NPF4 call for ideas: analysis of responses

Independent analysis of responses to the call for ideas to inform the preparation of a new National Planning Framework (NPF), launched in January 2020.


Housing - Specialist

Key objective of NPF4: To improve the policy so that the housing needs of older and disabled people are better accounted for in the planning system.

Many of the comments at this theme were relatively brief and focused on agreeing that NPF4 and SPP considers the needs and aspirations of an older population and disabled people.

Further comments included that existing policy is fit for purpose in that it meets legislative requirements in committing to meeting the housing needs of older people and disabled people and the inclusion of these in LDPs. However, it was suggested current planning policy on accessible and adapted housing, wheelchair housing and supported accommodation is not proportionate to the likely future scale of the requirement.

Some respondents commented on the types of homes and/or facilities that are likely to be required including:

  • Bespoke housing, such as bungalows.
  • Contemporary single storey solutions and small gardens for the increasing numbers of wheelchair users and their families who are not ready to live in flatted development.

It was reported that an accessible and inclusive environment is likely to sustain health, prevent isolation and promote participation and that there is an opportunity for planning to promote building design standards and environmental design standards such as street design which prioritise accessibility, inclusion and integration for all residents. It was also suggested that many of the issues identified in ancillary strategies such as housing for older people, and tackling loneliness and social isolation, will be addressed through application of the place-making approach.

In terms of aspects of the local environment that can be important, suggestions included:

  • Avoiding shared spaces.
  • Making the community dementia friendly.
  • Providing pavements with dropped kerbs at crossing points and controlled pedestrian crossings where appropriate.

Role of planning policy in meeting need

It was suggested that, given the new legislative requirements, existing policies would not provide sufficient guidance on how to address more specific targeted needs. It was suggested, for example, that it is unclear whether the expectation is that the general housing land supply would be the main area for delivery of particular needs and whether, if this is the case, it is the expectation that the desired outcomes would be achieved through design standards and on a particular scale.

It was noted that the current approach has been to not intervene in house types provided by builders for the private market. However, it was also suggested that some local approaches are emerging which are difficult to satisfy on a typical new build development, and that home builders already play a significant role in the provision of highly accessible homes for a wide range of users.

One perspective was that new planning policy should not be prescriptive in relation to specialist housing provision but should recognise that the latter stages of the HNDA and the LHS process will draw out local needs. It was also noted that Building Standards already require houses to be built to be adaptable and it was argued that NPF4 should not replicate provisions made through other legislation. Rather, it was suggested that as a minimum it should reinforce the need to comply with the 'basic' requirement for wheelchair users, as outlined in Housing for Varying Needs, and Lifetime Homes Standards.

With specific reference to wheelchair housing, it was suggested that the planning system may not be the best mechanism to address the requirement for wheelchair accessible housing across all tenures. Further, without buy in from the private sector an annual all tenure target will not lead to a change in all tenure supply of such housing types and could put additional pressure on the affordable housing sector to deliver wheelchair accessible housing. It was also reported that requirements for more single storey homes to meet wheelchair targets have the potential to impact on the viability of sites and to squeeze the land area available for affordable housing.

An alternative view was that NPF4 must require all new houses to be suitable for occupation by anyone who is mobility-impaired or who needs a hospital-style bed with a hoist to assist getting in and out of bed. It was suggested that these and other relevant requirements might best be implemented through the Building Control function and could make it possible for someone who has lived in their house for many years to continue to live there if they become less mobile or less well. There was a call for NPF4 to include a commitment that Building Standards will be reviewed to ensure that all new dwellings really are suitable for life-time occupation.

However, there was also a suggestion that a policy at national level, similar to that for affordable housing, requiring a minimum percentage of the market units to be specialist housing or housing which is capable of adaption would be helpful. It was proposed that, as for affordable housing, requirements could be varied downward where appropriate. It was also proposed that there should be a requirement to supply the specialist housing provision as set out in the LHS and that this must involve powers to require private developers to build for specialist needs.

To effect real change, it was suggested that planning authorities need more certainty to give them the confidence to allocate sites specifically for specialist housing and to require construction of new accessible/adapted/wheelchair housing, particularly in new build private sector housing.

There was also a call for clarity about how and when the affordable housing policy is applied to specialist housing. The local authority respondent raising this issue considered it will be ever more important to be able to apply affordable housing policy to specialist housing. However, they did suggest that it may not be appropriate to apply the policy to all types of specialist housing such as Care Homes.

Other ideas for tackling some of the barriers to the provision of more specialist housing included that:

  • Wider/general housing policy requirements can support delivery of this policy objective by working with all relevant stakeholders including RSLs, Health and Social care colleagues and the third sector with a view to improving data on the need and demand for appropriate, accessible and adaptable housing.
  • If it were to become a planning issue, NPF4 should define what is meant by accessible homes and establish a workable approach to delivering it through the planning system. If targets are set, consideration should be given to how they can be monitored and implemented given the restricted resources of local authorities.
  • Allocation of specific sites might assist in suppressing the land value which can be a hindrance to development of what tends to be relatively low-density housing.
  • New build housing should be required to be built to wheelchair accessible housing to varying needs standards, including the ability to adapt properties to future requirements.
  • Building Standards should be aligned across tenures to minimise the difference between affordable and open market properties, for example to assist and enable the delivery of wheelchair accessible properties. It was suggested that this approach would help strengthen policy, encourage a wider range and diversity (type and size) of properties across tenures.
  • The re-establishment of a national housing agency would provide greater efficiency and co-ordination, together with improved methods for assessing housing need and demand for specific forms of specialist housing.
  • Gathering robust evidence in terms of private sector wheelchair housing needs.

Other suggestions relating to what planning policy, and NPF4 specifically, should do included considering ways to:

  • Proactively respond to the aging population, not just focusing on people's needs now but how they plan and prepare for older age.
  • Ensure flexibility and adaptability in all types of new-build housing, reflecting that many people as they get older, or as their mobility needs change, want to remain in the house they already live in, possibly by making the Housing for Varying Needs Standards mandatory.
  • Investigate the role that technology can play in enabling independent living and to what extent this may or may not be relevant to planning's role in meeting housing need.
  • Encourage the development of varying types of specialist housing, and smaller properties that would appeal to older people even if not marketed or restricted as such, for those older people who do wish to move home.
  • Prioritise the importance of location and access to local services and avoid larger-scale older peoples housing developments designed to function as self-contained communities and/ or with poor access to public transport.
  • Introduce a requirement to provide bespoke housing for the elderly (bungalows) to meet the demands of an aging population.

Finally, respondents identified other groups who may require specialist housing responses. These included:

  • Children in poverty, given that a major contributing factor to poverty is cost of housing.
  • Women affected by domestic abuse and requiring refuge accommodation.
  • Some Black, Asian and Minority Ethnic communities who are more likely to live in overcrowded housing.
  • New families to live and work in island or remote communities. In particular, it was suggested that non-linked islands face a number of housing issues including a lack of suitable and available vacant houses, no or limited tradespersons to build/adapt properties at an affordable cost, or a high proportion of vacant/ruined houses.
  • Households that are in fuel poverty. It was noted that in some areas this group will include elderly people living in older houses with inefficient and costly oil-based heating systems.

Contact

Email: scotplan@gov.scot

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