Housing targets and Extra Care Housing - Public forum - Planning Advisory Service (PAS)
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En cours - juillet 2012
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Dernière modification - Aujourd'hui
Housing targets and Extra Care Housing
Hi there, There has been considerable debate in recent years over the use class of extra care housing models. The consensus as to whether these developments fall within C2 and C3 appears to depend principally on the level of care provided, as much as any other factors. Equally these units with their own front door, Council Tax charge, self-contained facilities and presumably a not insignificant price tag, clearly become the main residence for their occupiers. The new developments often feature show apartments, are marketed as apartments and bungalows and as somewhere to move to, from your existing home. I would be interested to know whether LPAs are counting these units as contributing to LPA housing targets and where unimplemented, included in SHLAAs and 5 year land supplies. Given that they are likely to be an increasing source of housing supply for an ageing population - and the household projections on which housing targets clearly take account of demographic trends such as an ageing population - is there an argument that self-contained, extra care housing units should count towards housing targets and 5 year land supplies.
We are just looking at this ourselves. With the very significant increase in the elderly population predicted over the next 15-20 years, providing suitable housing accommodation for this age group will clearly be an issue. Our provisional idea is that if the apartments have their own front doors and kitchen facilities, then arguably they should be counted as dwelling units. If the cooking and eating arrangements are communal then they should not be counted. However, we are then thinking that even if they do not count against the delivery side of the 5 year land supply, the provision will, in practice, be reducing the requirement side i.e. a new care home providing 50 units will potentially be releasing 50 homes. Should we therefore be taking these completions into account by reducing the 5 year housing requirement accordingly.
We had been including Extra Care Housing if they had their own front door and facilities and in fact still monitor these dwellings. However, at 2 recent appeals it was agreed that these dwellings did not contribute to the housing completions or housing supply. So I think this is something that it would useful to have a national stance on, as I agree with the comment from David that Extra Care Homes still meet housing needs and therefore reduce the numbers of people/households looking for homes.
It would be really interesting if you would post the case numbers for these appeals for us all to read the inspector's view. Is the issue the definition of a dwelling used by your Core Stategy/RSS? Under the rules of the New Homes Bonus, these would count as new homes. The London Strategic Housing Land Availability Assessment and Housing Capacity Study which forms the basis of the evidence for the latest London housing targets takes into consideration standard housing sites, non self-contained units and vacant properties, though this has been set as a target for no. of net additional homes per year not dwellings.
The London Housing Capacity work clearly takes account of non-C3, non self-contained categories of development such as hostels. It is difficult to argue that an individual's primary residence, with their own front door, self-contained facilities, council tax and leasehold - freeing up other homes - should not count even if it is within one of these extra care developments. People who purchase apartments within these developments are probably less transient than a student in an HMO for a year or two.
Not directly related, but still of interest, I asked CLG whether Extra Care housing counts as net additions to the 'effective stock' for the purposes of the New Homes Bonus. I was told if they are included in the council tax calculations, then they will count for the New Homes Bonus. According to this from the council tax valuation office, I think they do. Council tax banding of multi-occupied properties e.g. houses converted to bedsits Council tax is a local tax to pay for local services. The basic principle is that each household should contribute towards the cost of local services according to the value of the property that they occupy. In general, living space occupied exclusively by a separate household within a larger multi-occupied property usually has its own council tax band. This is the case even where the residents share some facilities and the living space is not entirely self-contained. In some circumstances a property occupied by one household may be allocated more than one band because it has more than one self-contained unit e.g. a house with an annexe to accommodate an elderly relative will have its own council tax band separate from the main house. This is known as Disaggregation. In exceptional cases a single council tax band may be allocated to the whole property, rather than each of the individual living spaces. This is known as Aggregation. The treatment for council tax of houses in multiple occupation can be difficult to understand so we have set out the most common situations along with some examples to illustrate how the bands are allocated. Houses (or other buildings) split into flats or bedsits Student halls of residence , Hostels, Boarding accommodation Registered Care homes Houses (or other buildings) split into flats or bedsits In general, individual flats or bedsits will be allocated their own council tax band, even though some of the facilities and accommodation may be shared with other residents of the same building. A separate band means a separate council tax bill for the occupants. See ‘Paying the bill' Example: A converted house comprising four bedsits, each separately occupied and with washing and toilet facilities but sharing a kitchen, would normally have four separate council tax bands. Example: A large Victorian house where bathroom and kitchen facilities are shared between seven tenants occupying the bedrooms on a month-to-month license, with the only adaptation being individual locks on each bedroom door. The VOA is likely to exercise its discretion to apply one council tax band to the whole property. Example: A purpose-built block of ten one-room flats each with kitchenette and shower/WC on short term lets would have ten separate bands, as each flat is a self-contained unit. Student halls of residence; Hostels; Boarding accommodation in schools and barracks Property shared by a number of people living as one household, for instance students sharing a house, or a hostel where the residents live communally, will usually have one band . This includes hostels known as “foyers,” which offer support for young people who are homeless. However, in some cases where the property consists of more than one self-contained unit, then more than one council tax band will be allocated. Example: A hostel with a canteen and laundry room for all residents but with living accommodation arranged on three floors, each with bathroom/WC and kitchenette, would be assessed as three self-contained units (one per floor) so the hostel would have three separate council tax bands. Example: A student hall of residence providing bed-sit accommodation with shared bathroom and washing facilities, one refectory and no individual cooking facilities will have a single band as the property is classed as comprising only one self-contained unit. Registered Care homes Care homes for the elderly or disabled that are registered under Part 2 of the Cares Standards Act 2000 will have a single council tax band except for any self contained unit(s) occupied by the registered person responsible for running the care home. Other care homes, or units whose occupants receive certified domiciliary care only are dealt with under the same rules applied to hostels. Discretionary exception In very exceptional circumstances, a single council tax band may be allocated to a property occupied by more than one household. Having a single band is a discretionary decision of the Valuation Office Agency's Listing Officer depending on the following factors: The extent that the property has been altered to provide separate areas of living accommodation The greater the adaptation to make each part a self-contained living space, the less likely it is to have only one council tax band. The frequency of tenant turnover A regular turnover of short-term tenancies in a property that has not been adapted into separate units of living accommodation is likely to mean that a single band is allocated to the whole building. However if the building has been adapted to comprise individual self-contained units, then each unit will have its own band, regardless of the tenancy turnover.
Thanks Harriet. That's very helpful. I wonder whether qualifying for New Homes Bonus (the clues in the name) means that some of the extra care housing units - where the care is very limited (a few hours) - would justify reclassification from C2 to C3. The Use Classes Order often lags behind changes on the ground and I think t's something of an anomaly, in my opinion, that needs to be addressed in the UCO. I wonder what use classes a Kibbutz or a Commune would fall under?!