Policy HSG2 Affordable Housing require proposals for housing of 10 dwellings or more (or is on sites of over 0.5 hectares) to deliver 40% affordable housing. This includes specialist housing for older people as confirmed through policy HSG6 Specialist Accommodation for Older People and those with Specialised Needs.
We note that consultation has been published without the supporting evidence of an up-to-date viability study and it is therefore difficult to ascertain if any of the options put forward are realistic or deliverable. We advise that by limiting scrutiny of the Local Plan Viability Assessment the Council is reducing the opportunities for comment on a crucial element of the evidence base that will inform policy and deliverability directly and the Local Plan would be consequently less robust.
We would like to remind the Council of the emphasis on Local Plan viability testing in Paragraph 58 of the NPPF and that the PPG states that “The role for viability assessment is primarily at the plan making stage. Viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the plan” (Paragraph: 002 Reference ID: 10-002-20190509).
Within any viability assessment the Council should acknowledge that the viability of specialist older persons’ housing is more finely balanced than ‘general needs’ housing. We are strongly of the view that these housing typologies should be robustly assessed separately to mainstream housing. This would accord with the typology approach detailed in Paragraph: 004 (Reference ID: 10-004-20190509) of the PPG on viability which states that. “A typology approach is a process plan makers can follow to ensure that they are creating realistic, deliverable policies based on the type of sites that are likely to come forward for development over the plan period.” If this is not done, the delivery of much needed specialised housing for older people may be significantly delayed with protracted discussion about policy areas such as affordable housing policy requirements which are wholly inappropriate when considering such housing need.
The Council must therefore ensure that an up-to-date viability assessment is undertaken to inform the future plan and ensure the plan is deliverable. The new viability assessment must include a number of typologies that includes older person’s housing and if older person’s housing is found to be not viable an exemption must be provided within the plan in order to prevent protracted conversations at the application stage over affordable housing provision and delaying the provision of much needed older persons housing.
We would direct the Council towards the Retirement Housing Consortium paper entitled ‘A briefing note on viability prepared for Retirement Housing Group by Three Dragons, May 2013 (updated February 2013 (‘RHG Briefing Note’) available from https://retirementhousinggroup.com/rhg/wp-content/uploads/2017/01/CIL-viabiilty-appraisal-issues-RHG-February-2016.pdf. The RHG Briefing Note establishes how sheltered housing and extra care development differs from mainstream housing and looks at the key variables and assumptions that can affect the viability of specialist housing for older people. These key variables include unit size, unit numbers and GIA, non-saleable communal space, empty property costs, external build cost, sales values, build costs, marketing costs and sales periods.
Recommendation
The Council must ensure that an up-to-date viability assessment is undertaken to inform the future plan and ensure the plan is deliverable. The new viability assessment must include a number of typologies that includes older person’s housing and if older person’s housing is found to be not viable an exemption must be provided within the plan in order to prevent protracted conversations at the application stage over affordable housing provision and delaying the provision of much needed older persons housing.