Sadiq Khan’s Next Housing Policy Victim, Housing for Older People
The Mayor of London is turning into a housing policy serial killer and nobody is brave enough to stop him.
Sadiq Khan. The proverbial Professor Plum with the candlestick in the library. At least to developers of housing for older people in our capital. Only the Mayor of London isn’t leaving clues, he is leaving a trail of demonstrable incompetence. His contrived attempt to reclassify housing with care as ‘Class C3 Residential’, via changes to the draft London Plan, has led to the proposed LifeCare scheme in Hampstead looking like a murder scene. Aided and abetted by Camden Council and the Planning Inspectorate, he has played a significant role in seeing it rejected on appeal.
The murder weapon, imposing the need to provide affordable housing for ‘Class C2 Residential Institutions’.
The likely motive, London Assembly colleagues suggesting he “could do better”, with his record on affordable housing having been brought into question.
It is a misplaced requirement for retirement living communities to provide affordable housing. Sadiq Khan and his housing policy team clearly lack any comprehension of the the implicit design inequalities that have seen ‘C2 Residential Institutions’ sit outside of this requirement for decades. Contributions from previous leaseholders are important in ensuring these schemes remain viable on an ongoing basis, underpinned mostly through “Event Fees”. The Mayor’s muddling is nothing less than usurpation of these fees for the purposes of affordable housing provision, instead of allowing operators to provide on-site care of the elderly.
Due to the level of amenities and healthcare provision within retirement living communities they inevitably operate at a much less efficient gross to net basis, when compared to typical residential development. This means they garner value from only 65–70% of the gross area of the building, meanwhile C3 schemes achieve up to 80%. The need to provide affordable is removed from C2 in order for it to remain competitive in the land market. Without it developers ability to bid for land is severely compromised.
In the UK only 0.6% of older people are residing in retirement living communities. Compared to Australia, New Zealand and the USA, these more maturer markets all exceed 5%. The UK sector is evidently nascent and has significant room for growth, but achieving this will not be without its challenges. The inevitable result will see developers need to move to a model that pushes up values of such units higher, or focus on cheaper less quality development through lower build costs. Perhaps a consideration for local Councillors clapping through a rejection on noddy grounds of no affordable, with a complete disregard for wider provision of adult social care.
Policy in the London Plan does not set planning use classes, laws do. Namely in the UK through the Town and Country Planning (Use Classes) Order 1987, of which determines C2 Residential Institutions as the following:
“Use for the provision of residential accommodation and care to people in need of care (other than a use within class C3 (dwelling houses)).”
The LifeCare scheme was refused for no less than sixteen reasons. Although the main concern for the sector comes as a direct result from Sadiq’s malfeasance. Blurring the lines between C2 and C3 results in developers sitting in limbo, having obscured the classification of retirement living communities for councils and inspectorates. JLL attempt to explain the difference below:
The Mayor of London appears to be under pressure given he is set to miss yet another housing target. Sadiq had promised to deliver 10,000 homes on Transport for London land by 2020. Only 322 homes have been delivered since 2016, with this target revised to be by 2021. His failure to get London building has seen Sadiq even miss targets for starts on site, having achieved only 6,000 affordable homes when his target was 14,000. It is under the pressure of his own failings that we find him looking for quick wins, which is resulting in knee jerk reactions often appearing to be rash and unsubstantiated.
Other proposed changes he has made to the London Plan, namely around dual management of Build-to-Rent developments, have been concluded as detrimental to the sector. His recent calls for rent control, despite having no power in which to enable such policy, flies in the face of decades of research in the area. Now, his recent proposed draft changes is sinking the viability of the very schemes that could provide housing with care in the capital.
Perhaps the Mayor of London does not place in importance on the need for housing to be designed so people can age in place, or remain independent for longer.
Perhaps the Mayor of London is not interested in the potential savings to the NHS that can be brought about by such schemes. Particularly those that can provide a cost-effective and efficient delivery of healthcare in someones own home. Pressures on the NHS have never been higher and here we have developers seeking to provide a means of alleviation. But instead the Mayor continues to advocate duff policies that will have long term serious ramifications for adult social care and housing.
That said, adult social care does not appear to be anything the incumbent Conservative government see as a priority either. Having delayed its Green Paper on Social Care no less than six times. Despite this it has recently mooted that it will contain a focus on innovative new models of care that enable people to live more independently, which brings a glimmer of hope some common sense may prevail. The Communities and Local Government Committee concluded in early 2018 that a national strategy is needed to bring together and improve policy in this area. The recommendations could not have been more on point and included the following:
- The National Planning Policy Framework should be amended to emphasise the key importance of the provision of housing for older people and the new standard approach to assessing need should explicitly address the housing needs of older people.
- To facilitate the delivery of new homes, specialist housing should be designated as a sub-category of the C2 planning classification, or be assigned a new use class.
- Councils should publish a strategy explaining how they intend to meet the housing needs of older people in their area and, in their Local Plans, identify a target proportion of new housing to be developed for older people along with suitable, well-connected sites for it.
- All new homes should be built to the Category 2 Building Regulations standard so that they are ‘age proofed’ and can meet the current and future needs of older people.
- The Social Care Green paper should consider the range of housing for older people, in particular the potential for extra care housing to play a greater role in providing social care alongside home care and residential care.
Nearly a year and a half later our country is still devoid of a national strategy and the leader of its capital feels he can write his own rule book to deflect from his own shortcomings. The Mayor’s housing target of 50% is one that is devoid of any economic sense, particularly when we still cannot subsidise private sector developers who are not Registered Providers.
Lets hope when policy makers finally come round to devising the Social Care Green Paper and its National Strategy on Housing for Old People it does not take a leaf out of Sadiq’s book.
Unless they are writing an easily solvable murder mystery.