plans for whatever reason: agree a sensible figure quickly and progress the plan or face higher levels of development than otherwise anticipated.

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