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CHURCHILL LIVING AND MCCARTHY & STONE RESPONSE TO THE GREATER NORWICH LOCAL PLAN SCOPING CONSULTATION
Churchill Living and McCarthy & Stone are national housebuilders specialising in the provision of housing for older people. Combined the companies provide broadly 90% if older persons housing for sale each year. Each company identifies and develops land for the development of much needed housing for older people across the UK. The companies are well placed to advise on policy matters and how such policy might impact aspirations to meet the housing needs of older people in the area.
Please find below our comments on the draft local plan insofar as they impact the delivery of specialist accommodation for older persons. These comments are intended to assist the council in formulating approaches which are both workable in practice and avoid stymying the delivery of a housing typology which the PPG describes as ‘critical’ in terms of addressing housing need.
Older Persons Housing Policy
The PPG on housing for older and disabled people identities at Paragraph: 001 Reference ID: 63-001-20190626 that the need to provide housing for older people is critical and that ‘an understanding of how the ageing population affects housing needs is something to be considered from the early stages of plan-making through to decision-taking’. Paragraph: 006 Reference ID: 63-006-20190626 then confirms that:
‘Plan-making authorities should set clear policies to address the housing needs of groups with particular needs such as older and disabled people. These policies can set out how the plan-making authority will consider proposals for the different types of housing that these groups are likely to require. They could also provide indicative figures or a range for the number of units of specialist housing for older people needed across the plan area throughout the plan period.’
Policies HO1 of the 2026 NPPF, in the context of establishing housing needs requires LPA’s to assess the size, type and tenure of housing for different groups which includes housing for older people and specifically includes retirement housing, housing-with-care and care homes. Policy H05 requires the development plan to set out policies to address the housing needs of different groups including older people. This includes identifying sites or parts of allocated sites which can provide a specific type of housing. It is likely that, given the ageing population that the council’s evidence base will indicate that policies must plan for the delivery of significant numbers of additional older person housing units over the next 20 years.
On this basis we note that the NPPF now under ‘national decision making policies’ contains a policy at HO9 that specifically addresses specialist forms of accommodation which includes ‘housing for older people’ and identifies that housing for older people should be ‘being located where residents will be able to access frequently-used services easily and safely by walking, wheeling (including mobility scooters) and public transport; including through on-site provision where applicable; and being delivered to M4(2) or M4(3) accessibility standards.’ We would therefore advocate that the Local Plan does not need to have a specific older persons housing policy that details the locational or accessibility requirements but instead the Local Plan should identify the older persons housing need and seek to allocate some sites to deliver such identified need.
Accessibility Standards
We also note that proposed national policy HO9 1aii states that specialist housing for older and disabled people should be ‘delivered to M4(2) or M4(3) standards. It is our view that the council should therefore not set a separate requirement for older persons housing to meet these standards and instead rely on the decision-making policy in the NPPF, namely policy H09. It is clear that the government are content for older persons housing to be delivered to either M4(2) or M4(3) but if the council feel that they should set M4(2) or M4(3) standards for older person housing specifically the council should note that the PPG on Housing for Older and disabled people identifies at Paragraph: 009 Reference ID: 63-009-20190626 that:
Where an identified need exists, plans are expected to make use of the optional technical housing standards (footnote 46 of the National Planning Policy Framework) to help bring forward an adequate supply of accessible housing. In doing so planning policies for housing can set out the proportion of new housing that will be delivered to the following standards……...…… Planning policies for accessible housing need to be based on evidence of need, viability and a consideration of site specific factors.
The Housing: Optional Technical Standards (‘HOTS’) reconfirm the position with respect to viability at Paragraph: 003 Reference ID: 56-003-20150327 that states ‘Local planning authorities should consider the impact of using these standards as part of their Local Plan viability assessment.’. Paragraph: 007 Reference ID: 56-007-20150327 of the HOTS then sets out the factors that Local Planning Authorities can consider when setting standards. This includes ‘the overall impact on viability’.
With respect to need it is common for local authorities to conflate the needs of ‘wheelchair users’ with the needs of older people in the community. McCarthy and Stone has recently undertaken a Wheelchair user survey of all its developments to understand the proportion of residents that use a wheelchair. This identified that only 2.7% of residents of occupied flats use a wheelchair in their apartment whilst 3.2% of residents use a wheelchair in communal areas. Churchill Living’s figures are similar. This is out of a total of 8,159 occupied apartments. This clearly identifies that there is probably just a very small need for older persons housing schemes to be built to accessible standards, much of which can be met via M4(2) and this should be further considered by the council and supports our view that policy H09 of the new NPPF should prevail and older persons housing should be built to M4(2) or M4(3).
With respect to viability building a Retirement Living apartment block to M4(3)(2)(a) standards requires significant modifications to a typical unit beyond a M4(2) unit that must be considered within any viability study. The most notable difference is that units built to M4(3)(2)(a) have to be bigger than units built to M4(2) to accommodate the same number of bedspaces. This is due to the need to provide enough wheelchair circulation space for clear access and turning areas around furniture, kitchens and sanitaryware as well as additional storage space. The minimum space requirements are detailed in Approved Document Part M. In addition, additional re-enforcement of walls etc needs to occur as part of the build to provide the strength for adaptations such as wall hoists. This adds additional build cost compared to an M2(2) unit.
Designing a scheme to M4(3)(2)(a) would therefore have a number of impacts on the scheme as follows that all affect viability and must be considered within any viability study.
• A significant reduction in units (and hence sales revenue)
• A substantial change in unit mix
• An increase in sales price for larger units, while some overall greater value may be secured for larger units, this is generally at a lower vale per sq. m and is unlikely to compensate for the overall loss of units across the proposal as a result of the requirement.
• An increase in service charges as the costs have to be shared amongst less apartments.
• The scheme would be at a lower density and not make such an efficient use of and therefore would directly conflict with policies L1 – L3 of the NPPF especially given the central location of the appeal site.
As an example, a typical 2-bedroom apartment of 72 sq m that can accommodate 3 persons (incorporating a double and a single bedroom), if laid out to meet M4(3)(2)(a) requirements would then just be able to accommodate 1 double bedroom (accommodating 2 persons).
The result would then be, given the reduction in units, that a M4(3)(2)(a) requirement would deem a scheme unviable with a less than efficient use of land. Given the level of likely need for older persons housing, the council should be careful not to prejudice delivery through the imposition of overly prescriptive and unnecessary criteria that is dealt with via the new NPPF.
Viability
We would remind the Council of the increased emphasis on Local Plan viability testing in Policies PM12 and DM5 of the NPPF. Policy DM5: Development viability highlights the importance of referring to the plan wide viability study which informed the relevant development plan policies. The emphasises the importance of ensuring that proper engagement has taken place at the plan making stage to ensure plan wide viability testing is reflective of the particular housing typology in question.
Stakeholders must be afforded the opportunity to engage and inform the plan wide viability testing process. Plan wide viability testing should be undertaken as early as possible in the formation of the plan.
The council should note that the PPG on Viability confirms at para 002 Reference ID: 10-002-20251216 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………..Policy requirements, particularly for affordable housing, should be set at a level that takes account of affordable housing and infrastructure needs and allows for the planned types of sites and development to be deliverable, without the need for further viability assessment at the decision making stage’.
Paragraph 004 Reference ID: 10-004-2019509 of PPG confirms what is meant by a typology approach to viability and advises that;
Plan makers may wish to consider different potential policy requirements and assess the viability impacts of these. Plan makers can then come to a view on what might be an appropriate benchmark land value and policy requirement for each typology.
We would like to highlight to the council that the viability of specialist housing for older people is more finely balanced than ‘general needs’ housing and we are strongly of the view that these housing typologies should be robustly assessed for viability and affordable housing separately to mainstream housing.
This would accord with the typology approach detailed in Paragraph: 004 (Reference ID: 10-004-20190509) of the PPG 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 specialist housing for older people may be significantly delayed with protracted discussion about other policy areas such as affordable housing policy requirements which are wholly inappropriate when considering such housing need. The worst-case scenario is the introduction of a policy which completely stymies the delivery of this typology.
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 2016 (‘RHG Briefing Note’) available from. https://retirementhousinggroup.com/wp-content/uploads/2025/08/CIL-viabiilty-appraisal-issues-RHG-February-2016.pdf
The RHG Briefing Note establishes how sheltered housing and extra care development differ 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 and significantly variable benchmark land values.
The following should be noted within viability testing:
Unit numbers / GIA / Density
A typical sheltered housing / retirement living scheme would consist of 45 dwellings on a gross site area of 0.45 hectares creating a density of 100 units per hectare. Extra care housing tends to have a lower density (due to more non saleable area) and a typical scheme would consist of 60 units on a 0.75-hectare site at a lower density of 80 units per hectare.
As discussed earlier, the unit numbers will be much less if M4(3) units would be required.
Unit Size
Typical units sizes are larger than minimum space standards to allow for additional storage and circulation space to facilitate downsizing:
• 1 bed sheltered 55 sq. m and 2 bed sheltered 75 sq. m
• 1 bed extra care 60 sq. m and 2 bed extra care 80 sq. m
As discussed earlier, these unit sizes will be much larger for M4(3) units.
Unit mix
A typical scheme provides 1 and 2 bedroomed apartments using a mix of 60% 1 bed and 40 % 2 bed units on a development. This is the case for both sheltered (retirement) and extra care (retirement living plus) schemes.
Build Cost
The BCIS median rate rebased to the location is appropriate is it represents the cost of a typical of developing the typology in that area.
Non-chargeable / communal space
Older persons’ housing has a larger communal and non-saleable areas such as residents lounge, laundries, guest rooms, managers office and wellness rooms. Extra care housing also includes additional facilities such as a restaurant area. For sheltered schemes the non-chargeable space used should be at least 25% and for extra care schemes this should be 35% of GIA.
Where M4(3) units are included, communal space will also be larger.
Professional fees
Given that most specialist housing for older people developments are delivered on brownfield sites, in our experience these often involve more professional advisors associated with contamination, legal fees, drainage, air quality, overheating, sunlight, ecology and noise amongst other areas. We would therefore recommend that a 10% of build cost figure is used for brownfield sites for professional.
Sales and marketing costs
As detailed within the RHG Briefing Note sales and marketing costs for older persons housing schemes are typically 6% of GDV and this should be used within the older persons modelling rather than the 3% level for general housing.
Sales periods
As discussed in the RHG Briefing Note, sales periods of older persons’ housing schemes are typically longer for retirement and extra care housing than general needs housing. There is a typical 18 month build period before sales can commence. Sheltered and Extra care schemes cannot be phased but must be fully operational and completed from month 1 of sales / occupation. As detailed within the RHG Briefing Note, once sales commence a rough guide is that 40% of units will be sold at the end of the first year of sales, 30% during the second year of sales and 30% during the third period.
At present, sales rates overall are typically at 0.5-0.6 sales per month and so consideration should be given to extending sales periods in testing given this downward trend in sales rates over many years.
Empty property costs
It is recommended that a standard allowance of £7,000 per unit is assumed as a typical average empty property cost – to cover Council Tax liability on unsold units and service charges (which will be applicable to the whole building from day first resident moves in). This increases to £10,000 for extra care accommodation to reflect higher costs particularly in maintaining care, communal and catering facilities, staff and services and reflecting a slower sales rate than Retirement Living. These costs might in reality be higher due to empty property premiums on council tax now in force for property empty longer than 12 months.
External build costs
From our experience external build costs tend to range from 8% to 15% of base build costs on flatted schemes within urban areas and we therefore feel that an allowance is 10% of base build cost should be used for external build costs for brownfield sites.
Developer Return
PPG sets out that ‘For the purpose of plan making, an assumption of 15-20% of gross development value (GDV) may be considered a suitable return to developers. However, for specialist housing for older people there is a clear precedent for a return of not less than 20% of gross development value primarily because of the risks associated with such developments. This is consistent with the Inspector’s conclusions for appeals such as McCarthy Stone proposal at Redditch (Appeal Ref: 3166677), Churchill Living proposal at Cheam (Appeal Ref: 3159137) and the Churchill Living scheme at West Bridgford (Appeal Ref: 3229412) in 2019. A minimum of 20% profit should therefore be assumed for specialist housing for older people.
Policy costs –Biodiversity Net Gain
Any local plan BNG should be applied in line with Policy N1 of the NPPF.
Since the price of statutory BNG units have been published it is able to determine how much BNG may cost and this needs to be incorporated into the viability assessment at a realistic level. In addition, brownfield site BNG costs are often more substantial than Greenfield, but this very much depends on the site characteristics.
For example, if an older person’s housing scheme consisting of 50 units on a 0.5-hectare site needed to purchase 1 off-site statutory credit, if this was for the cheapest low-quality habitat type this would cost £84,000 or £1,680 per unit given that 2 credits are needed per unit. Older persons housing schemes are ideally located on small windfall sites close to local facilities and it will most likely be that BNG requirements will need to be met largely or entirely off site by contribution.
Any other accessibility and environmental policy requirements must also be costed appropriately as discussed earlier in this response. This includes the forthcoming changes to the Future Homes Standard which will not be included in BCIS base build costs.
Finally, the Building Safety Levy must also be considered. The levy will be applied from October 2026 and is an additional cost to this typology.
Policy PM13: Setting Standards of the NPPF requires that local plan policies should not cover matters that are already addressed by Building Regulations only in a narrow range of circumstances and must not have an adverse impact on the viability and deliverability of development.
Generic Application of Affordable Housing Policy
Our experience is that older person’s housing proposals will not viably provide affordable housing on a typical development site given that firstly, unit numbers will not generate sufficient affordable housing for a registered provider to have any interest in acquiring units.
Secondly, typical sites are too constrained to accommodate mixed management arrangements and thirdly, viability has consistently demonstrated that it is not financially feasible to provide affordable housing at levels deemed ‘policy compliant’ in the local plan.
We recommend that viability testing is undertaken within the plan wide viability study for older persons housing typologies and that a specific affordable housing policy is drafted based upon the findings. The testing must examine the type of sites where this housing will realistically be delivered. Alternatively, a specific brownfield policy should be applied whereby older persons housing has a lower or NIL affordable housing requirement on brownfield land.
By way of example of good practice, we note that BCP Council’s now withdrawn local plan proposed an exemption in respect of older person’s housing following the findings of the plan wide viability study. We have seen similar policies emerging in Birmingham, Charnwood (now adopted), Fareham (adopted), Hyndburn, Teignbridge, Dudley and Great Yarmouth. This is the correct approach in line with the requirements of national policy.
We consider based upon our experience that a reduced affordable housing target is likely to be appropriate for specialist housing for older people. It is inappropriate in our experience to apply generic affordable housing policy to this typology.
Finally, we would recommend that where viable, local plan wide viability studies should also test formula in respect of affordable housing commuted sums as such requirements must be tested as part of the examination of a local plan and not introduced within supplementary planning guidance.
Recommendation
The provision older persons housing developments will require a supportive policy environment which avoids overloading the sector with unviable and unnecessary requirements. We would make the following general recommendations from our own experience.
• This policy area should identify the large older persons housing need, and this might include allocating sites specifically for older persons housing but also acknowledging that the typology is different from mainstream housing and must be determined more flexibly with this in mind.
• The application for adaptable and accessible standards must not be so rigid that they deem schemes unviable. If a target is set this must be based on need. The council should rely on policy H09 of the new NPPF in respect to older persons housing.
• The application of affordable housing policy should not be generally applied and should recognise that the viability of older persons housing will differ from mainstream housing.
• The plan should not have a separate older person’s housing policy area and instead the council should rely on policy H09 of the new NPPF
• The policy must be clear that generic housing policies such as in respect of housing mix, will be applied flexibly in respect of older persons housing and in line with identified housing needs.
Conclusions
Thank you for the opportunity for comment on the emerging plan. We would be grateful if you would add our details to the circulation list for further opportunities to engage on emerging policy.
