<<

Doncaster Local Plan

Housing Design Standards Policy

Local Plan Evidence Base

June 2019

Table of Contents

List of Figures ...... Executive Summary ...... 1.0 Introduction ...... 1 2.0 Accessible and Adaptable Dwellings ...... 2 2.1 Introduction to the Standards ...... 2 2.5 National Policy and Context ...... 2 2.17 Current Local Planning Policy and Council Strategies ...... 5 2.29 Evidence Required ...... 8 2.37 Evidence ...... 10 2.38 The Likely Future Need for Housing for Older and Disabled People ...... 10 Older People...... 10 Long-Term Health Problem or Disability ...... 17 Wheelchair Dwellings ...... 21 Summary ...... 24 2.89 Size, Location, Type and Quality of Dwellings Needed to Meet Specifically Evidenced Needs ...... 26 Size ...... 28 Location ...... 31 Type ...... 39 Quality...... 42 Summary ...... 43 2.141 The Accessibility and Adaptability of Existing Housing Stock ...... 45 Summary ...... 50 2.160 How Needs vary across Different Housing Tenures ...... 51 Summary ...... 57 2.179 The Overall Impact on Viability ...... 58 Viability Testing ...... 58 Falls ...... 62 Delayed Transfers of Care ...... 64 Residential Care Costs ...... 65 Adaptations ...... 66 Summary ...... 67 2.209 The Case for Introducing the Accessibility Standards ...... 69 2.211 Category M4(2) Accessible and Adaptable Dwellings ...... 69 2.218 Category M4(3) Wheelchair Adaptable Dwellings ...... 71 3.0 Nationally Described Space Standards ...... 73 3.1 Introduction to the Standards ...... 73 3.7 Current Local Planning Policy ...... 75 3.10 Evidence Required ...... 76 3.11 Evidence ...... 77 3.12 Need ...... 77 Survey ...... 77 Density ...... 80 Ventilation and Climate Change ...... 82 Occupancy of Dwellings ...... 84 Storage ...... 85 Overcrowding ...... 86 Education ...... 86 Health and Well-being ...... 87 Houses in Multiple Occupation ...... 87 Accessible and Adaptable Dwellings...... 88 Summary ...... 89 3.54 Viability ...... 91 Viability Testing ...... 91 Affordability ...... 93 Summary ...... 96 3.72 Timing ...... 97 3.76 The Case for Introducing the Standards ...... 98 4.0 Appendixes ...... 100 Appendix 1 – Statistical data used to produce map data ...... 100 Appendix 2 – Map of the high, medium and low value viability areas in ...... 104 Appendix 3 – NDSS Survey Sample...... 105

List of Figures

Figure 1: M4(2) pictorial example ...... 9 Figure 2: Doncaster’s Older Population in 2011 ...... 10 Figure 3: Doncaster’s Older Population in 2017 ...... 10 Figure 4: Doncaster’s Population Projection ...... 11 Figure 5: Projected Population Age Breakdown by Total Percentage ...... 11 Figure 6: Percentage Breakdown of the 65 and Over ...... 12 Figure 7: OADR comparison by regions ...... 12 Figure 8: Internal Migration Figures ...... 13 Figure 9: Doncaster Household Projections ...... 13 Figure 10: Tenure of 65 and above households ...... 14 Figure 11: Projection of Older People Living Alone or in Care in Doncaster ...... 15 Figure 12: Healthy life expectancy in Doncaster at birth and at age 65, by sex, 2015 to 2017 ...... 16 Figure 13: Projected Characteristics of Older People in Doncaster ...... 17 Figure 14: Current Population of People with a LTHPD by Age Category ...... 18 Figure 15: Breakdown of the Population of Doncaster with a LTHPD...... 18 Figure 16: Projection of People with a LTHPD in Doncaster ...... 19 Figure 17: Age Breakdown of Figure 16 ...... 20 Figure 18: Households and LTHPD’s ...... 20 Figure 19: Projection of Households with a LTHPD in Doncaster ...... 21 Figure 20: Unmet Housing Need Estimation Table...... 22 Figure 21: DLA Claimants in Receipt of Higher Mobility rate Award by Age ...... 24 Figure 22: Older Persons’ Housing Option Preferences ...... 26 Figure 23: Households that required an adaptation wanting different accommodation, by age and tenure, 2014-15 ...... 27 Figure 24: Future Need for Specialist Older Person Accommodation ...... 28 Figure 25: Household Composition of AHR Applicants ...... 29 Figure 26: Property Size Requirements of AHR Applicants ...... 29 Figure 27: Older Persons’ Housing Choices...... 30 Figure 28: Future Housing Choices of Older Households ...... 31 Figure 29: Distribution of 65 and over by numbers per ward ...... 32 Figure 30: Distribution of 65 and over by percentage of population per ward ...... 33 Figure 31: Distribution of people with a LTHPD by numbers per ward ...... 34 Figure 32: Distribution of people with a LTHPD by percentage of population per ward ...... 34 Figure 33: Health Deprivation and Disability Rank by LSOA ...... 36 Figure 34: Quality of Housing Rank by LSOA ...... 37 Figure 35: Location Preferences of AHR Applicants ...... 37 Figure 36: Location of Council Housing Adapted Properties ...... 38 Figure 37: Older Persons’ Housing Type ...... 39 Figure 38: Type Preferences of AHR Applicants ...... 40 Figure 39: Neighbourhood Team Areas ...... 41 Figure 40: Location, Size and Type of RSL stock ...... 42 Figure 41: Property Requirements of AHR Applicants ...... 43 Figure 42: Visitability of Sample Stock in England ...... 45 Figure 43: Age of Housing Stock in Doncaster ...... 46 Figure 44: Number and Type of Adaptations delivered between 2016/18 ...... 47 Figure 45: Housing Adaptations Required in Doncaster ...... 48 Figure 46: Future Need for Adapted Properties...... 49 Figure 47: Property Tenure by Ward ...... 51 Figure 48: Distribution of people aged 65 and over living in Private Accommodation, by percentage of population per ward ...... 52 Figure 49: Tenure of Individuals with a LTHPD ...... 54 Figure 50: Distribution of people with a LTHPD living in Private Accommodation, by percentage of population per ward ...... 54 Figure 51: New Build Dwellings Completed by Tenure in Doncaster ...... 55 Figure 52: Households that need to move on medical/welfare grounds ...... 56 Figure 53: Cost Impact of Accessibility Standards ...... 59 Figure 54: M4(1) and M4(2) Internal and External Differences ...... 61 Figure 55: Emergency Hospital Admissions due to Falls in People Aged 65 and Over in Doncaster ...... 63 Figure 56: Cost associated with falls in Doncaster by age, for the 12 months ending 31st August 2018 ...... 63 Figure 57: Reasons for DTOC in Doncaster ...... 65 Figure 58: Residential Care Costs 2017/18 ...... 66 Figure 59: Private and Social Housing Adaptations conducted for Individuals being Discharged from Hospital 2016/18 ...... 67 Figure 60: Minimum Gross Internal Floor Areas and Storage (m2) ...... 75 Figure 61: South Yorkshire Internal Space Standards ...... 76 Figure 62: Annual Mean Change Projections in Air Temperature in Doncaster ...... 83 Figure 63: Bedroom Occupancy Rating ...... 85 Figure 64: Average Attainment 8 Scores over the last Three Academic Years ...... 87 Figure 65: Cost Impact of Nationally Described Space Standards ...... 91 Figure 66: Design Team Costs per Development Size ...... 93 Figure 67: Median House Prices 2017 by Ward ...... 95 Figure 68: Dwelling Size Scenario ...... 96

Executive Summary

The National Planning Policy Framework indicates that planning authorities should deliver a sufficient supply of homes and that the need for different groups in the community should be assessed and reflected in planning policies. This Housing Design Standards Policy Evidence Paper was produced to demonstrate the requirement in Doncaster for the Government’s new national housing standards. It sets out evidence, highlighting the need for the optional standards around access requirements M4(2) and M4(3) and the Nationally Described Space Standards.

Doncaster’s population demographic will shift to accommodate a significant increase in older and disabled people during the plan period. As a result more households will include somebody with one of these characteristics, creating an increase in health and mobility issues. There will be an increased need for wheelchair dwellings in the borough over the plan period.

Older and disabled people will generally be spread across the borough with hotspots experienced in certain wards. There is a strong link between deprivation and the location of these demographics. Many older and disabled people want smaller, better-designed dwellings with little to no steps and a preference for bungalows.

Whilst specialist forms of accommodation will play an important role in meeting demand, most older and disabled people live and want to continue living in private market housing. Even if they wanted to move to a social adapted property, these are located in wards with a small percentage of older and disabled people. Current stock in Doncaster is ill equipped to deal with the changing population and the emergence of demand it will bring.

The introduction of the policy will have no significant impact on the viability of schemes, and will help promote significant social monetary cost savings.

The majority of current new builds in Doncaster are big enough to meet the Nationally Described Space Standards, but lack the internal design requirements to allow compliancy around storage space and bedroom sizes.

The introduction of the standard would help tackle key societal issues within Doncaster such as density, ventilation, under-occupancy and overcrowding. There is also a strong link between the standards and accessibility of houses. The introduction of the policy will have no significant impact on the viability of schemes, and will also produce little to no impact on the affordability of houses in Doncaster.

Overall the paper demonstrates a clear need for the inclusion of these housing standards in Doncaster. They are a necessary and appropriate mechanism to provide all current and potential residents of Doncaster access to good quality and appropriate housing in the private market, without a significant impact to developers.

1.0 Introduction

1.1 On 25th March 2015 the Government set out, in a written Ministerial Statement, information on the new optional housing technical standards in England. This was introduced to ensure new homes were high quality, accessible and sustainable. In doing so, the new system comprised of a new additional optional Building Regulations on water and access, and a new national space standard (NDSS).

1.2 These requirements are optional, and from 1st October 2015, local authorities had the option of implementing these higher standards. In order to apply the optional standards, the online National Planning Practice Guidance (NPPG) states that a local authority must gather evidence to determine the need for the additional standards in their area. The guidance on the optional technical standards is supported by NPPG on housing for older and disabled people.

1.3 The revised National Planning Policy Framework 2019 (NPPF) sets out the Government’s approach to achieving well-designed places. The NPPF acknowledges that “the creation of high quality buildings and places is fundamental to what the planning and development process should achieve”.1 To assist in this aim planning policies and decisions should ensure that developments: “create places that are safe, inclusive and accessible and which promote health and well-being, with a high standard of amenity for existing and future users”.2 To achieve this, within the footnote attached for paragraph 127, the NPPF sets out that “planning policies for housing should make use of the Government’s optional technical standards for accessible and adaptable housing, where this would address an identified need for such properties. Policies may also make use of the national described space standards, where the need for an internal space standard can be justified”.3

1.4 This background paper seeks to set out the context and evidence base used to inform the Housing Design Standards Policy (Policy 46) in the emerging Doncaster Local Plan. The policy adopts two of the new optional standards, access and the NDSS. It provides the necessary evidence required to satisfy the inclusion of the policy, as set out by the NPPG to ensure the policy is complaint and sound with national policy.

1 National Planning Policy Framework 2019, para 124. 2 ibid 127(f). 3 ibid footnote 46. 1 | P a g e

2.0 Accessible and Adaptable Dwellings

2.1 Introduction to the Standards

2.1 Part M Volume 1 of the Building Regulations sets out the regulations for the access to and use of dwellings. This is split into three categories:  M4(1) Visitable dwellings (mandatory standard);  M4(2) Accessible and adaptable dwellings (optional standard);  M4(3) Wheelchair user dwellings (optional standard), which includes: o Wheelchair adaptable; o Wheelchair accessible.

2.2 Category M4(1) regulation is mandatory for all new dwellings, as such only the M4(2) and M4(3) standards are relevant for consideration within this paper. The two categories are summarised below:4

2.3 Category M4(2) Accessible and Adaptable Dwellings requires that dwellings meet the needs of occupants with differing needs, including some older and disabled people, and to allow adaptation of the dwelling to meet the changing needs of occupants over time. This category is broadly equivalent to the Lifetimes Homes standard, which this optional regulation replaces.

2.4 Category M4(3) Wheelchair User Dwellings requires dwellings to meet the needs of occupants who use wheelchairs or to allow simple adaptation to meet the needs of occupants who use wheelchairs. This category can therefore be divided into wheelchair adaptable and wheelchair accessible dwellings. The requirement for wheelchair accessible dwellings should only be applied to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling.

2.5 National Policy and Context

2.5 As alluded to in the description of M4(2) requirements, accessible and adaptable housing helps meet the needs of numerous individuals, but most notably the older and disabled demographics. During the Conservative and Liberal Democrat coalition Government, housing for older and vulnerable people became a prominent policy priority. This led to the Laying the Foundations: A Housing Strategy for England Paper, which emphasised the need for local plans to consider the needs of different groups, including older

4 The detailed requirements and frequently asked questions can be found at: https://www.gov.uk/government/publications/access-to-and-use-of-buildings-approved-document-m 2 | P a g e

and disabled people.5 This strategy was subsequently fed into the statutory guidance building regulations applicable to the optional standards examined here.

2.6 More recently, in 2017 the Conservative Government released their ‘Fixing our broken housing market’ housing white paper. This again reiterated the current national position on improving the housing options and meeting the housing needs of older and disabled people.6 The paper states, “offering older people a better choice of accommodation can help them to live independently for longer and help reduce the costs to the social care and health systems. […] Expectation that all planning authorities should set policies using the Optional Building Regulations to bring forward an adequate supply of accessible housing to meet local need”.7

2.7 The recent update to the NPPF in 2019 confirms the requirement for local authorities to make use of the optional technical standards within the construction of planning policies. It also requires local authorities to assess and reflect the housing needed for different groups in the community, including older people and people with disabilities.8 It can therefore be argued that the current national government’s position is to ensure that at a local government level, strong consideration is made to helping older and disabled people live in appropriate housing to improve standards and ensure they can live independently if desired.9

2.8 Parliamentary committees have also considered the current issues regarding accessible and adaptable dwellings and the needs of older and disabled people. The Housing Communities and Local Government Committee conducted an inquiry into Housing for Older People. The Committee is made up on Conservative and Labour backbenchers. The Women and Equalities Committee conducted an inquiry into Disability and the Built Environment. This inquiry has finished and subsequently a report was published. As part of the inquiry, relevant charities and organisations contributed to different stages.

2.9 Within the final report on the Disability and Built Environment inquiry, the optional technical standards were assessed. This confirmed that M4(2) replaced the previous Lifetime Homes standard, and that M4(3) replaced the previous Wheelchair housing design guide.10 The Committee reported that, “wherever people live or choose to live in the future, there should be a real choice in the housing available to them”.11 The Committee also argued that the default minimum baseline standard for all new homes under Part M should be set to Category M4(2) from M4(1).12 This was supported by numerous organisations, such as: Age UK; Habinteg; Later Life Ambitions; and the Thomas Pocklington Trust.

5 MHCLG, Laying the Foundations: A Housing Strategy for England, pg 16. 6 MHCLG, Fixing our Broken Housing Market, pg 63. 7 ibid. 8 NPPF (n 1) para 61. 9 ibid footnote 46. 10 Women and Equalities Committee, 9th Report – Building for Equality: Design and Built Environment HC 631, para 95. 11 ibid para 110. 12 ibid para 122. 3 | P a g e

2.10 The inquiry into Housing for Older People presented their 2nd report in February 2018. Accessible homes were examined as part of the different types of available housing. Evidence presented by organisations, in particular Habinteg, argued that the current minimum M4(1) standard was “not sufficiently accessible for most older and disabled people and it is only ‘visitable’ in the loosest sense”.13 The higher M4(2) category was evaluated by Julia Park, Head of Housing Policy at Levitt Bernstein who stated: “The principal benefits would be practical. All of those little moves added together mean that day-to-day life would be very much easier”.14 The Committee acknowledged they had experienced this ease in day-to-day life themselves in a site visit to recently built Lifetime Homes standard dwellings. The Committee also acknowledged the ‘futureproof’ nature of the optional standards, especially in comparison to current mainstream homes.15 On building homes to M4(2) and M4(3), Claudia Wood from the think-tank Demos stated “it is one of the puzzles: why is everyone not doing it? It is basic common sense for long-term liveability of homes”.16 In summary, the Committee, in similar vain to the Women and Equalities Committee, stated that M4(2) should be the minimum baseline standard for all new homes.17

2.11 The benefits of M4(2) and M4(3) building regulations in addressing accessibility issues has also been commented on collectively by non-government organisations (NGOs). In an open letter published in the Guardian, NGOs demanded “more action […] to ensure new homes are inclusively designed with effective planning for the current and future housing needs. Inclusive homes benefit everyone, from older people, to people with mobility problems as well as families with young children”.18

2.12 The Equality and Human Rights Commission (EHRC), a statutory non-departmental public body, have also focused on the housing needs of specific groups with housing and disabled people being one of their most recent projects. The work presented the current state of housing for disabled people across the country and provides a damning reflection of the current market being ill equipped for this demographic. This is also reflected in various news reports, most notably articles published by The Guardian newspaper.19 The EHRC published a report on the current situation of disabled people housing which found that: the current housing system is demoralising and frustrating; there is a significant shortage of accessible homes; and disabled people are not getting the support they need to live independently.20 They concluded that without an increased supply of accessible and adaptable housing, disabled people would continue to face discrimination and disadvantage in the housing market.21

13 Communities and Local Government Committee, 2nd Report – Housing for Older People HC 370, para 76. 14 ibid para 77. 15 ibid para 78. 16 ibid para 81. 17 ibid. 18 The Guardian, Britain needs more accessible housing, https://www.theguardian.com/society/2017/sep/10/britain-needs-more-accessible-housing accessed 04/12/2018. 19 For example, see The Guardian, ‘I never feel safe’: meet the people at the very sharpest end of the housing crisis – disabled millennials, https://www.theguardian.com/society/2018/aug/21/disabled-accessible-housing- shortage-young-millennials accessed 11/12/2018. 20 EHRC, Housing and Disabled People: Britain’s Hidden Crisis. 21 ibid pg 20. 4 | P a g e

2.13 As well as through national policy, international human rights provisions also provide a backdrop to housing standards. The International Covenant on Economic, Social and Cultural Rights, which the UK is a party to, established the right of everyone to an adequate standard of living (ICESR Article 11). General Comment No. 6 addressed the interpretation of this Article in relation to older persons. It stated, “housing for the elderly must be viewed as more than mere shelter and that, in addition to the physical, it has psychological and social significance. National policies should help elderly persons to continue to live in their own homes for as long as possible”.22 This support to help elderly persons to live independently includes the contribution of accessible and adaptable homes.

2.14 People with disabilities also have the right to adequate standard of living enshrined within Article 28 of the Convention on the Rights of Persons with Disabilities. Article 19 of the same Convention also enshrines the right of persons with disabilities to “have the opportunity to choose their place of residence and where and with whom they live on an equal basis with others and are not obliged to live in a particular living arrangement”. This Convention has also been ratified by the UK. It is therefore essential that the housing market provides genuine choice for all citizens.

2.15 The Council is also bound by its duties under the Equality Act 2010 to ensure non- discrimination, promote the advancement of equality and to remove or minimise the disadvantages suffered by people due to their protected characteristics of which includes age and disability.

2.16 In June 2019, the outgoing Prime Minster, The Rt Hon Theresa May MP announced a new drive to tackle barriers faced by disabled people. Within this included the recognition that too many disabled people lived in unsuitable homes. In response, the Government at the time of writing, announced it will consult on mandating higher accessibility standards for new housing, a policy position supported through the Committee recommendations highlighted above.23

2.17 Current Local Planning Policy and Council Strategies

2.17 As the optional standards came into effect from 1st October 2015, the emerging Local Plan is the first planning document that has had the opportunity to implement the standards. However, previous documents referenced the Lifetime Homes standards, and current Doncaster Council24 strategies highlight the intention to cater for differing needs and to promote independent living.

22 CESCR, General Comment No. 6 E/1996/22, para 33. 23 ‘PM launches new drive to tackle barriers faced by disabled people’ (2019) accessed 27 June 2019. 24 Hereby known as ‘Council’. 5 | P a g e

2.18 The Doncaster Unitary Development Plan (UDP) and Core Strategy Development Plan (DPD) set out the current Local Development Framework for the borough. The DPD was adopted in 2012 and replaced large parts of the UDP. This document sets out the overall vision for planning within the borough. The emerging Local Plan will replace both documents.

2.19 Policy CS14: Design and Sustainable Construction, Part B, of the DPD recognises the need to ensure a more adaptable and sustainable housing stock. This was in response to the wide range of local needs, particular of those of an ageing population. For this reason it encourages the development of Building for Life criteria developments and the building of Lifetime Homes. The policy states “new housing developments will be expected to meet relevant Building for Life criteria (14/20 criteria for developments of more than ten dwellings). An agreed proportion of new homes should be designed to Lifetime Homes standards, subject to design and viability considerations”. Within the explanatory text to the policy it was proposed to seek to negotiate up to 20 percent of all homes on a site to be Lifetime Homes.

2.20 Whilst this policy encourages the building of dwellings to higher standards, it has not been monitored by the Council. Properties built to Lifetime Homes have largely been on sites developed in conjunction with Homes England and through the Council’s social housing build programme. The Council estimate around 500 properties have been approved, or built to Lifetime Homes Standards since the adoption of the DPD. Following the housing standards review and introduction of the optional building regulations, the Lifetime Homes requirement of Policy CS14 have been considered to be out of date, so largely has not been pursued by Doncaster Council except for their own social build programme and voluntarily by Registered Providers.

2.21 The Council has wider strategies that influence the priorities of the borough. Doncaster Growing Together (DGT) is the current strategic vision for the Council. Launched in September 2017 and in place for four years, DGT has four key themes:  Working – in ways that create purpose and meaning, and allow more people to pursue their ambitions;  Learning – that prepares all children and young people for a life that is fulfilling;  Living – in a place that is vibrant and full of opportunity where people enjoy spending time;  Caring – together for the most vulnerable in our communities.

2.22 Within the Living theme of DGT is the area for action that aims to allow more people to live in a good quality, affordable home. This forms the pledge for “Homes for All” and ensuring fewer people are in unsuitable accommodation. This will make sure that “more high quality new homes are built that are suitable for people of all ages and from all walks of life”.25 This makes particular reference to older people and the emerging Local Plan.

25 Doncaster Growing Together Prospectus 2017, pg 16. 6 | P a g e

2.23 The Caring strand of DGT aims to ensure that older people can live well and independently in their own homes. This acknowledges that “residential care is not always the best solution so we will improve home and community services to continue to reduce the number of people admitted”.26

2.24 The Council also has a wider Housing Strategy 2015-2025 which focuses upon the current and future housing needs to ensure growth and improvement. The Housing Strategy sets out the following housing vision: “residents will be able to access suitable, quality accommodation to meet their needs; viable, quality options will exist within the social rented, private rented or home ownership sectors; and residents will be able to live in safe, healthy and supported communities within vibrant and well-managed neighbourhoods”.27

2.25 In order to achieve the vision the Housing Strategy sets out three key objectives:28  Meet Housing Need  Raise Standards  Support Independent Living

2.26 To help achieve the objective ‘Meet Housing Need’, the Housing Strategy sets out that more needs to be done to recognise the ageing population issues within Doncaster. To do so housing adaptations would be provided to help people live independently for longer, as well as including accessibility design features in new built homes to keep future adaptation costs to a minimum.

2.27 To assist with the objective ‘Support Independent Living’, the Housing Strategy reiterates the need for accessibility design features to reduce the need for costly future adaptations. It also highlights the importance of Lifetime Homes standards to support needs associated with disabilities or limiting long-term illnesses.29 As established earlier, Lifetime Homes standards have now been replaced with the optional building regulations, but the principle still applies.

2.28 Understanding the Council’s strategic priorities outlines the current context and aims in which this report finds itself. As part of the holistic approach operated by DGT, planning policy, as alluded to in the strategies, has a key part to play in achieving the overarching aims of the Council.

26 ibid pg 18. 27 Doncaster Housing Strategy 2015-2025, pg 12. 28 ibid. 29 ibid pg 16. 7 | P a g e

2.29 Evidence Required

2.29 As highlighted in paragraph 1.2, the NPPG sets out that local authorities must provide an evidenced need for the optional standards. This evidence should demonstrate a clear need for housing with specific housing needs, and subsequently planning policy should reflect this.30

2.30 The NPPG states that it is up to local planning authorities to set out how they intend to approach demonstrating the need for requirements M4(2) and/or M4(3). It does however suggest that the following are considered when determining whether to introduce the standards:31  the likely future need for housing for older and disabled people (including wheelchair user dwellings).  size, location, type and quality of dwellings needed to meet specifically evidenced needs (for example retirement homes, sheltered homes or care homes).  the accessibility and adaptability of existing housing stock.  how needs vary across different housing tenures.  the overall impact on viability.

2.31 The NPPF sets out the definition of older people and people with disabilities in Annex 2. The definitions are outlined below:

2.32 Older People: People over or approaching retirement age, including the active newly- retired through to the very frail elderly; and whose housing needs can encompass accessible, adaptable general needs housing through to the full range of retirement and specialised housing for those with support or care needs.32

2.33 People with disabilities: People have a disability if they have a physical or mental impairment, and that impairment has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities. These people include, but are not limited to, people with ambulatory difficulties, blindness, learning difficulties, autism and mental health needs.33

2.34 To assist in the data collection of evidence required to satisfy the NPPG, the Government produced a summary data sheet.34 In 2019, NPPG on housing for older and disabled people was released, setting out some of the evidence plan-makers can consider when identifying housing needs for these demographics.35 This sets out useful data and sources of further information. Additionally, the Town and Country Planning Association and

30 NPPG, para 005, Ref ID 56-005-20150327; NPPG, para 008 Ref ID 63-009-20190626. 31 ibid para 007, Ref ID 56-007-20150327. 32 NPPF (n 1) pg 69. 33 ibid pg 70. 34 MHCLG, Guide to Available Disability Data 2015. 35 NPPG (n 30) paras 004 and 005, Ref IDs 63-004-20190626 and 63-005-20190626. 8 | P a g e

Habinteg prepared and published a toolkit36 to help planners to plan and secure delivery of accessible homes. The toolkit gathers together resources to help ensure an increased supply of accessible homes.

2.35 In 2018 the EHRC, alongside Habinteg, produced their own toolkits to assist those involved in housing and planning in local authorities. One of these is towards planning for accessible homes.37 This sets out the current regulations and policy context, good practice from other local authorities and a data source checklist. The toolkit also includes a pictorial example of a M4(2) home, this can be found below.

Source: EHRC Housing and Disabled People Toolkit Figure 1: M4(2) pictorial example

2.36 In preparing this evidence paper, the Council has been mindful of the need to present a robust evidence base whilst considering the aims of current National policy and local strategies.

36 TCPA and Habinteg, Towards Accessible Housing: A toolkit for planning policy. 37 EHRC and Habinteg, Housing and Disabled People: A toolkit for local authorities in England: Planning for accessible homes. 9 | P a g e

2.37 Evidence

2.37 The following section will present the evidence required to satisfy the NPPG. This is outlined under the same headings as stated in paragraph 7 of the NPPG.

2.38 The Likely Future Need for Housing for Older and Disabled People

Older People

2.38 According to the 2011 Census, 16.91 percent of Doncaster’s population were aged 65 and above. In contrast to the regional and national figures, this was a higher percentage of the total population. More recently, mid-year estimates allow for a more up-to date account of the population breakdown by age.

2.39 When the data from the 2017 mid-year estimate is compared to the 2011 Census, there is an estimated increase of 6,558 individuals aged 65 or above. This increase is at a slower rate than Y&H and England, however the percentage of the population that is at that age category is still higher.

Under 65 65-74 75+ Total Total % of pop 65+ 65+ Doncaster 251,261 27,109 24,032 302,402 51,141 16.91 Yorkshire & 4,409,162 463,849 410,722 5,283,733 874,571 16.56 Humber England 44,351,927 4,552,283 4,108,246 53,012,456 8,660,529 16.34 Source: 2011 Census Figure 2: Doncaster’s Older Population in 2011

Under 65 65-74 75-84 85+ Total Total 65+ % of % pop change 65+ from census Doncaster 250,950 32,230 18,590 7,190 308,960 58,010 18.78 +13.43 Yorkshire 4,447,440 554,370 320,610 127,710 5,450,130 1,002,690 18.40 +14.65 & Humber England 45,588,920 5,495,190 3,183,280 1,352,050 55,619,440 10,030,520 18.03 +15.82 Source: ONS 2017 Mid-Year Population Estimates Figure 3: Doncaster’s Older Population in 2017

2.40 Doncaster will also have a significant increase in the ageing population by the end of the plan period. In 2035 there will be an estimated total population of 315,700 people, this is an increase of 7,000 in comparison to 2018. In the same period the total amount of people aged 65 or over will increase by 19,900, subsequently the number of people aged below 65 will decrease. As a result the percentage of individuals within Doncaster that are 65 or over will increase to just under a quarter of the total population (24.83 percent).

10 | P a g e

Doncaster's Increasing Population 450000 400000 350000 300000 250000 200000 Overall Population Axis Title 150000

100000 65+

50000

0

Axis Title

Source: ONS 2016 Sub-National Population Projections Figure 4: Doncaster’s Population Projection

2.41 The changing age demographic of Doncaster can be highlighted with the population breakdown by percentage shown in Figure 5. As mentioned above, the percentage of the population 65 and over will increase to just under 25 percent. As a result, the percentage of the total population that are aged 0-64 will decrease.

100% 90% 80% 70% 60% 65+ 50%

40% 15-64

0-14 30% 20% 10% 0%

2026 2028 2017 2018 2019 2020 2021 2022 2023 2024 2025 2027 2029 2030 2031 2032 2033 2034 2035 2016 Source: ONS 2016 Sub-National Population Projections Figure 5: Projected Population Age Breakdown by Total Percentage

2.42 Whilst the overall 65 and over population is increasing, it is also important to determine the breakdown of this demographic. Doing so will help establish to what extent the population is ageing.

11 | P a g e

100%

90%

80%

70% 60% 85+ 50% 40% 75-84 30% 65-74 20% 10%

0%

2026 2035 2017 2018 2019 2020 2021 2022 2023 2024 2025 2027 2028 2029 2030 2031 2032 2033 2034 2016 Source: ONS 2016 Sub-National Population Projections Figure 6: Percentage Breakdown of the 65 and Over

2.43 Figure 6 shows that within the 65 and above age group, there will be an increasing percentage of people aged 75 or higher; and in particular 85 or higher. With a greater local and national strategic focus on allowing people to live independently at home for longer, it is essential to ensure housing is appropriate to deal with this increased 85 and above age group.

2.44 Old-age dependency ratios (OADR) measure the number of elderly people as a share of those of working age. This helps provide an idea of the relationship between working and pensioner populations. As increases in longevity continue, the ratio will rise. In mid-2016 the OADR for England was 302.8, this was slightly lower than the OADR for Y&H which scored 310.2. In Doncaster, the OADR was higher than the Yorkshire average at 319.3.

450 400 350 300 Doncaster 250 SCR 200 150 Y&H 100 England

50

0

2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2016 Source: ONS 2016 Sub-National Population Projections Figure 7: OADR comparison by regions

2.45 Over the plan period, the OADR for Doncaster is expected to remain higher than all other comparable regions with the exception of City Region Combined Authority

12 | P a g e

(SCR). SCR contains local authorities that also form part of Y&H and some that do not. When analysing the areas that make up SCR, the higher OADR figures came from local authorities outside South Yorkshire; such as Dales and North East Derbyshire, which had an OADR score in 2035 of 597.3 and 482.7 respectively.

2.46 Analysing migration flow statistics will help determine whether or not the increase in the 65 and over population is a consequence of older people moving to Doncaster in later life, or as a result of people growing old here.

Town 65-74 75-84 85+ Net Flow Doncaster 80 20 -40 60 Sheffield -200 -60 -90 -350 Barnsley 110 0 20 130 Rotherham 0 50 10 60 Source: ONS 2017 Internal Migration Figure 8: Internal Migration Figures

2.47 In comparison to other local authorities nearby and in the SCR, Doncaster has a small but fairly insignificant positive net migration flow for the 65 and over. What this seems to indicate is that there is reluctance for people 65 and over to move out of their current geographical area. This is supported through focus groups conducted by Sheffield Hallam University as part of their ‘The Housing Options of Older People in Doncaster’ report.38

2.48 Within the Sheffield Hallam Report respondents were asked their thoughts on moving. Respondents showed reluctance to move sighting various reasons, including not wanting to leave a neighbourhood they had established a close relationship with. As such, if a respondent did end up moving there was a strong preference to move within their current neighbourhood, village or town.39

2.49 Data is also available on the projection of households. Figure 9 shows the projection of the total number of households and households where the Household Reference Person (HRP) is aged 65 or over. This is projected to the end of the plan period.

DMBC 2015 2035 Change Household 128,533 140,312 +9.16% Projections Household 37,738 (29.36% of all 51,845 (36.95% of all +14,107 65+ Projections 65+ households) households) households; +37.8% Source: ONS 2016 Household Projections Figure 9: Doncaster Household Projections

2.50 The total 65 and over households will increase from 37,738 households in 2015 to 51,845 households by 2035, this is an increase of 14,107. Over the 20 year period in question this is an average increase of 705, 65 and over households per year. When applying this

38 Hereby knows as ‘Sheffield Hallam Report’. 39 Sheffield Hallam University, The Housing Options of Older People in Doncaster 2015 pg 49. 13 | P a g e

yearly average to the Local Plan, the NPPF states that strategic policies should look ahead over a minimum 15 year period.40 If the yearly estimate was projected forwarded 15 years, it would mean an increase of 10,580, 65 and over households in Doncaster by the end of the plan.

2.51 The 2011 Census provides a snapshot of older households by tenure. Tenures will be explored in more detail later, but it is important to apply them in relation to households here. This showed there were 23,951 households where the HRP was 65 and over in Doncaster. Over 70 percent of households are owner occupiers, with a further 6.66 percent either privately renting or in rent free accommodation.

2.52 Rates of social renting make up the tenure of a quarter of the total amount of 65 and over HRP households. The information does show that, whilst the majority of older people are provided for by the private market a significant number of individuals rent social housing and the policy should reflect this.

Tenure Total 65+ Households Average % of 65+ Households Owned 23951 70.11 Rented from Council 6929 20.28 Other Social Rented 1007 2.95 Private Rent or Rent Free 2275 6.66 Total 34162 100 Source: 2011 Census Figure 10: Tenure of 65 and above households

2.53 Using the information from Figure 10 we can predict the private market demand of the 10,580 increase of 65 and over households. The total percentage of households within the private market tenure accounts for 76.77 percent. Based on that figure, during the plan period there will be 8,122 new 65 and over households within the private market. This works out at approximately 542 households per year. This figure may be an underestimate as more people live independently for longer. It is acknowledged that not all of this demand will be met through new builds, and existing stock will play some part. However, as will be established in paragraph 2.141 not all existing stock is suitable to meet the specific needs that the 65 and over demographic require.

2.54 The ageing population will inevitably lead to an increase in the need for older people housing, due to the link associated with age and mobility and disability issues. Government statistics highlight the correlation between age and disabilities. According to the Family Resources Survey 2016/17, 45 percent of individuals at state pension age have a disability; this is in comparison to 19 percent of working-age individuals and 8 percent of children.41

40 NPPF (n 1) para 22. 41 Department for Work & Pensions, Family Resources Survey 2016/17, 2018 pg 1. 14 | P a g e

2.55 The Projecting Older People Population Information (POPPI) and Projecting Adult Needs and Service Information (PANSI) are useful online sources of information for determining the likely future changes with regards to age and disability. Figures 11 and 13 present POPPI information on the likely future change on certain characteristics of older people.

2019 2020 2025 2030 2035 % change 65+ Living 19,075 19,311 21,383 23,537 25,540 +33.89 Alone 65+ Living 1,781 1,811 2,054 2,314 2,708 +52.05 in a Care Home Source: POPPI Figure 11: Projection of Older People Living Alone or in Care in Doncaster

2.56 As can be seen there is predicted to be a significant increase in the number of older people living alone. Whilst the percentage increase of individuals living in a care home is predicted to be greater than those living alone, the numbers are considerably smaller in comparison. Whilst there is no breakdown of the care or other support that will be provided, the increase poses significant issues. Using the tenure breakdown presented in Figure 10, if 76.77 percent of those living alone lived within the private market, then at least 19,607 older people will be living alone within the private market by 2035.

2.57 The medical advances and societal successes that have increased life expectancies is allowing people to live longer. However, as demonstrated earlier, they are spending an increasing number of later years in poor health. This has profound implications for the quality of life experiences by those aged 65 and above, but more importantly their housing needs. Data allows us to examine the healthy life expectancy (HLE) and the disability-free life expectancy (DfLE) of the population at birth, but also more specifically for those currently at 65 and above.

15 | P a g e

Healthy life expectancy in Doncaster at birth, by sex, 2015 to 2017

Female

Female DfLE

Male

Male DfLE

0 10 20 30 40 50 60 70 80 90

Healthy Life Expectancy Years in 'Not good' Health Disability-Free Life Expectancy

Healthy life expectancy in Doncaster at age 65, by sex, 2015 to 2017

Female

Female DfLE

Male

Male DfLE

0 5 10 15 20 25

Healthy Life Expectancy Years in 'Not good' Health Disability-Free Life Expectancy

Source: ONS 2018 Health state life expectancy at birth and at age 65 by local areas Figure 12: Healthy life expectancy in Doncaster at birth and at age 65, by sex, 2015 to 2017

2.58 In Doncaster females are expected to live slightly longer than their male counterparts, however they will spend more of their life in ‘not good’ health. When DfLE is evaluated males will on average have 60.7 years disability-free whilst females will on average have 59.9 years. As noted by the ONS, it is important to recognise that periods of ill health may not be experienced during the same point in a person’s life. Despite this, it is acknowledged that the majority of years lived with a disability for most occurs post-retirement age. This is even more significant in Doncaster given the increasing OADR shown in Figure 7.

2.59 When the HLE is evaluated more specifically at the age 65, it is expected that both males and females will live 10 years in healthy life. Due to females living longer, this means they will live more than half of their remaining years in ‘not good’ health. When analysing DfLE males in Doncaster will experience 9 years from the age 65, and for females this is 8.6 years. If we are to presume that these disability-free years are experienced continuously from the age 65, it means potential difficulties might be experienced from early 70’s onwards. As demonstrated in Figure 6, there will be an increasingly proportion of the population aged 70 and above. 16 | P a g e

2.60 Figure 13 shows the POPPI projections for certain characteristics older people in Doncaster will have. These figures are projection forward to the end of the plan period. There will be a significant increase in the number of people unable to manage at least one domestic task on their own, and having a long-term illness that will limit their day-to-day activities by a little or a lot. There is also a steady increase in the number of individuals who will be unable to manage at least one mobility activity on their own. The implication of the number of people predicted to be admitted to hospital due to falls will be explored in more detail at para 2.189. 30,000

Limiting long-term illness (day-to-day activites are 25,000 limited a little)

Limiting long-term illness (day-to-day activites are 20,000 limited a lot) Require help with at least one domestic task 15,000

Unable to manage at least one mobility activity (inc getting around the 10,000 house/stairs)

Predicted to have a fall

5,000 Predicted to be admitted to hospital as a result of falls

0 2019 2020 2025 2030 2035 Source: POPPI Figure 13: Projected Characteristics of Older People in Doncaster

2.61 All of the factors highlighted in Figure 13 directly relate to the ageing population predicted in Doncaster during the plan period. When we consider this information alongside the increase of 65 and over households, people living alone and the strategic emphasis on allowing people to live independently for longer, the need for an increase in accessible and adaptable homes is prominent. As the population gets older, and more people stay within the private market the situation will only increase.

Long-Term Health Problem or Disability

2.62 Not everyone who suffers from a long-term health problem or disability (LTHPD) is part of the 65 and over demographic. The Ministry of Housing, Communities & Local

17 | P a g e

Government (MHCLG) produces an English Housing Survey (EHS), which provides a national perspective of households with a LTHPD. This data is not available at a local authority level however the 2011 Census provides some information.

2.63 Figure 14 shows the current breakdown of people with a LTHPD by age category. This has been presented alongside different regions for comparison purposes. According to the data, 21 percent of the borough is thought to be suffering from a LTHPD; as highlighted previously and illustrated by Figure 15 this is more prominent amongst the 65 and over.

Doncaster SCR Y&H England

Age 0 to 14 2,035 4% 12,814 4% 34,086 4% 339,110 4% Age 15 to 49 13,979 10% 82,746 10% 217,556 9% 2,103,015 8% Age 50 to 64 17,195 30% 96,605 29% 247,877 25% 2,196,897 23% Age 65 & 29,635 60% 178,581 59% 487,411 56% over 4,297,932 52% Total 62,844 21% 370,746 21% 993,649 19% 8,936,954 17% Source: 2011 Census Figure 14: Current Population of People with a LTHPD by Age Category

2.64 In comparison to the different regions the borough is consistent with the averages for the SCR local authorities, but has a higher rate of LTHPD than Y&H and England as a whole. Within the 50 and above categories Doncaster has a significantly higher percentage of the population affected than Y&H and England, emphasising the correlation between age and disability and its prevalence in Doncaster.

0-14 3%

15-49 22% 65+ 47%

50-64 28%

Source: 2011 Census Figure 15: Breakdown of the Population of Doncaster with a LTHPD

18 | P a g e

2.65 Unlike for age, the Office for National Statistics (ONS) does not provide population projections for individuals with a LTHPD. However, we can create a reasonable estimation based upon the current projected population within Figures 4 and 5. This does have certain limitations, such as its reliance on presuming that the same percentages of the population with a LTHPD in each age band are consistent. Doing so does not take into account any positive or negative health changes, better diagnoses of a LTHPD condition, or definition changes of what constitutes a LTHPD. For these reasons this projection is to provide a general estimation.

2.66 The population percent changes demonstrated through the ONS 2016 Sub-National Population Projections was used alongside the current percentage of people with a LTHPD against the total for each age band to calculate the estimation.

2017 2020 2025 2030 2032 2035 Age 0 to 2232 2256 2176 2076 2052 2024 14 Age 15 31104 30960 30768 30320 30256 29840 to 64 Age 65+ 34620 36180 39660 43800 45300 47040 Total 67956 22% 69396 22% 72604 23% 76196 24% 77608 25% 78904 25% Source: Estimation formed from 2011 Census and ONS 2016 Sub-National Population Projections Figure 16: Projection of People with a LTHPD in Doncaster

2.67 As demonstrated, by the end of the plan period a quarter of the total population of Doncaster will have a LTHPD. Across the borough all of this increase is expected to be in the age groups aged 65 and over. This is to be expected with the population reductions for people aged between 0 and 64. Figure 17 shows this age breakdown of people with a LTHPD more closely.

19 | P a g e

100%

90% 80%

70% 60% 65+ 50% 15-64

40% 0-14 30%

20% 10%

0% 2017 2020 2025 2030 2032 2035

Source: Estimation formed from 2011 Census and ONS 2016 Sub-National Population Projections Figure 17: Age Breakdown of Figure 16

2.68 The 2011 Census data provides a breakdown of the number of households that include somebody with a LTHPD. This is broken down into different household compositions, with each split between households where no person has a LTHPD, one person has a LTHPD, or two or more people have a LTHPD.

Household Composition All No people One person Two or more Households with with LTHPD people with LTHPD LTHPD All Categories 126,487 77,080 37,005 12,402 (9.8%) (60.94%) (29.26%) One Person household 36,104 19,630 16,474 0 (54.37%) (45.63%) One family only: Total 82,278 52,677 18,491 11,110 (13.5%) (64.02%) (22.47%) One family only: All ages 65+ 10,980 3,168 3,144 4,668 (42.51%) (28.85%) (28.63%) One family only: Marries, 57,403 39,849 12,052 (21%) 5,502 (9.58%) same-sex civil partnership or (69.42%) cohabiting couple One family only: Lone parent 13,895 9,660 3,295 940 (6.77%) (69.52%) (23.71%) Other Household types 8,105 4,773 2,040 1,292 (15.94%) (58.89%) (25.17%) Source: 2011 Census Figure 18: Households and LTHPD’s

2.69 Out of a total of 126,487 households in the 2011 Census, 39.06 percent included at least one individual who suffered from a LTHPD. This was very prevalent in households where every occupant was aged 65 and over. Out of all households with only one person

20 | P a g e

living there, just fewer than 50 percent suffered from a LTHPD. In such households the lack of human help may increase the need for assistance through design features.

2.70 Projection data released by the ONS does not go into enough detail to include numbers on the projection of households with individuals with a LTHPD. As mentioned in paragraph 2.65, a general estimation can be calculated based upon 2011 Census data and the household projections in Figures 4 and 5.

DMBC 2011 2035 % Change LTHPD Household 49,407 54,806 10.93 Projections Source: Estimation formed from 2011 Census and ONS 2016 Sub-National Population Projections Figure 19: Projection of Households with a LTHPD in Doncaster

2.71 By 2035 there will be 140,312 households in Doncaster. If the percentage of households with a LTHPD stays the same as Figure 18, then 39.06 percent of the 140,312 households will have a LTHPD. This equates to 54,806 households. This would mean an increase of 225 households with a LTHPD per year by 2035. In fact, due to the relationship between old age and LTHPD, the ageing population in Doncaster and emphasis on living independently, this could mean any calculated projection is an underestimate.

Wheelchair Dwellings

2.72 In paragraph 2.4, it was presented that the optional building regulations also include a M4(3) category that provides requirements for wheelchair user dwellings. Information about the need for housing for wheelchair users is difficult to obtain, with the 2011 census not going into any specific detail.

2.73 According to the EHS 2014-15, in 2014 just 7 percent of homes in England had all four accessibility features that provide visitability to most people, including wheelchair users.42 More specifically, among all households with a wheelchair user, 84 percent lived in a home that did not have full visitability.43

2.74 Some analysis was also undertaken based on national data in a report produced by Habinteg and South Bank University.44 Whilst this report was produced in 2010, there is an inadequate supply of further information available.

2.75 Within the report was a formula established allowing local authorities to apply the estimate of unmet wheelchair housing need into local planning. The formula uses data regarding the number of households in the local authority, alongside their table presenting their calculations of unmet housing need as shown below.

42 MCHLG, English Housing Survey: Adaptations and Accessibility Report 2014-15, pg 2. 43 ibid pg 24. 44 Habinteg and London South Bank University, Mind the Step: An estimation of housing need among wheelchair users in England. 21 | P a g e

Source: Habinteg and London South Bank University Mind the Step Report Figure 20: Unmet Housing Need Estimation Table

2.76 Using this method all local authorities in the region will show the same percentage of wheelchair user households with unmet housing need. Whilst this does not take into account the variation in levels of unmet needs between local authorities, the method is based upon good regional data.

2.77 The formula requires local authorities to take the number of households within their area and add it to the following equation.

Unmet Wheelchair Need (y)45 = (Local Authority Households × Column 4) × Column 5

When applying this to the household projection data in Figure 9 for the end of the plan period, the unmet wheelchair housing need for Doncaster is:

y = (140,312 × 3%) × 11% = y = 4,209.36 × 11% = y = 463.03

2.78 The plan proposes a net new build completion rate of 920 dwellings per year.46 Over the 15 year plan period, this would mean a total of 13,800 new dwellings. The unmet wheelchair housing calculation of 463 would therefore only represent 3.36 percent of the number of targeted new builds in the plan.

45 ibid pg 33. 46 Doncaster Draft Local Plan, Policy 3. 22 | P a g e

2.79 The forthcoming updated Doncaster Housing Needs Survey (HNS)47 produced a recent demographic modelling presumption on the need for wheelchair dwellings. This was based upon the data return from their survey on the current percentage of properties with adaptations and household projections. According to the HNS, residents in 4 percent of properties state they need their dwelling to be wheelchair adaptable. This led the HNS to calculate that there would need to be an increase by around 665 dwellings over the plan period. The unmet wheelchair housing calculation would therefore represent 4.8 percent of the number of planned new builds in the plan. This number is only slightly higher than the prediction calculated using the work undertaken by Habinteg.

2.80 Disability Living Allowance (DLA) statistics from the Department for Work and Pensions also provides an insight into the number of people in Doncaster with mobility issues. Whilst they do not specifically state whether or not those individuals have or require a wheelchair, it is a reasonable presumption that due to their application for DLA the majority of applicants will be wheelchair users.

2.81 Payments of DLA are made up of two components, one of which assesses mobility. The mobility component is paid at two rates: a higher rate for people who are physically unable, or virtually unable to walk; and a lower rate for people who can walk, but need guidance or supervision from another person when walking out of doors or on unfamiliar routes. Not all applicants of DLA will be eligible for the mobility component. To understand the potential prevalence of wheelchair usage in Doncaster, the percentage of applicants who have been awarded the higher rate of mobility pay has been compared to the same calculation for the overall applicants in England. Individuals on the higher rate will most likely require a wheelchair due to being classified as ‘physically unable, or virtually unable to walk’. This has been broken down by age bands to highlight the issues amongst older people, which is important due to Doncaster’s ageing population.

47 This will be published more widely by the Council at a later date. However early data produced and available at the report writing stage of the HNS will be presented in this paper to ensure the information in this evidence base is as up-to-date as possible. Any reference to the HNS in this report will be based around this forthcoming version unless stated otherwise. 23 | P a g e

100.00% 90.00% 80.00% 70.00% 60.00% 50.00% 40.00% 30.00% 20.00% 10.00% 0.00%

Doncaster Higher Mobility Rate England Higher Mobility Rate

Source: Department for Work and Pensions DLA Cases In Payment, Data from May 2018 Figure 21: DLA Claimants in Receipt of Higher Mobility rate Award by Age

2.82 In comparison to national figures, applicants of DLA in Doncaster are more likely to be awarded the higher mobility rate award. The number of overall applicants requiring the higher rate increases as they get older. The implications of this is that as the population age increases and the distribution of the population amongst the age bands moves towards the 65 and over, more applicants of DLA are expected to require a higher mobility rate. Again, due to the description of those successful for the higher rate, it would be reasonable to presume this increase would require wheelchairs and therefore wheelchair adaptable dwellings.

2.83 The numbers calculated through the Habinteg formula and the HNS represent a very small percentage of the overall new builds during the plan. However, the report in question acknowledged that local authorities with a relatively higher proportion of older people are likely to have more wheelchair users.48 As already established, the 65 and over demographic in Doncaster is expected to rise faster than the regional and national average. Not only this but the majority of individuals with a LTHPD will also be aged 65 and over, and a higher proportion of DLA applicants require the higher mobility rate award compared to the national figures. It is therefore more than likely that the calculated need will be an underestimate of the actual need by the end of the plan.

Summary

2.84 This section has presented the current and likely future need for housing for older and disabled people, including potential wheelchair need.

48 Habinteg (n 44) pg 35. 24 | P a g e

2.85 Over the plan period there will be a significant increase in older people and individuals who suffer from a LTHPD. By the end of the plan period, it is projected that 25 percent of the population will suffer from a LTHPD, and 24.83 percent of the population will be aged 65 and over.

2.86 More households in the borough will accommodate at least one individual who is over 65 and or suffers from a LTHPD. During the plan period, there is predicted to be an average increase of 705 65 and over households per year, and 225 households per year with someone suffering from a LTHPD.

2.87 These increases will coincide with a relatively low HLE and DfLE, an increase of people living alone and an increase in people unable to manage everyday tasks. This means the impact of an increase in these two demographics will highlight the need for appropriate housing, especially considering the push and desire for more people to live independently.

2.88 During the plan period, there is also a predicted increase in people requiring a wheelchair dwelling. It is predicted that the unmet wheelchair dwelling need will be between 463-665 new dwellings. In Doncaster, more recipients of DLA are eligible for the high mobility award than the national average. This may be lead to an underestimation of wheelchair need due to the prevalence of wheelchair defining characteristics and increasing older and disabled populations.

25 | P a g e

2.89 Size, Location, Type and Quality of Dwellings Needed to Meet Specifically Evidenced Needs

2.89 Within this section, different sources of information will help inform and present the evidence required to assess the size, location, type and quality of dwellings needed. Some of this will be informed through Council services, and the Council’s forthcoming HNS.

2.90 The HNS helps provide information on the housing options of older people. One of the questions asked was; “If you think it is relevant to you, which of the following older persons’ housing options would you seriously consider either now or in the next 5 years”; respondents were allowed to tick more than one option. Figure 22 is extracted from the HNS and shows that majority of older people want to continue living in their current home with support when needed. Buying a property in the open market was also a popular option.

Housing option % would consider Continue to live in current home with support when needed 83.7 Buying a property in the open market 7.7 Rent a property from a private landlord 1.6 Rent from a housing association 7.2 Sheltered Accommodation - Renting 16.2 Sheltered Accommodation –-Buying 8.0 Sheltered Accommodation - Shared Ownership 4.6 Extra Care Housing – Renting 14.2 Extra Care Housing – Buying 6.36 Extra Care Housing - Shared Ownership 3.7 Residential Care Home 7.2 Co-housing 8.2 Go to live with children or other relatives 4.5 Other 3.4 Base (total households responding) 23,709 Source: Housing Needs Survey Figure 22: Older Persons’ Housing Option Preferences

2.91 The above table clearly shows that the majority of older people want to continue living in their own home. This again highlights the importance the private market sector will play in ensuring that individuals can live independently for longer in appropriate accommodation.

2.92 In 2018, the government commissioned an independent review of the Disabled Facilities Grant (DFG). The subsequent report highlights the preferences of rehousing as an alternative to adaptations, by tenure and then age.

26 | P a g e

Source: University of the West of England DFG and Other Adaptations – External Review Figure 23: Households that required an adaptation wanting different accommodation, by age and tenure, 2014-15

2.93 People in private renting are most keen to move, while homeowners are the least keen. Almost 20 percent of households under 55 were willing to move; however, desire declines with age. This reluctance to move emphasises the evidence in Figure 22 from the HNS, and supports the need for dwellings that are easier to adapt from the offset. Whilst the optional building regulations will be more applicable to those already in old age, future generations, especially considering the ageing population in Doncaster, need to be considered. By building new dwellings to the optional building regulations, not only could those whom need an accessible or more adaptable property now have more choice, but also households can buy new properties with the peace of mind that if and when their needs change in the future they do not need to move.

2.94 Whilst the majority of older people will continue to live in their own homes, it is recognised that a proportion of people will prefer more specialised forms of housing. This is evident through the housing tenure presented in Figure 10, and the HNS above. The NPPG also references retirement homes, sheltered homes and care homes in its guidance.49

2.95 In Doncaster, specialist forms of housing are provided in various forms and by different organisations. St Leger Homes manage the Council’s housing stock, which according to their website stands at around 21,000 homes.50 Registered Social Landlord’s (RSL) also help provide housing within the borough.

49 NPPG (n 30) para 007, Ref ID 56-007-20150327. 50 St Leger Homes accessed 18 December 2018. 27 | P a g e

2.96 The HNS provides information on the current categories of specialist older person accommodation, this data was retrieved from the Elderly Accommodation Counsel and the Private Registered Provider Social Housing Stock Statistical Data Return 2017 return. From this data the change in need of specialist older person housing and residential care outside of the private market sector was calculated.

Current provision Number of Number aged 75 Number aged 75 and Change units 2018 and over 2018 over 2032 (projected) in need 25,900 36,500 Ratio of population to Ratio applied to 2032 current provision population Older person housing 2,022 7.9% 2,850 828 Residential care 4,023 15.7% 5,669 1,646 Total 6,045 8,519 2,474 Source: Housing Needs Survey Figure 24: Future Need for Specialist Older Person Accommodation

2.97 The table predicts that there will be the need for 1,646 additional units of residential care provision and 828 additional units of specialist older persons’ accommodation. As demonstrated in Figure 22 a higher percentage of older people would prefer to stay within the private market sector; however a proportion of the population will require and want more specialised care. It is important to make sure that older people are making an active, informed choice to live independently and that those wanting specialist housing have that opportunity.

2.98 The Council maintains an accessible housing register (AHR), which is a register of adapted properties that can be let to people with a proven priority need, as and when they become available. The register uses council stock dwellings and is means tested; as such the information provides only a partial picture of the requirements needed in Doncaster. It does however help provide a useful insight into the size, location, type and quality of adapted dwellings currently requested. Currently51 there are 75 households on the register. There is also 220 households currently on the inactive section of the AHR, most of these have been rehoused. To increase the sample size analysed from the AHR data, both the active and inactive list and their preferences was used.

Size

2.99 Applicants on the register are required to submit their current household composition and their property size requirements. The information is split into the region of the area in the borough that they would prefer to be located.

2.100 The household composition below clearly shows a higher tendency for applicants to have zero children, with one or two adults being the norm.

51 Data retrieved from the AHR is correct as of 29 October 2018. 28 | P a g e

4A 5C Household Composition 4A 3C 400 3A 5C 3A 4C 350 3A 3C 3A 2C 300 3A 1C 2A 4C 250 2A 3C 2A 2C 2A 1C 200 1A 5C 1A 4C

150 1A 3C

1A 2C 100 1A 1 Child (C) Unknown

50 4A only 3A only 2A only 0 1 Adult (A) only North South East Central Total Source: Doncaster Council Accessible Housing Register Figure 25: Household Composition of AHR Applicants

Property Size Requirements 5 only 450 4 or 5 400 4 only 350 2 or 3 or 4 300 3 or 4 250 2 or 3 200 1 or 2 150 3 only 100 2 only 50 1 only 0 North South East Central Total

Source: Doncaster Council Accessible Housing Register Figure 26: Property Size Requirements of AHR Applicants

29 | P a g e

2.101 Applicants on the AHR overwhelming wanted a two bed property. This is no surprise considering the one and two person tendencies in the household composition. Officers within the council interviewed as part of the HNS, also indicated that smaller bedroom properties were popular due to the ‘bedroom tax’ for under occupation of properties.52 Despite a high number of single person households, the number of households wanting a one bedroom property was significantly low.

2.102 When looking at the housing options of older people more specifically, the HNS provides an insight into the size of properties people aspired to but also expected.

Current Dwelling (%) Aspiration (%) Expectation (%) ½-Bedroom House 8.2 2.9 3.5 3-Bedroom House 38.2 10.6 7.5 4 or more-Bedroom House 9.5 3.8 4.3 ½-Bedroom Flat 5.5 9.0 8.2 3+ Bedroom Flat 0.2 0.0 0 ½-Bedroom Bungalow 26.5 43.2 41.7 3+-Bedroom Bungalow 10.9 22.5 25.1 Other 1.0 8.1 9.7 TOTAL 100 100 100 Base 34,287 1,359 955 Source: Housing Needs Survey Figure 27: Older Persons’ Housing Choices

2.103 Currently there are a great number of three bedroom properties occupied by older people. This does not match up to their size aspirations represented in Figure 27, where the majority of individuals surveyed chose either one or two bedrooms. This seems to highlight a preference for downsizing, which can be summarised with the reduction of three bedroom houses from being 38.2 percent of current occupied dwellings to only 10.6 percent of older people’s aspirations. What is worth noting is the expectation of one or two bedroom properties largely meets aspiration. This suggests that older people in the borough want to move to a smaller property, and most are expecting the opportunity to. It is vital this size demand is met.

2.104 Allowing the opportunity to downsize is one of the strategic arguments advocating for better appropriate older persons accommodation. A report by The University of Sheffield and Designing for Wellbeing in Environments for Later Life (Dwell) investigates how housing design can help older people downsize. They argue that the case for downsizing can be framed in terms of a win-win-win scenario, this is due to “improving the quality of life of those choosing to downsize, reducing future costs to health and social care services, and producing a positive impact on the housing market and the wider economy”.53 The report

52 Forthcoming Doncaster Housing Needs Survey, pg 102 (page reference subject to the publication version of the HNS). 53 The University of Sheffield and Dwell, Designing with downsizers: The next generation of ‘downsizer homes’ for an active third age 2016, pg 8. 30 | P a g e

acknowledges economic arguments on the basis that there are quantifiable benefits of freeing up more ‘family-sized’ housing assets currently owned or rented by older households.54

2.105 Figure 27 already suggests that current older person households occupy bigger, more family-sized dwellings, with the aspiration of reducing this to smaller properties. The HNS produced more specific evidence on the current attitude towards downsizing in Doncaster.

Housing choice Aspiration (%) Expectation (%) Downsizing (moving to a smaller 70.4 74.4 property) Staying same 24.5 23.4 Upsizing (moving to larger property) 5.1 2.2 Total 100.0 100.0 Base (households responding) 1,636 1,215 Source: Housing Needs Survey Figure 28: Future Housing Choices of Older Households

2.106 In terms of downsizing, 70.4 percent of older households aspired to move to a smaller property with nearly three-quarters of those households expecting to achieve this. Moving in the opposite way, a small percentage of households wanted to upsize to a larger property. This does show that whilst the majority of those individuals who would benefit from the optional building regulations would like to move to smaller one or two bed properties, some will be aiming for four or five bed. It is therefore essential that any sized new build is met to the optional standards, however the evidence suggests the market should aim for smaller bedroom sized dwellings.

Location

2.107 The location of both older people and individuals with a LTHPD can be assessed through both ONS and 2011 Census data. Recently, the Local Government Boundary Commission for England carried out an electoral review of Doncaster. As a result, the ward boundaries changed in 2015. Subsequently, map data from the 2011 Census will show different wards in comparison to data post 2015.

2.108 The population of the 65 and over is generally quite spread across the borough. According to ONS 2017 Ward Level Mid-Year Population figures, Doncaster had a total of 58,002 residents aged 65 and over;55 this equates to 18.77 percent of the population. When looking at the figures at a micro-level, in general the wards on the outskirts of the borough seem to hold higher densities of 65 and over people. Due to the geographical size differences between wards, the areas in which there is a higher number of older people do not necessarily

54 ibid pg 7. 55 Figures from the Ward Level and the Mid-Year estimates (Figure 3) differ slightly. 31 | P a g e

have a higher percentage of older people for that ward. Map data56 constructed using the ONS 2017 Ward Level Mid-Year figures help show this.

Source: ONS 2017 Ward Level Mid-Year Population Estimates (Map created by Doncaster Council) Figure 29: Distribution of 65 and over by numbers per ward

2.109 The highest number of 65 and over individuals currently reside within Finningley, on the east side of the borough. This is followed closely by Bessacarr and then Hatfield wards. When this data is transferred into percentages of the total population in each ward Finningley and Bessacarr remain fairly high but are not the highest density areas. Sprotbrough is currently the ward with the highest percentage of people aged 65 and over in relation to the total population of that ward. The age group makes up nearly a quarter of the population of Sprotbrough. The ward is closely followed by Tickhill & Wadsworth.

56 The statistical data used to create some of the maps can be found in Appendix 1. 32 | P a g e

Source: ONS 2017 Ward Level Mid-Year Population Estimates (Map created by Doncaster Council) Figure 30: Distribution of 65 and over by percentage of population per ward

2.110 The lowest number of people aged 65 and over generally live within the centre of the borough. Hexthorpe & Balby North have the lowest number and the lowest percentage of 65 and over in comparison to any other ward. The low percentage of 65 and over in relation to the ward population was closely followed by Town ward.

2.111 The distribution of individuals with a LTHPD is spatially uneven across the borough, however there is less discrepancy than there is with individuals aged 65 and over. The information is derived from 2011 Census. In total 21.7 percent of the borough had their activities limited a little or a lot.

33 | P a g e

Source: 2011 Census (Map created by Doncaster Council) Figure 31: Distribution of people with a LTHPD by numbers per ward

Source: 2011 Census (Map created by Doncaster Council) Figure 32: Distribution of people with a LTHPD by percentage of population per ward

34 | P a g e

2.112 Adwick and Mexborough wards ranked highest for the number of people with a LTHPD. When this transferred to the percentage of the total population in that ward both scored highly, but not the highest. Conisbrough & Denaby ward had the highest percentage of individuals with a LTHPD. Since the ward boundary changes in 2015, Conisbrough ward has expanded to include parts of the 2011 Thorne, and Edlington wards that scored fairly high for people with a LTHPD; this indicates there could be an even higher percentage now.

2.113 The lowest scoring wards were Finningley and Sprotbrough. As demonstrated by Figure 32, there is no real pattern concerning individuals with a LTHPD and their location within the borough. There does seem to be a small split between the north and south of the borough with slightly higher percentages of individuals with a LTHPD recorded in the most northern wards in comparison to the equivalent in the south.

2.114 The English Indices of Deprivation (IMD) provide a set of relative measures of deprivation for small areas across England, based on seven different domains of deprivation. The domains include a range of various factors, two of which help provide an indication of the necessity for more adaptable and accessible dwellings in the borough. These are the health deprivation and disability domain and the living environment deprivation domain. To demonstrate the spread of each domain within Doncaster maps have been created, these maps show the rank of each of the different lower later super output areas (LSOAs) in Doncaster, where a rank of 1 equates to part of the most deprived 10 percent of LSOAs in England.

2.115 The health deprivation and disability domain measures the risk of premature death and the impairment of quality of life through poor physical or mental health. The domain measures disability and therefore can help show the prevalence of disability and poor health across Doncaster. In general, Doncaster ranked as the 44th worst local authority in the country (out of 326) for health deprivation and disability.

2.116 As Figure 33 highlights, there is a disparity across the borough of health deprivation and disability. None of the LSOAs in Doncaster scored higher than eight, meaning the least deprived area in the borough is more deprived than the least deprived 20 percent of LSOAs in England. In general, apart from a few exceptions, the central and northern areas of the borough experienced higher health deprivation and disability than the south. This closely resembles the distribution of people with a LTHPD demonstrated in Figures 31-32. What is more significant is the level of deprivation experienced in comparison to the rest of England. The majority of these areas experienced a rank of four or below, meaning a significant proportion of the borough is in the 40 percent most health deprived and disability prone areas in England. Not only does Doncaster experience high levels of poor health and disability, but also it is significantly worse than the rest of the country. An increase in easier to adapt and better accessible dwellings would therefore help individuals with a demonstrated need to live in more suitable, safer housing and thus contribute to reducing deprivation.

35 | P a g e

Source: MHCLG English Indices of Deprivation 2015 (Map created by Doncaster Council) Figure 33: Health Deprivation and Disability Rank by LSOA

2.117 The IMD also gives data on the living environment deprivation domain that measures the quality of the local environment. This is split into the indoors sub-domain which measures the quality of housing, and the outdoors sub-domain which measures the air quality and road traffic accidents; as such only the former is assessed in Figure 34.

2.118 In general Doncaster ranked 138th worst (out of 326 local authorities) for living environment. When looking at the quality of housing specifically, the borough has LSOAs that scored positively, however this is offset with areas, most notably within the north of the borough, that performed poorly and were amongst the most deprived areas in England. What is noticeable is that many of the areas that ranked amongst the most deprived on this domain have a high older population as demonstrated in Figures 29-30. Certain areas with a higher aged 65 and above population scored amongst the least deprived areas for housing quality. When compared to individuals with a LTHPD, there seems to be an even higher correlation between poor housing quality and people experiencing a LTHPD. The vast disparity amongst people indicates a post-code lottery impact for many of the borough’s older population and individuals with a LTHPD. Ensuring appropriate and quality housing choices across different areas in the borough is therefore an important issue for Doncaster.

36 | P a g e

Source: MHCLG English Indices of Deprivation 2015 (Map created by Doncaster Council) Figure 34: Quality of Housing Rank by LSOA

2.119 The AHR allows individuals to request where in the borough they would prefer to be located. Most applicants request to stay within their current area, with 92 percent of people wanting to. In general the south of the borough was the most requested area, with the east of the borough the least.

120 114

97 100 90 80 81 80 68 61 60 53

40

20

0 North South East Central

Current Address Preferred Address

Source: Doncaster Council Accessible Housing Register Figure 35: Location Preferences of AHR Applicants

37 | P a g e

2.120 As most people tend to want to stay within close proximity to their current address, this suggests that there is a current shortfall of accessible homes within highly requested areas such as the south of the borough. This may lead to applicants waiting on the list for long periods of time before they can be relocated.

2.121 The Council’s housing stock provides some properties that are already adapted. Whilst part of the social market, it gives an indication to where in the borough people who need an adapted property could locate one.

Source: St Leger Homes (Map created by Doncaster Council) Figure 36: Location of Council Housing Adapted Properties

2.122 Whilst all wards have a council house adapted property, there is a vast difference between wards in the level of such housing. This could mean applicants for council housing having to move further away from their current property. In relation to the private market, the above map highlights areas in the borough that residents will struggle to rely on social housing if they require an adapted property. This is important as the current population of older people or those with a LTHPD have higher densities in wards with a lack of adapted social housing. If individuals in private market housing required an adapted or more accessible house, and their current property was not suitable, then they would be restricted on the location of social housing they could potentially apply for. This demonstrates a lack of appropriate choice across Doncaster.

38 | P a g e

Type

2.123 The HNS surveyed the current property types occupied by older persons’ in the borough, their aspired property type and their expectation of meeting that aspiration. This was presented in Figure 27 when the size of those properties was analysed. The table also allows us to understand the type of properties older people want to purchase. Unsurprisingly, there is a strong shift in attitudes to move from houses to bungalows. Highlighting a market demand for level-access dwellings.

2.124 In the HNS, aspiration and expecting scenario testing was conducted which helps determine the change as a result of demographic increases and decreases. Figure 37 presents extracted data reflecting the results for older persons’. It is noted that within the age breakdown, the 65 and over benchmark was reduced to 60 and over. In any case, those aged 60 at the time of the survey would be well into the 65 and over category by the end of the plan period. Figure 37 shows that the older demographic expect more flats to be built than they actually aspire for.

16000

14000

12000

10000

8000 Aspiration Expectation 6000

4000

2000

0 House Flat Bungalow Other Total

Source: Housing Needs Survey Figure 37: Older Persons’ Housing Type

2.125 In the Sheffield Hallam Report, bungalows also became a topical housing type. During focus group discussions many older people stated they would like to move to a property without stairs, but bungalows were in relatively short supply.57 The focus groups also commented on how new mainstream developments should focus more directly on the housing needs of older people, rather than focusing on first time buyers and young families.58

57 Sheffield Hallam Report (n 39) pg 47. 58 ibid. 39 | P a g e

2.126 On the AHR, applicants also get to select their desired type of property required. Applicants are allowed to select as many options as applicable, from the following types of properties: ground floor flats; bungalows; houses; parlour houses; and non-parlour houses.

House Type

400 H/PH/NPH

PH/NPH 350 B/H/NPH

B/H/PH 300 GFF/B/H/PH/NPH GFF/H/PH/NPH 250 GFF/B/PH/NPH

GFF/B/H/PH 200 GFF/B/PH GFF or (/) B 150 Non-parlour House (NPH) Only Parlour House (PH) Only 100 House (H) Only 50 Bungalow (B) Only

Ground Floor Flat (GFF) Only 0 North South East Central Total

Source: Doncaster Council Accessible Housing Register Figure 38: Type Preferences of AHR Applicants

2.127 The most requested choices were overwhelmingly bungalows or ground floor flats, with a small selection requesting parlour and non-parlour houses. Interestingly, no applicant made a request for a house only. The preference for house types, which minimises the usage of stairs, indicates the preference and need for step-free design requirements in Doncaster.

2.128 Current RSL’s provide housing of numerous sizes and types of properties across the borough. Whilst RSL stock generally caters for those in the social rented sector, in a similar vain to the AHR it provides an insight into the distribution of housing. Figure 40 breaks this down to show these figures. The regions were determined through the Council’s neighbourhood teams which are grouped into three areas: East, West and Central. The wards are placed into the different areas as follows:

40 | P a g e

Wards West Central East Adwick and Carcroft Balby South Armthorpe

Bentley Bessacarr Edenthorpe and Kirk Sandall Conisbrough Hexthorpe and Balby North Finningley

Edlington and Warmsworth Town Hatfield Mexborough Wheatley and Intake Rossington and Bawtry Norton and Askern Stainforth and Barnby Dun Roman Ridge Thorne and Moorends Sprotbrough Tickhill and Wadworth

Source:http://www.doncaster.gov.uk/services/get-involved/communities Figure 39: Neighbourhood Team Areas

2.129 One restriction with the data is that not every RSL broke down the type of dwelling into property size, for example, some simply recorded the dwelling as “house”. Some RSL’s provided specific needs housing, such as “disabled purpose built” or “bedsit age exclusive”, however these numbers were limited.

2.130 Collectively RSL’s own more houses and flats than bungalows. This is inconsistent with the preference and aspirational rates demonstrated through the HNS and AHR. When the number of bedrooms was stated the evidence shows there is a high number of one or two bed properties. The majority of these one bed properties are flats with the majority of these two bed properties being bungalows.

41 | P a g e

Source: Doncaster Council Figure 40: Location, Size and Type of RSL stock

2.131 The majority of RSL stock is located within the Central neighbourhood team area, this is despite the fact this area contains the least number of wards. Figures 29-32 mapped out the location of people 65 and above and those with a LTHPD. A small number of people aged 65 and above lived within the central area, whilst only a modest number with a LTHPD lived in the central area, especially in relation to the west and east. This suggests that any future housing provided for by RSL’s to address the need of the above demographics, should be better dispersed geographically across the borough.

Quality

2.132 The quality of housing needed can be assessed through the requests made on the AHR and the type of adaptations required. The AHR allows applicants to select the requirements needed for their potential property. Applicants were allowed to select more than one specification.

42 | P a g e

Property Requirements

Property Requirements

Ceiling track hoist 15 Adapted kitchen 42 Off road parking 44 Parking 52 Garden 94 Downstairs toilet 267 Through floor lift 13 Stair lift 23 3 steps max 0 1 or 2 steps 57 Wheelchair accessible internally 139 Wheelchair level access/ramps 249 Over-bath Shower 6 Level Access Shower 288

Source: Doncaster Council Accessible Housing Register Figure 41: Property Requirements of AHR Applicants

2.133 The most requested facility was a level-access shower, followed closely by a downstairs toilet and wheelchair level access/ramps to the property. The low numbers of requests for one or two steps demonstrates the emphasis on the need to eradicate stairs within the property; zero applicants felt they could manage with three steps. This, alongside the high level of requests for wheelchair level access/ramps shows a strong preference for step-free access to and within the home.

2.134 The think-tank Policy Exchange produced a report in 2018 on ‘Building for the Baby Boomers’ which assessed the housing market for an ageing population. Within this older people’s priorities for the design of homes were analysed. Respondents determined that amongst other priorities: ensuring homes are built to last; flexible to meet changing needs; and safe against accidents were important in designing homes.59 Whilst this highlights the national picture, the quality of housing needed, as presented in the data, shows a tendency to ensure homes can last and be appropriate for changing circumstances. Ensuring this flexibility is more important in areas with an ageing and prominent LTHPD population, such as Doncaster.

Summary

2.135 This section evaluated the size, location, type and quality of dwellings needed to meet housing for older and disabled people.

59 Policy Exchange, Building for Baby Boomers: Making a Housing Market for an Ageing Population, pg 33. 43 | P a g e

2.136 Most people want to stay within their home and this preference only increases with age. Ensuring housing is suited for changing circumstances is therefore important to the Doncaster housing market.

2.137 Older people and individuals suffering from a LTHPD would prefer to live in smaller, one or two bed properties. Allowing appropriate housing size choice for people, especially the older generation, would allow for the option of downsizing something that would be widely considered. This would free up larger family size properties in the borough and provide a more efficient and sustainable housing market in Doncaster.

2.138 Whilst the location of older and disabled people is relatively disperse across the borough, there are hotspot wards that accommodate a higher percentage. Using map data there is a current trend between the location of people aged 65 and above and individuals suffering from a LTHPD and health and disability, and quality of housing deprivation figures for the borough. When location was considered by people, most wanted to stay within close proximity to their current address. A location map of current adapted council housing across the borough shows that there is a lack of social housing in wards where more older and disabled people live.

2.139 When type was considered there is a strong preference for bungalows and dwellings with step-free or limited steps in the property. However, many older people in particular feel as if more flats and houses will be built than they aspire to live in. Most current RSL Stock revolved around flats and houses showing an inconsistency with what older and disabled people want and need, and what is currently available.

2.140 Applicants on the AHR frequently requested properties with step-free access design features with a home built to last being important. As mentioned earlier, people would prefer not to move later on in life, so ensuring that new dwellings are appropriate for changing needs with adequate design quality allows people to stay living in those properties even if their circumstances change.

44 | P a g e

2.141 The Accessibility and Adaptability of Existing Housing Stock

2.141 As mentioned previously, the current supply of homes within the borough will play a part in addressing the need of older people and those with a LTHPD. The extent to which the current supply will help with this need depends on the accessibility and adaptability of the existing stock.

2.142 The EHS produced a specific report looking into adaptations and accessibility in 2014-15. Surveyors assessed the visitability of sample dwellings across England on four features that make the home accessible to wheelchair users: including level assess through the main door; flush thresholds within the home; a ground floor toilet; and passage space throughout the home of at least 81cm wide.

2.143 Figure 42 is taken from the 2014-15 EHS report into accessibility and adaptability, and shows how visitability varies across tenure, dwelling type and dwelling age.

Number of ‘visitability’ features present (%) None One Two Three All Four All Dwellings (%) Tenure Owner Occupied 25.7 42.0 20.1 7.1 5.2 100.0 Private Rented 28.9 34.6 18.6 9.9 8.0 100.0 Local Authority 23.1 31.9 20.5 18.1 6.5 100.0 Housing Association 18.1 27.6 18.6 17.5 18.3 100.0 Dwelling Type Terraced House 40.6 36.1 13.6 5.3 4.5 100.0 Semi-detached House 33.7 42.3 16.0 5.5 2.5 100.0 Detached House 8.8 49.5 27.7 8.7 5.3 100.0 Flat 9.5 23.7 25.2 22.1 19.5 100.0 Dwelling Age Pre 1919 34.1 42.6 17.4 5.1 0.7 100.0 1919-44 33.7 43.8 17.6 4.1 0.9 100.0 1945-64 30.3 41.9 19.2 7.3 1.2 100.0 1965-80 20.7 41.8 23.5 10.7 3.4 100.0 1981-90 21.1 38.0 23.2 11.1 6.5 100.0 Post 1990 7.5 18.5 18.8 20.9 34.3 100.0 All Dwellings 25.4 38.4 19.7 9.5 7.1 100.0 Source: English Housing Survey 2014-15: Accessibility and Adaptability Report Annex Table 2.2 Figure 42: Visitability of Sample Stock in England

2.144 A number of conclusions can be taken from the table above, which can be considered in the context of Doncaster:  Owner occupied and private rented housing is generally least accessible, indicating a massive current shortfall in the private housing market. In the context of Doncaster, and the ambition to allow people to live independently for longer, this means the current stock may not be able to help with the vast need demonstrated.  Housing associations are most likely to have the highest visitability, however this number remains fairly small.

45 | P a g e

 Flats tend to be the most visitable type of dwelling with current houses falling short. As shown in Figure 37, in general older people in Doncaster do not aspire to live in a flat.  Older dwellings are generally less accessible than newer dwellings, this will be explored in more detail in relation to Doncaster below.

2.145 The dwelling age not only affects the accessibility of a property but also its adaptability. The older a property is, the harder it is to make it fully visitable through adaptations. According to the EHS Accessibility and Adaptability Report, even with properties built post-1990, only a quarter of dwellings can be made fully visitable with only minor works. Another quarter would not be feasible to make fully visitable, and the remaining half would require moderate or major works to the property.60

2.146 Information provided for in the EHS is only available at a national level, however its findings can be used to provide a snapshot of the situation in Doncaster. The Valuation Office Agency produces a Council Tax Stock of Properties for local authorities, which enables the current stock to be broken down by age. This has been compared with SCR, Y&H and England. Build Period Total (% of overall total)* Area Pre 1919 1919- **1945- 1965-1982 1983-1999 2000-2017 1939** 1964 Doncaster 18,740 29,610 28,560 28,050 14,600 12,410 (14.2) (22.4) (21.6) (21.3) (11.1) (9.4) SCR 151,870 155,600 163,230 163,670 85,410 88,120 (18.8) (19.3) (20.2) (20.3) (10.6) (10.9) Y&H 523,690 417,090 428,700 455,390 268,430 266,420 (22.2) (17.7) (18.2) (19.3) (11.4) (11.3) England 5,096,160 3,819,930 4,188,370 4,692,230 3,033,460 2,857,580 (21.5) (16.1) (17.7) (19.8) (12.8) (12.1) Source: Valuation Office Agency Council Tax Stock of Properties 2017 *Figures may not sum due to rounding to one decimal point **There is a gap in the data for the period of WW2 Figure 43: Age of Housing Stock in Doncaster

2.147 When you breakdown the age of housing stock in Doncaster, the borough has a lower than regional and national averages for pre-1919 builds. Using the EHS this means that less homes should fall into the bracket of not being feasible at all to make visitable. However, unlike the data for other regional groups, there are a smaller percentage of properties built post-2000. This means that whilst there are fewer properties that will most likely not be feasible to make visitable, there are fewer properties that will most likely be easy to make visitable with minor works. This was commented upon in the Sheffield Hallam Report, which stated that stakeholders felt the time taken for adaptations to take place could pose problems, and there were suggestions that some homes were not suitable for adaptation at all. One

60 EHS (n 42) pg 19. 46 | P a g e

concern of this was that it might drive some people towards a premature move into residential care.61

2.148 Another indication of the accessibility of existing housing stock is the need for home adaptations. Doncaster currently has an adaptations team within the Council with support and finances available through the DFG and the Home Improvement Agency. The HNS also surveyed respondents on the current situation regarding adaptations and their homes.

2.149 The Council’s housing adaptations service provides help for people in both the private and the social housing sector to advise and facilitate adaptations so they can stay mobile in and around their home. Information provided by the service allows an insight into the type of home adaptations required across the borough.

3096 Minor Works (Grabrails etc) 1690

Garage Conversion 1 0 0 Widen Doors/Internal Alterations 22 3 Steplift 0

Vertical Lift 11 5 1 Hardstanding 4 4 Specialist Toilet/Bio Bidet 9

Door Entry 2 6 6 Extension 7 86 Ramp 148

Specialist Bath 3 2 10 Shower Over Bath 24 116 Stairlift 98

Level-Access Shower 299 467 0 500 1000 1500 2000 2500 3000 3500 Private Housing St Leger Adaptations

Source: Doncaster Council Housing Adaptations Figure 44: Number and Type of Adaptations delivered between 2016/18

2.150 As Figure 44 shows, most of the adaptations provided were level-access showers, starlifts, ramps and then minor works such as grabrails. The high demand for level-access

61 Sheffield Hallam Report (n 39) pg 39. 47 | P a g e

showers mirrors the need illustrated through the AHR in Figure 41. The split between private and social housing stock highlights the need for properties with certain characteristics within the private market sector and demonstrates the preferences of individuals to stay within the private market with modifications if possible.

2.151 The HNS shows the adaptations or home improvements that households indicated that they required at the time, or within five years from the data they were surveyed. Data on home improvements required that are not relevant to the optional standards, such as ‘security alarm’ or ‘better heating’ have been removed for the purposes of this report.

Adaptation/improvement required Age group (% of households) Total Under 60-74 years 75+ 60 years Adaptations to bathroom 8.0 14.4 15.3 10.8 Adaptations to kitchen 7.4 5.7 5.2 6.6 Downstairs WC 6.1 7.4 7.7 6.7 External handrails 4.6 9.2 13.5 7.0 Improvements to access 3.1 5.5 6.2 4.2 Internal handrails 5.5 11.8 14.7 8.5 Stair lift / vertical lift 3.1 8.4 11.4 5.7 Wheelchair adaptations 2.9 4.9 6.7 3.9 Base (all households) 69,587 37,069 14,171 120,827 Source: Housing Needs Survey Figure 45: Housing Adaptations Required in Doncaster

2.152 The above table shows that a significant number of households in Doncaster require home adaptations. The most commonly required adaptation are bathroom adaptations and internal handrails. Wheelchair adaptations scored low, however as this data is based on the current needs and expectations of respondents as when surveyed this is unsurprising. It is highly unreasonable for people to expect to be wheelchair bound within in the next five years and as such require wheelchair adaptations. Indeed, the extent to which respondents predict their future requirements would depend on the level of optimism with regards to health, mobility and help with independence the respondent felt at the time. As such, it could be an underestimation of the future demand.

48 | P a g e

2.153 The HNS also took the percentage of properties with adaptations by HRP age and used this to try predict the number of adapted properties required by 2032.

Age Group Year % properties Number of adapted properties with required by age group adaptations Year: 2018 2032 change 2018 2035 change Under 65 91,578 87,872 -3,706 7.4 6,777 6,503 -274 65+ 39,174 50,166 10,992 12.6 4,936 6,321 1,385 Total 130,752 138,038 7,286 9.0 11,713 12,823 1,100 Source ONS ONS 2018 2018 survey 2018 2016-based 2016-based Household applied to survey Survey ONS 2016 applied to ONS 2016 Source: Housing Needs Survey Figure 46: Future Need for Adapted Properties

2.154 As can be shown, the HNS prediction indicates that there will be an increased need of 1,100 adapted properties. This model is only based upon the current percentages of properties with adaptations for those with an illness/disability, as such it does not take into other influencing factors required by the NPPG or the current unmet need. It does highlight that without any policy change there will be an increase in the need for home adaptations. As a result, the HNS concludes that the council implements the optional building regulations M4(2) and M4(3) with a requirement of 95 percent and 5 percent respectively.62 This recommendation from the HNS does not however take into account viability factors and considerations.

2.155 The above information highlights the current and potential future demands for adaptations in Doncaster. The Council in administering the DFG must ensure that all adaptations are the simplest and most cost effective options possible. Information provided for by the adaptations team shows the significant expenditure associated with adaptations. Over the period of 2016-18, £3,814,810.36 was spent on adaptations to Council housing stock and, £3,640,033.09 was spent on adaptations costing over £1,000 to private housing. Adaptations that cost under £1,000 in private market dwellings was not totalled, however over the time period 3,096 such adaptations were provided for. If we took £500 as a cost guide it would mean an additional £1,548,000 on adaptations to private market housing. In total this would mean the Council spent £9,002,843.45 on adaptations between 2016-18.

2.156 These cost implications are part funded by the DFG, however they have serious resource consequences. Many of the adaptations administered under the scheme could be undertaken more easily or cheaply, or in some cases not required at all, in dwellings built to M4(2) or M4(3) optional building regulations. Many issues faced could be negated during the design phase of development, reducing the future need for adaptations completely. Whilst

62 HNS (n 52) pg 106 (page reference subject to the publication version of the HNS). 49 | P a g e

other adaptations, such as level-access showers, which are one of the most common required, would be able to be undertaken more cheaply; as for example, plumbing would already be in place, or level-access already built. Therefore, the introduction of the optional standards would reduce the cost implications of each adaptation, thus allowing the Council to provide more. This is supported by NPPG that states it is better to build accessible housing from the outset rather than making adaptations to housing stock at a later stage. This makes particular reference to cost savings.63

Summary

2.157 The purpose of this section has been to evaluate the adaptability and accessibility of Doncaster’s existing stock.

2.158 According to the EHS only 7.1 percent of housing in England had all four of the visitability features present. When using EHS data on the ease of adapting dwellings to become visitable, most of Doncaster’s stock does not fall into the oldest stock and therefore not feasible at all to make visitable, but similarly most of the stock is not new enough to be adaptable easily.

2.159 According to the Council’s adaptations team, more adaptations are conducted on private market dwellings than council stock. Over the period of 2016-18, an estimated £9,002,843.45 was spent on adaptions across both private and social housing, with a higher proportion of this cost being associated with the private market. In the future, it is predicted more households will require adaptations in Doncaster. It is therefore essential stock be made as easy, quick, and as cheap as possible to adapt in the future to address the changing and emerging need.

63 NPPG (n 30) para 008, Ref ID 63-008-20190626. 50 | P a g e

2.160 How Needs vary across Different Housing Tenures

2.160 Data on the tenure profile by demographics assessed within this report is available from both the 2011 census data, and the recent HNS. The HNS provides a more generic tenure profile of the borough per ward based on the results of the survey conducted. This information does not allow for a breakdown of different demographics, such as aged 65 and above, or suffering from a LTHPD; but it does give a more recent update than the 2011 census.

Ward Owner occupied Private rented Affordable Base

Adwick le Street & Carcroft 57.5% 14.6% 27.9% 6,871 Armthorpe 71.3% 15.7% 12.9% 6,289 Balby South 60.8% 17.0% 22.2% 4,497 Bentley 60.5% 21.1% 18.4% 7,944 Bessacarr 70.3% 15.3% 14.4% 6,208 Conisbrough 59.4% 13.3% 27.3% 7,133 Edenthorpe & Kirk Sandall 79.2% 11.6% 9.2% 3,690 Edlington & Warmsworth 66.2% 15.9% 18.0% 5,074 Finningley 81.4% 10.8% 7.8% 6,353 Hatfield 75.1% 12.6% 12.3% 6,498 Hexthorpe & Balby North 47.3% 30.7% 22.0% 5,961 Mexborough 55.0% 17.1% 27.9% 6,778 Norton & Askern 72.6% 14.2% 13.2% 6,604 Roman Ridge 73.7% 10.5% 15.8% 4,889 Rossington & Bawtry 69.3% 13.5% 17.2% 7,567 Sprotbrough 84.2% 12.6% 3.3% 4,658 Stainforth & Barnby Dun 65.3% 12.7% 21.9% 4,859 Thorne & Moorends 63.6% 16.7% 19.7% 7,468 Tickhill & Wadworth 78.2% 13.8% 8.0% 4,465 Town 48.5% 34.0% 17.5% 8,175 Wheatley Hills & Intake 57.8% 13.8% 28.4% 7,837 Doncaster Total 65.4% 16.5% 18.0% 129,818 Source: Housing Needs Survey Figure 47: Property Tenure by Ward

2.161 The wards of Sprotbrough, Finningley and Edenthorpe recorded the highest proportion of owner-occupied properties. Private accommodation was high in Hexthorpe and Balby North, and Town wards, with it contributing over a third of the stock in the latter ward. Affordable housing was more prevalent in Wheatley Hills and Intake, Adwick le Street and Carcroft, and Mexborough wards.

51 | P a g e

2.162 The 2011 census allows for a tenure breakdown based upon age and individuals with a LTHPD. Figure 10 shows the housing tenure for the aged 65 and above in Doncaster with a majority of older people owning their own properties. The 2011 census broke the tenure data down by ward. This allows for a geographical analysis of the current spread of tenure preferences in Doncaster, to determine whether certain areas occupy more homeowners or not.

Source: 2011 Census (Map created by Doncaster Council) Figure 48: Distribution of people aged 65 and over living in Private Accommodation, by percentage of population per ward

2.163 Sprotbrough and Finningley have a considerably higher ownership rating than other wards in the borough. This is at the expense of people renting from the Council in those areas. When compared to the distribution of people aged 65 and above across the borough both wards scored highest amongst the number of people aged 65 and above living there. It is also consistent with the data set in Figure 47. This indicates that both wards are currently hotspot locations for the private market older population, with potentially a disproportionate amount of older people living there.

2.164 The preference to stay within the private market is consistent with the housing options preferences of older people as demonstrated in Figure 22. In general, it is difficult to predict the future tenure breakdown of the aged 65 and above. Despite this Figure 22 helps demonstrate an indication. The Sheffield Hallam Report also give an insight into the preferences of older people. Within the report the focus groups expressed a clear preference

52 | P a g e

for independent living, and there was a tendency to equate independent living within general needs housing. Focus group participants reported wanting, as a minimum, a dwelling that is:  Spacious;  Accessible;  Manageable;  Attractive; and  Well-located64

2.165 For the requirement of ‘accessible’, respondents mentioned that accessibility was related to the ease with which people can enter and leave a dwelling, as well as the use of the space within the property (especially concerning an accessible bath or shower and downstairs toilets).65

2.166 Other than choice, respondents in the Sheffield Hallam Report also indicated that a key reason for wanting to remain a homeowner was a desire to hold on to housing equity and the greater quality the sector provides.

2.167 In the 2011 census the tenure of individuals with a LTHPD were assessed by whether or not their LTHPD effects their day-to-day life; this was either by a lot, a little, or not. In general, those people with a LTHPD lived within the private market. This was more prominent with people whose day-to-day activities were not limited. Social housing contributed to a small percentage of individuals, this was highest when people’s LTHPD limited their day-to-day life a lot. The higher percentage of people living in the social rented market when their day-to-day life is greater effected indicates that there is more housing appropriate to their needs in the social market. This transfer between tenures could be a consequence of the lack of appropriate housing in the private market for LTHPD needs.

2.168 The breakdown by ward shows that there is quite a difference of people within the social and private market across the borough. The wards with the highest percentage of people with social rented accommodation, as shown in Figure 50 through scoring lower for private accommodation, are also the wards where the majority of individuals with a LTHPD reside, as shown in Figure 31. This again supports the notion that the tenure has better quality dwellings that are more appropriately suited currently.

64 Sheffield Hallam Report (n 39) 46. 65 ibid. 53 | P a g e

100% 3571 3387 90% 41076 48034 80% 6940 31577 48509 70% 9992 60% 7088 50% 5418 111315 123821 40% 30% 20% 12707 13741 10% 50388 76836 0% Day-to-Day Limited a Day-to-Day Limited a Day-to-Day not Total Lot Little limited

Owned Outright Owned with Mortgage Social Rented Private Rented or Other

Source: 2011 Census Figure 49: Tenure of Individuals with a LTHPD

Source: 2011 Census (Map created by Doncaster Council) Figure 50: Distribution of people with a LTHPD living in Private Accommodation, by percentage of population per ward

2.169 As demonstrated by Figures 48-50, the private rented sector (PRS) plays a significant part in the housing market in Doncaster. The Government’s Housing Strategy acknowledged

54 | P a g e

the PRS in establishing a pro-active approach to new builds.66 Overall, since 2000/01 the sector has grown by 131 per cent,67 highlighting its impact upon the private market and its potential to be increasingly an option for those aged 65 and over and/or have a LTHPD now or in the future. Despite this, a recent report published by the think-tank IPPR found that private renters are more likely to live in housing which is of poor quality than owner- occupiers and social renters.68 This supports information from stakeholders in the Doncaster HNS whom state conditions in the PRS are typically worse than in other tenures with negative impacts on health and well-being.69 Whilst it is impossible to determine the extent to which dwellings built to the optional building regulations will be used in the PRS, as demonstrated with the tenures in the figures above, the option should be available. Therefore, it could be presumed that without the introduction of accessible and adaptation dwellings, many older people or those with a LTHPD who need or want to privately rent would not be able to in an appropriate house.

2.170 MCHLG provides information on the current tenure split between private enterprises and housing associations within the borough of new build dwellings. Whilst this does not indicate the split between buying and renting of private enterprises, it does help show that the private market is increasingly the provider of new housing in Doncaster. It is therefore imperative, especially considering the tenure profiles and preferences of people, that the quality of these enterprises match the need demonstrated in this report.

1200

1000

800

600 Private Enterprise Housing Associations

400

200

0 2011-122012-132013-142014-152015-162016-172017-18

Source: MCHLG Tables on House Building: New Build Dwellings September 2018 Update Figure 51: New Build Dwellings Completed by Tenure in Doncaster

66 MHCLG, Laying the Foundations: A Housing Strategy for England 2011. 67 Darren Baxter and Luke Murphy, Sign on the Dotted Line? A New Rental Contract Final Report IPPR 2019, pg 3. 68 ibid pg 29. 69 HNS (n 52), pg 58 (page reference subject to the publication version of the HNS). 55 | P a g e

2.171 Throughout the report, reference is made to downsizing and the moving preferences of older people. The HNS provides information on the general reasons as to why people aged 65 and over want to move. This will help inform new builds and shows the importance for the requirements of higher quality dwellings for this demographic, especially in the context of their tenure profile and the support for people living independently for longer.

2.172 The HNS found that the main reason for people aged 65 and over moving was for health problems or they needed housing more suitable for an older/disabled person. This supports the demand for accessible housing options presented in the Sheffield Hallam Report referenced earlier. The reason was followed by the need for a smaller sized property and wanting a smaller garden.70

2.173 The requirement to move for health problems is also a significant issue within the social market. The Local Authority Housing Statistics provides information on the number of households that needed to move to council stock on medical or welfare grounds, including relating to a disability. Within the data set this criteria is classified as a household waiting in a reasonable preference group. Whilst this does not necessarily indicate that an accessible or adaptable dwelling was required or sufficient, it does support the increasing prevalence of health in housing decisions and relationship with a disability.

Households that need to move on medical/welfare grounds 600

500 Households who need to move on medical or welfare grounds, 400 including relating to a disability

300

200

100

0 2011-12 2012-13 2013-14 2014-15 2015-16 2016-17

Source: Local Authority Housing Statistics 2011-2017 Series’ Figure 52: Households that need to move on medical/welfare grounds

2.174 The data above is relatively new, however it shows a steady increase – with the exception for one year – of households on the waiting list for local authority stock that need to move due to medical or welfare grounds. It indicates that more individuals are suffering

70 ibid pg 93 (page reference subject to the publication version of the HNS). 56 | P a g e

medical conditions or a disability that impacts their normal living status and that their current dwelling, either in the private or social sector, is inadequate.

Summary

2.175 This section presented how needs vary across different housing tenures.

2.176 According to the 2011 Census, those wards which accommodated a higher percentage of older people had higher numbers of older people living in private accommodation. This was also the trend with individuals suffering from a LTHPD but not to as high extent. As people’s disability affected their day-to-day tasks more, people were more likely to be living in the social rented sector. In Doncaster, the vast majority of new dwellings built are private enterprises meaning any future choice will most likely be in the private market. This supports the housing tenure preferences of residents in Doncaster.

2.177 A growing number of older and disabled people are relying on the PRS for their living arrangements. Current rented stock is typically poorer quality than private market dwellings, meaning without standards policies in place, more people may be living in health hazard homes.

2.178 Health is a key factor in the need to move dwellings. In Doncaster households that have needed to move on medical or welfare ground, including relating to a disability has increased over the past five years.

57 | P a g e

2.179 The Overall Impact on Viability

2.179 The NPPF requires the planning system to take account of development viability when deciding planning applications and preparing the Local Plan. As such sites identified in the plan must be deliverable by avoiding a scale of policy requirements that together risks their ability to be developed.

Viability Testing

2.180 The council commissioned the Valuation Office Agency’s District Valuer Services (DVS) to undertaken an independent ‘Whole Plan Viability Testing’71 for the Local Plan in 2016. Due to the time elapsed since the original testing an updated assessment was commissioned and produced by CP Viability Ltd in 2019.72

2.181 The Viability Study 16 assessed housing design standards and for the purposes of the test assumed that all new housing be built to Part M4(2) of the optional building regulations.73 The updated Viability Study 19 assumed that 95 percent of new housing be built to Part M4(2) and 5 percent to Part M4(3) Adaptable of the building regulations.74 The NPPG refers to the Government’s Final Implementation Impact Assessment of the Housing Standards Review, which addressed the optional technical standards, and the EC Harris Cost Impact Study that it was supported by.75 The tables below have been taken from the EC Harris study and show the cost implications of introducing the new technical standards. The study compared the cost against the existing standards at the time, Lifetime Homes.

71 Hereby known as the Viability Study 16. 72 Hereby known as the Viability Study 19. 73 DVS, Doncaster Local Plan Viability Testing 2016, pg 53. 74 CP Viability Ltd, Whole Plan Viability Testing 2019 – Update, pgs 106-107. 75 NPPG (n 30) Para 003, Ref ID: 56-003-20150327. 58 | P a g e

Source: DCLG and EC Harris Housing Standards Review: Cost Impacts 2014 Figure 53: Cost Impact of Accessibility Standards

2.182 As an example, the above tables shows that for a three bedroomed semi-detached dwelling, the additional cost of applying the M4(2) regulations would incur an extra £521 per dwelling; this is in comparison with the £1,097 cost for the Lifetime Homes standard. As outlined in paragraph 2.18 of this report, the current Doncaster housing policy regarding accessibility and adaptability design standards was the requirement of up to 20 percent of new dwellings to be to Lifetime Homes standards. The optional standards would represent a reduction in building costs of approximately a half per dwelling compared to the Council’s current policy.

2.183 The costs for the Category 2 standards were included in the original Viability Study 16 and the updated Viability Study 19. The study conducted various viability tests based on different sensitivity analysis. Using the Viability Study 16 the policy, even if at 100 percent of all new dwellings, would be deliverable. Meeting M4(3) standards would incur higher build costs however this would still be at a cheaper rate than the previous wheelchair housing standards. The additional costs of a three bedroomed semi-detached dwelling to Category 3 Adaptable standards would be £10,307, and for Category 3 Accessible standards it would be £22,791. The standard was not incorporated into the original Viability Study, however the Viability Study 19 assessed a policy requirement of 95 percent of all new builds built to

59 | P a g e

M4(2), and 5 percent of all new builds built to M4(3) Adaptable standards. Under the NPPG, local plans policies for wheelchair accessible homes should be applied only to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling.76 As such, the new viability report assessed both M4(3) standards but only the wheelchair adaptable standard results apply to the policy in question.

2.184 The Viability Study 19 analysed the implication of adopting a policy requirement of 95 percent of new builds to be built to M4(2) and 5 percent to M4(3) wheelchair adaptable standards. This was done separately, and then collectively as a holistic policy requirement. The Viability Study 19 reported that under different sensitivity testing, the policy requirements would be deemed viable in high and median value areas. The low value schemes show an unviable outcome, however under the base sensitivity testing without any policy requirements the low value areas still showed an unviable outcome. This suggests that including the standards does not impact on the viability outcomes.77

2.185 The Local Authority Building Control has summarised the main differences between the mandatory M4(1) standard and the optional M4(2) standards, to give an indication of where additional costs may occur.

External Differences  All external doors must have a level threshold – the mandatory standard is just one door;  Approach routes must have a minimum clear width of 900mm or 750mm where there are obstructions, the gradient should be between 1:20 and 1:12;  Every gateway must have an 50mm clear opening, with a 300mm nib on the leading edge to allow users to reach the handle;  Parking spaces within the private curtilage of the dwelling (but not a car port or garage) must include at least one standard parking bay that can be widened at a later date to 3.3m;  Every principal entrance must have a canopy covering a minimum width of 900m and a depth of 1200mm. This can’t be a porch;  External doors must have an openable width of 850mm and have a 300mm nib on the leading edge. Internal Differences  Stairs must be a minimum width of 850mm to allow the future installation of a stair lift;  At least one bedroom must have a 750mm clear access zone from the foot of the bed and on both sides. Every other double bedroom will need a clear access zone on one side and the foot of the bed. Plans of furniture layouts in this case will need to be provided to show compliance;  Walls, ducts and boxing on all WC, bathroom and wet rooms must be strong enough to support grab rails, shower seats and other adaptations, which can take a loan of 1.5kn/m3;  A bathroom must be located on every floor that has a bedroom;  Ground floor WC must have a hidden drainage connection and be large enough to accommodate a shower;  Consumer units must be mounted at a height between 1350mm and 1450mm above floor level;

76 NPPG (n 30) para 009, Ref ID 56-009-20150327. 77 CP Viability Ltd (n 74) 112-116. 60 | P a g e

 Handles for windows, unless on a remote opening system, must be located between 450mm and 1400mm above floor level. Source: LABC Building Regulations Approved Document Part M in a Nutshell 2016 Figure 54: M4(1) and M4(2) Internal and External Differences

2.186 As the above differences show, the majority relate to positioning, layout and specific measurements. These can be accommodated through the initial design of the property rather than later on and thus incurring costs at the build stage. Advice for the previous Lifetime Homes standard stated that it is more cost effective to incorporate standards at the design stage rather than modify standard designs. This was also found in 1997 when the cost of lifetime homes was analysed by the Joseph Rowntree Foundation.78 As other local authorities incorporate the optional building regulations and the standards become consistent across the market in England, costs will be reduced as the market adjusts and best practice is shared.

2.187 The Government’s own Impact Assessment also outlines monetised and non- monetised social benefits. These wider viability considerations are important and must be factored in when considering the viability implications on whether or not to introduce the standards. The most common savings include but are not limited to:79  Avoiding temporary residential costs by enabling early return from hospital;  Reduced bed blocking in primary health care due to inappropriate housing preventing return home;  Reduced residential care costs by delaying long term need to move in to residential accommodation;  Reduced cost or and need for case assistance in the home;  Reduced costs to the health services arising from unsuitable housing and including trips, falls and injury to carers;  Reduced cost or need for adaptations;  Reduced cost of removing adaptations;  Reduced administration costs in re-housing older or disabled people.

2.188 As demonstrated above, the optional building regulations could provide a number of positive health and cost benefits and the Health Foundation states that one of the key indicators of a healthy home is “able to provide for all the household’s needs”.80 Inadequate housing is a potential source of a wide range of hazards, from burns, scalds and fire, to cuts and falls; this increases the longer an individual spends time in their home. People aged 65 and over spend more than 80 percent of their time at home, demonstrating the importance of the home environment to older adults’ health and well-being.81

78 K Sangster, Costing Lifetime Homes 1997. 79 Department for Communities and Local Government, Housing Standards Review: Final Implementation Impact Assessment 2015, pg 49-51. 80 Joia de Sa, How does housing influence our health? 2017. 81 Whitehead et al, Bathing adaptations in the homes of older adults: results of a feasibility randomised controlled trail BMC Public Health 2018, pg 2. 61 | P a g e

Falls

2.189 Falls are the most common cause of injury related deaths in people over the age of 75 in the UK, with up to 35 percent of people aged 65 and over falling one or more times every year.82 According to oral evidence presented to the Housing for Older People inquiry mentioned in paragraph 2.8, approximately 75 percent of deaths related to falls happened in the home.83 Where death is not a consequence, it can cause a person to lose confidence, become withdrawn, and feel as if they have lost their independence. As such falls may directly force people out of their own homes and into residential accommodation, or result in residents requiring care at home. One study found that 80 percent of older women surveyed said they would rather be dead than experience the loss of independence and quality of life that results from a bad hip fracture and subsequent admission to a nursing home.84 An Ipsos report stated that people were more worried about losing independence when they were older than dying.85

2.190 The online Public Health Profiles help provide information on emergency hospital admissions due to falls in people aged 65 and over. Since 2010/11 the number of people affected in Doncaster has increased in contrast to a slight decrease in the national figures; consequently, Doncaster has gone from ‘better’ to ‘worse’ in comparison.

82 Department of Health, Falls and fractures: effective interventions in health and social care 2009. 83 Communities and Local Government Committee (n 13) Q194. 84 Salkeld et al, Quality of life related to fear of falling and hip fracture in older women: a time trade off study BMJ 2000 85 Ipsos Thinks, The Perennials: The Future of Ageing What is Later Life Like? accessed 7 March 2019. 62 | P a g e

Source: Public Health Profiles Hospital Episode Statistics Figure 55: Emergency Hospital Admissions due to Falls in People Aged 65 and Over in Doncaster

2.191 When the data is broken down into individuals aged between 65-79 and 80 and above, it is clear that in recent years there has been a significant increase in the admission rates for individuals aged 80 and above. This is in contrast to the national data, which has increased only slightly. When looking specifically at the information for admissions for people aged 65-79, Doncaster has seen a slight increase however the national average has declined since 2010/11. Overall the data highlights that emergency admissions due to falls is demonstrably a problem in Doncaster. This is predicted to increase by 2035, as shown previously in Figure 13.

2.192 Information provided by Doncaster Clinical Commissioning Group (Doncaster CCG) provides the financial cost incurred in Doncaster to the health service due to hospital admissions from falls.

Age Hospital Admissions Cost (£) Cost per Individual Due to Falls (£) 0-64 933 2,027,474 2,173.07 65-84 1117 3,458,995 3,096.68 85+ 908 2,957,962 3,257.67 Total/Average 2,958 8,444,431 2,854.78 Source: Doncaster CCG Figure 56: Cost associated with falls in Doncaster by age, for the 12 months ending 31st August 2018

2.193 The data presented by Doncaster CCG highlights the significant cost that falls place upon the health service. What is interesting is that despite the 0-64 age category being the majority of the population, just over three-quarters of the cost is associated with those aged 65 and over. The 85 and over category recorded less falls than the 0-64 age, however their costs were higher. These costs will increase as more older people are admitted due to falls as predicted. What this indicates is that cost per fall per individual is higher as you get older. As

63 | P a g e

the population gets older, and the more expensive categories become more prominent, so will the health costs unless necessary action is taken.

2.194 In 2017, the Building Research Establishment Group (BRE) produced a cost benefit analysis of home adaptations commissioned by the Centre for Ageing Better. Within the report possible direct benefits to the NHS and adult social care budgets relating to changes in care needs as a result of an adaptation were explored. Certain adaptations that were assessed, such as an external ramp, extension of the home (space requirements) and shower replacing a bath, were considered to have highly likely or likely direct benefits on the reduced risk to falls. The introduction of the optional building regulations would therefore have a presumed return on investment benefit by helping reduce falls through its design requirements. It would also help cheaper and quicker adaptations, such as stair lifts, to be completed which further help reduce the risk of falls.86

Delayed Transfers of Care

2.195 As stated in the Government’s impact assessment on the optional building regulations, the standards will also help reduce the costs sometimes associated with discharges, through the reduction of bed blocking and the need for temporary residential care.87 Prior to discharge it is a typical practice for occupational therapists to assess conditions in the home to establish if older, disabled or temporarily injured people will be able to cope, to arrange for care and support where this will be necessary or recommend delayed return (until suitable adaptations can be made) or arrange a temporary move into residential care. Therefore, the appropriateness of an individual’s home will have profound impacts upon bed blocking, homecare packages and temporary residential care costs.

2.196 The impact assessment recognises that accessible housing improves the speed of adaption and makes it easier to avoid the need for temporary re-housing in residential accommodation. It also is likely that housing which is more accessible or adaptable will reduce the frequency of bed blocking by older people. To help equate this to Doncaster, information provides a breakdown of delayed transfers of care (DTOC), the reasons for the DTOC, day’s affected and additional information. The numbers are broken down by days affected, with patients occasionally covering more than one day and for different reasons. The data is restricted to the most appropriate reason for delay being recorded.

86 Centre for Ageing Better, Appendices to the role of home adaptations in improving later life 2017 accessed 11 March 2019, pg 93. 87 DCLG (n 79) pg 49-50. 64 | P a g e

700 600 500 400 300 200 100 0

April 2018 - 21/01/19

Source: Doncaster Council Figure 57: Reasons for DTOC in Doncaster

2.197 As can be seen assessments and care packages are the biggest reasons for a DTOC; with other reasons such as awaiting a residential home, adaptations and housing issues contributing to a significant number of days. Whilst the chart and the reasons provided do not break down into case studies where inaccessible housing was the specific reason, additional comments provided to each delay provides an insight. Some of these are presented below:

“Ambulance liaison to assess property access”

“Waiting for door to be re-hung to allow access”

“No medical needs on the ward. Needs adapted property”

2.198 According to the NHS, an excess bed day within acute services cost £346 per bed, per day in 2017/18.88 Relating this to the numbers in Figure 57 there were 1991 DTOC in the period between April 2018 and 21st January 2019. This would amount to £688,886 being spent on people physically ready to be discharged but unable to for the reasons explored in Figure 57.

Residential Care Costs

2.199 Residents who can no longer live independently and do not have a property suitable for adaptations could be forced into early residential care. Whilst available data does not

88 NHS Improvement, Reference Costs 2017/18: Highlights, Analysis and Introduction to the Data 2018, pg 5. 65 | P a g e

highlight the reasons why an individual ends up in residential care, there is financial information that helps show its implications.

Age Budgeted Total Expenditure Income (£) Total Cost Number of Number of (£) (£) Clients Clients 18-64 178 198 9,680,260 949,340 8,730,920 65+ 733 776 20,383,970 6,512,050 13,871,920 Total 911 974 30,064,230 7,461,390 22,602,840 Source: Doncaster Council Figure 58: Residential Care Costs 2017/18

2.200 The current costs associated with residential care is considerably more expensive than the cost associated with adaptations outlined in paragraph 2.155. As a result, if the option were a straight choice between adapting an individual’s property and placing them into residential care, the former would be the most viable. It was also be the preferred choice of residents as demonstrated in paragraph 2.90.

2.201 Within the BRE adaptations cost benefits analysis report adaptations that would have a direct benefit on delaying long-term care requirements, such as residential care, were assessed. The report concluded that adaptations, such as an extension of the home (space requirements), external ramp, parking and shower replacing a bath would be likely to have benefits on delaying long-term care requirements.89 Subsequently the introduction of the optional building regulations would help prolong the independence of residents even if their needs change and ensure that residential care would be a genuine last resort. This would have substantial societal monetary benefits but also personal benefits to the individuals affected.

Adaptations

2.202 The Council’s adaptations team also provides information on the number of adaptations provided to individuals being discharged from hospital. This information is for the financial years from 2016-18 and is split between adaptations made to the council’s St Leger stock, and adaptations made to private market properties.

89 Centre for Ageing Life (n 86). 66 | P a g e

HOSPITAL DISCHARGE ADAPTATIONS

Private Housing Market Social Housing Market

18%

82%

Source: Doncaster Council Housing Adaptations Figure 59: Private and Social Housing Adaptations conducted for Individuals being Discharged from Hospital 2016/18

2.203 Over the period of 2016/18, 260 adaptations were conducted to properties required as part of an individual being discharged from hospital. Out of the 260 the majority of these were made to dwellings in the private housing market. Hospital discharges tend to stem from unexpected accidents requiring hospital attention, occasionally resulting in changing personal circumstances for those affected. As can be determined from Doncaster’s housing tenure, the majority of people live within the private housing market, and therefore when being discharged from hospital their properties may not be suited to meet their changed need and circumstances, resulting in the need for adaptations as shown above. It is therefore essential that private market stock is suitable to change as people’s circumstances change. As was presented in paragraph 2.141, the current housing stock in Doncaster is relatively older, and harder to adapt to make visitable and appropriate. Adoption of the optional building regulations will therefore provide more dwellings that meet the changing needs of occupants over time, reducing the time or potential need for hospital discharge adaptations.

Summary

2.204 The above section considers the impact on viability by the introduction of the optional building regulations.

2.205 The Council’s commissioned Viability Study 16 considered the policy position of 100 percent of all new dwellings been built to M4(2) standards. Under different sensitivity analysis this was found to pose no viability issues. The updated Viability Study 19 tested a policy position of 95 percent M4(2) and 5 percent M4(3) wheelchair adaptable dwellings. It

67 | P a g e

found that the standards posed no impact to the viability results under the base scenario testing.

2.206 The Government’s Impact Assessment acknowledged wider monetised social benefits that should be considered. In Doncaster, there is an increased number of falls in comparison to the national average. As a result, from September 2017-August 2018, Doncaster’s health service incurred £8,444,431 due to hospital admissions from falls. This becomes more expensive the older the patient is.

2.207 DTOC could be avoided if dwellings could accommodate quicker adaptations to allow people who are ready to be discharged from hospital to go home. In Doncaster, home assessments, care packages and housing issues are common reasons for a DTOC. In total, between April 2018 and 21st January 2019 an estimated £688,886 could be attributed to DTOC in Doncaster.

2.208 During 2016-18, 260 adaptations were conducted to properties required as part of an individual being discharged from hospital. 82 percent of these adaptations were made to private housing with the other 18 percent made to social housing.

68 | P a g e

2.209 The Case for Introducing the Accessibility Standards

2.209 The Council considers that based on the evidence presented above that there is a strong need to increase the supply of accessible and adaptable dwellings, especially in the private market. It is considered that there is a small need presented in the paper for M4(3) category dwellings. Currently the provision of wheelchair homes is met through the Council’s strategic housing programme. However, as demonstrated throughout this paper, appropriate and adequate choice needs to be met across all housing tenures. The considerably higher costs of the M4(3) from M4(2) standards has been acknowledged due to the potential impact the standard would have on the viability of schemes. This could potentially have negative impacts on other policies in the Local Plan, such as affordable housing requirements and Section 106 contributions. As a result, the Council feels the proposed percentages of new builds for both standards in the policy, as will be outlined below, is an appropriate and justified balance.

2.210 The proposed policy recognises the situations whereby it may not be feasible or practical to meet these requirements. This is recognised in the NPPG as site specific factors such as vulnerability to flooding, site topography, and other circumstances which may make a site less suitable for M4(2) and M4(3) compliant dwellings, particularly where step free access cannot be achieved or is not viable. It is acknowledged that under the NPPG, where step-free access is not viable, neither of the optional requirements should be applied.90

2.211 Category M4(2) Accessible and Adaptable Dwellings

2.211 The evidence presented in this paper clearly demonstrates the need for more accessible and adaptable homes in Doncaster. The Council recognises that the strong evidenced need for more adaptable and accessible dwellings has to be considered alongside other policies in the Local Plan, as well as the Council’s chosen higher housing figure than required under the standard methodology. As such, the Council is not proposing that all new dwellings, but that 65 percent of all new dwellings are built to M4(2) standards. The reason for this figure is based on the evidence provided in this report and summarised below.

2.212 The number of older persons living in Doncaster is expected to increase substantially over the plan period, with a significant proportion of this growth been seen with those aged 85 and above. Consequently the number of households expected to house individuals aged 65 and over is also expected to increase. With the issue of an ageing population, it is essential dwellings are built to match the future demographic of the borough and the challenges presented that come with this. There is an expected increase of older people living alone, and unable to manage normal domestic tasks on their own. This will occur alongside an increase of individuals with a LTHPD. This is important considering the borough’s high OADR and the considerable number of years spent in ‘bad’ health as demonstrated through the HLE. The

90 NPPG (n 30) para 008, Ref ID 56-008-20160519.

69 | P a g e

borough also experiences a considerable amount of falls in comparison to the rest of England and DTOC affected by inadequate housing where trip hazards represent a very serious threat to health. The step-free access requirements of M4(2) will help eradicate this and allow easier and cheaper modifications to properties as resident’s requirements change.

2.213 Publically funded housing should be built to the appropriate standards from the outset, and to provide support where necessary the Council has an AHR programme matching applicants with appropriate accessible and adapted council housing stock. The stock is built to the optional building regulations since the replacement of the Lifetime Homes standard. Despite this, as demonstrated the majority of older people and those with a LTHPD live and want to stay within the private market sector. As the age of the population increases, it is imperative we allow people to move to a more accessible and readily adaptable private market property at a time that suits their needs. This is essential in delivering national and local policies to help support people to live independently for longer and to promote healthier, better quality housing. Current stock can be adapted to meet people’s changing needs, however according to the EHS it is more difficult and more expensive to complete with older properties. Doncaster has a lower percentage of properties built post-2000 in comparison to SCR, Y&H and England as a whole. This means that whilst some properties will be appropriate for relevant adaptations, many homes will simply not be able to meet the demand of a changing population. This risks exacerbating health problems, forced residential care, an expansion of applicants on the AHR or some residents having to move to another part of the country with more accessible and adaptable homes.

2.214 It is clear, therefore, that the pressures and demands for accessible and adaptable housing will increase and become a considerable housing issue if not dealt with in Doncaster. Using the HNS and information provided by the AHR and adaptations team, the need for properties suitable for older people and those with a LTHPD is generally quite even across the borough. Whilst both demographics have wards with an increased percentage of people living there, in general people would prefer to stay within close proximity to their current location as opposed to move to an area heavily populated with people of the same demographic. What is more important to individuals, is the size, type and quality of dwellings. There is a strong preference for properties with less bedrooms, and in particular for bungalows. This highlights the desirability of dwellings with little or no steps, and therefore can be seen as in support of the step-free design requirement of the optional building regulations. Such provision may therefore offer developers significant design features desirable to a large section of the market.

2.215 The policy has been robustly evaluated through the Council’s Viability Study 16 and 19 versions which found that the requirement of the M4(2) regulation would not make sites unviable even if applied to all new builds. Under this presumption any policy requirement, which is less than 100 percent of all new dwellings, would increase the viability of housing developments. The Council also recognises the importance of wider social monetary costs presented by the Government in their impact assessment. Health impacts due to inaccessible housing, residential care costs and adaptations to less adaptable properties create monetary

70 | P a g e

social pressures on the public sector, and neglect of these costs in the face of a well- evidenced demand would not constitute a sustainable or appropriate approach. As other local authorities include the standards in their local plans, the market will adapt to the ever- normalising standard and appropriate designs in new builds will be transferable from developments across the country.

2.216 The principle that all homes should be built to meet a wider range of needs is considered important to the Council in terms of its duties under the Equality Act 2010, and the wider obligation to ensure adequate housing for all. As a public sector organisation the Council has a duty to ensure non-discrimination, the advancement of equality and to remove or minimise the disadvantages suffered by people due to their protected characteristics, including age and disability. It is therefore imperative that housing allows every citizen of Doncaster the opportunity to access dwellings that meet their needs and tenure preferences. In this case that is more accessible and adaptable dwellings in the market. If the Council took a do nothing approach, then the upcoming Local Plan would fail in meeting the needs of the local residents as presented in this paper.

2.217 As summarised in this conclusion, the report has demonstrated a very clear demand for more appropriate dwellings for the ageing population and those with a LTHPD. The requirements set out in M4(2) optional building regulations will allow a greater opportunity of choice for residents due to its design requirements, but also allow for cheaper and easier adaptations for when life dictates. As Doncaster’s population gets older and people want to enjoy living independently for as long as they can, these characteristics of dwellings will become more important. It will also allow for people to move into more appropriate housing earlier, ensuring households do not need to move home, or go into residential care in order to address mobility issues which may be experienced at some point during their lifetime. Not all new homes will necessarily be occupied by someone who needs specific access-related requirements from the outset, but the standards will reduce the impact of changing circumstances over time. As such, the Council finds it appropriate and justified to require that 65 percent of all new dwellings are built to M4(2) requirements. Using the Council’s target of at least 920 (net) new homes per year,91 this would represent 598 M4(2) dwellings per year. 598 dwellings per year would help accommodate the projected increase of 705, 65 and over households per year and projected increase of 225 LTHPD households per year whilst recognising the part the current housing market has to play.

2.218 Category M4(3) Wheelchair Adaptable Dwellings

2.218 As demonstrated in this report, there is a small but significant evidenced needs for the higher M4(3) wheelchair dwelling standard. M4(3) is split into two distinct categories; wheelchair accessible and wheelchair adaptable properties. Under the NPPG, local plans policies for wheelchair accessible homes should be applied only to those dwellings where the

91 Doncaster Local Plan (n 46). 71 | P a g e

local authority is responsible for allocating or nominating a person to live in that dwelling.92 As such, only the M4(3) adapted wheelchair category shall apply in the local plan policy to new developments.

2.219 The Council’s evidence, presented in the HNS and summarised in this report indicated a potential need for 463-665 additional wheelchair adaptable dwellings over the plan period. As acknowledged earlier in this paper, this represents a small proportion of the current plan target of 3.36-4.8 percent, however this could be a serious underestimation of the need. Due to Doncaster’s particular ageing population and older current housing stock, it is deemed appropriate and evidenced that a slightly higher figure of 5 percent of new builds should be built to M4(3) wheelchair adaptable regulations. This figure will become more important in relation to the future demand from increased wheelchair users.

2.200 As evidenced, the population in Doncaster is getting older, and as a result the predictions for disabilities and mobility issues is expected to increase. This is supported through POPPI and PANSI predictions estimating that more people in Doncaster will have their day-to-day activities and mobility restricted. The borough also has a higher than national percentage of people deemed appropriate for the DLA’s higher mobility award allowance, designed for people who are physically unable to walk. By allocating a slightly higher than the predicted figure from the Habinteg formula and the HNS, the policy will take into account more evidence supporting the notion that mobility and disability will become more of an issue in Doncaster.

2.201 The updated Viability Study 19 tested the inclusion of 5 percent of new builds to be built to M4(3) wheelchair adaptable standards. It found that the policy inclusion had no impact to the viability of schemes when analysed against the base scenario testing. This was still the case when sites were analysed with the M4(2) requirement alongside the M4(3) requirement.

2.202 With the policy push from central and local government to allow people the choice to live more independently for longer, this gap is important to overcome particularly in the private sector. The Council is committed to ensuring a wide range of needs is cater for by ensuring genuine housing choices in Doncaster as explained in paragraph 2.216, the introduction of M4(3) adaptable dwellings will help support this. It is imperative that we recognise that without this adequate and appropriate choice we will be failing to create a physical world that serves all. Using the Council’s target of at least 920 (net) new homes per year,93 5 percent would represent 46 M4(3) wheelchair adaptable dwellings per year and accompany the Council’s social housing build programme.

92 NPPG (n 30) para 009, Ref ID 56-009-20150327. 93 Doncaster Local Plan (n 46). 72 | P a g e

3.0 Nationally Described Space Standards

3.1 Introduction to the Standards

3.1 New build dwellings are often judged too small for the needs of people who buy them, and often they are perceived as impractical for modern living. The Royal Institute for British Architects (RIBA) commissioned YouGov to conduct a poll to test perceptions and preferences around new dwellings. It was found that the size of rooms was more important to buyers of new builds than the number of rooms.94 This findings support the current imbalance between the distribution of the population, which is mostly one-and-two person households, and the distribution of homes, which are mostly three-or-more bedroom houses.95

3.2 The lack of space in homes can compromise basic lifestyle needs such as spaces to store possessions, learn, play, exercise and entertain friends; but as the RIBA report and a report by Shelter points out, it can also have profound impacts on the public’s health, family relationships, education, and contribute to anti-social behaviour.96 The size and quality of new dwellings in Doncaster is therefore an important factor into the happiness, health and well-being and quality of life experienced by our citizens.

3.3 The pressures of an increasing population, housing demand and land supply could lead to increased housing density and a housing crisis that is pushing more individuals into shoebox homes.97 However, these issues are not unique to new dwellings in England. In comparison to other European countries, the UK builds houses with the smallest average floor space (76m2) and the smallest room size (15.8m2). This is nearly half the overall floor space of Denmark, which recorded the highest floor space (137m2) and over half the room size of Greece, which recorded 39.5(m2).98 The issue of space is most notorious within Y&H where research has found homes to be the smallest in England when comparing the average for three-bedroom properties. The average in Y&H recorded to be 84m2, 1.4m2 smaller than the second smallest region the North East, and 24.5m2 smaller than the largest region, London.99

3.4 After consideration of space standards in the national housing standards review, the government introduced the new NDSS, these were made optional for local authorities to include in their Local Plans. In the instance where a local authority wanted to include planning policy that incorporated the NDSS, its need locally would have to be justified.

94 RIBA, The Case for Space 2011, pg 8. 95 Malcom Morgan and Heather Cruickshank, Quantifying the extent of space shortages: English dwellings Building Research & Information 2014, pg 710. 96 RIBA (n 94) pg 13; Shelter, Chance of a Lifetime: The impact of bad housing on children’s lives 2006. 97 The Guardian, Shoebox Britain: How shrinking homes are affecting our health and happiness, https://amp.theguardian.com/money/2018/oct/10/shrinking-homes-affect-health-shoebox-britain accessed 11 October 2018. 98 Morgan (n 95) pg 711; RIBA (n 94) pg 10. 99 Planning & Building Control Today, The UK has the smallest homes in Europe, says new research, https://www.pbctoday.co.uk/news/building-control-news/uk-smallest-homes-europe/32902/ accessed 30 January 2019. 73 | P a g e

3.5 In June 2019, the outgoing Prime Minster, The Rt Hon Theresa May MP delivered a speech on the state of housing, and in particular new builds. The speech described how the optional and regulation element of the standards has created a postcode lottery affect for buyers across the country. The Prime Minster stated, “I cannot defend a system in which some owners and tenants are forced to accept tiny homes with inadequate storage”.100 Whilst she acknowledged that it would be up to her successor in Downing Street to deal with the issue, she stated, “I believe the next government should be bold enough to ensure the Nationally Described Space Standard applies to all new homes”.101 In response to potential criticism of the approach from developers, the Prime Minster rejected “the argument that such a change will make building less likely” and “in fact it will have the opposite effect […] remove(ing) the commercial disincentive to develop sites in areas with stricter standards”.102 Whilst this speech is welcomed and supportive of the proposed policy, this evidence base will be presented under the current framework of the NDSS being optional for local authorities.

3.6 The NDSS deals with internal space within new dwellings and is suitable for application across all tenures and number of bedrooms. It sets out the requirements for the Gross Internal (floor) Area of new dwellings at a defined level of occupancy as well as floor areas and dimensions for key parts of the home, notably bedrooms, storage and floor to ceiling height. The technical requirement standards require that:103 a) The dwelling provides at least the gross internal floor area and built-in storage area (see Figure 60 below) b) A dwelling with two or more bedspaces has at least one double (or twin) bedroom c) In order to provide one bedspace, a single bedroom has a floor area of at least 7.5m2 and is at least 2.15m wide d) In order to provide two bedspaces, a double (or twin bedroom) has a floor area of at least 11.5m2 e) One double (or twin bedroom) is at least 2.75m wide and every other double (or twin) bedroom is at least 2.55m wide f) Any area with a headroom of less than 1.5m is not counted within the Gross Internal Area unless used solely for storage (if the area under the stairs is to be used for storage, assume a general floor area of 1m2 within the Gross Internal Area) g) Any other area that is used solely for storage and has a headroom of 900-1500mm (such as under eaves) is counted at 50% of its floor area, and any area lower than 900mm is not counted at all h) A built-in wardrobe counts towards the Gross Internal Area and bedroom floor area requirements, but should not reduce the effective width of the room below the minimum widths set out above. The built-in area in excess of 0.72m2 in a double

100 The Rt Hon Theresa May MP, Prime Minster of Great Britain and , ‘PM’s Speech on Housing’ (Speech at the Housing 2019 Conference, , 26 June 2019) accessed 27 June 2019. 101 ibid. 102 ibid. 103 DCLG, Technical Housing Standards – Nationally Described Space Standard 2015, para 10. 74 | P a g e

bedroom and 0.36m2 in a single bedroom counts towards the built-in storage requirement i) The minimum floor to ceiling height is 2.3m for at least 75% of the Gross Internal Area

Source: DCLG Technical Housing Standards – Nationally Described Space Standard Figure 60: Minimum Gross Internal Floor Areas and Storage (m2) * Where a 1b1p has a shower room instead of a bathroom, the floor area may be reduced from 39m2 to 37m2, as shown bracketed.

3.7 Current Local Planning Policy

3.7 Doncaster Council does not currently impose internal space standards through a policy in the current Local Development Framework through either the UDP or the DPD. However, despite this, guidance on space standards is provided through the South Yorkshire Residential Design Guide SPD, this was adopted by the Council in 2015.

3.8 The SPD was designed to provide guidance to residential developers and their design professionals, consultants and agents in formulating designs and making applications for planning permission in South Yorkshire. Under the SPD, internal space standards were produced after extensive research into standards in other local authorities. The standards set out the minimum internal spaces for different aspects of a dwelling, across various dwellings sizes.

75 | P a g e

Source: South Yorkshire Residential Design Guide SPD Figure 61: South Yorkshire Internal Space Standards

3.9 When compared to the NDSS, the above standards meet or better the minimum requirement for certain criteria, such as double bedroom area space, but fall short on other criteria, such as single bedroom area space. The overall floor area per bedroom and occupancy in general falls short of the NDSS, which provides a more comprehensive breakdown of bedroom and occupancy. Whilst the SPD provides guidance, its application does not provide as much weighting towards planning decisions as policies included in a Local Plan, or equivalent Planning Development Framework. Prior to the Housing Standards review the Design Guide space standards were used to guide and assess the amount of space provided in new developments. The operation and use of the standards was implemented relatively informally but was successful in providing an indication of the minimum amount of space required to be considered broadly acceptable.

3.10 Evidence Required

3.10 The NDSS can only be incorporated into planning policy where local authorities have demonstrated a need in their area. To help with the process of establishing a need for internal space standards the NPPG provides guidance on the areas local planning authorities should take into account. These are:104

104 NPPG (n 30) para 020, Ref ID 56-020-20150327. 76 | P a g e

 Need – evidence should be provided on the size and type of dwellings currently being built in the area to ensure the impacts of adopting space standards can be properly assessed, for example, to consider any potential impact on meeting demand for starter homes.  Viability – the impact of adopting the space standard should be considered as part of a plan’s viability assessment with account taken of the impact of potentially larger dwellings on land supply. Local planning authorities will also need to consider impacts on affordability where a space standard is to be adopted.  Timing – there may need to be a reasonable transitional period following adoption of a new policy on space standards to enable developers to factor the cost of space standards into future land acquisitions.

3.11 Evidence

3.11 The following section will present the evidence required to satisfy the NPPG. This is presented under the same headings as stated in paragraph 20 of the NPPG.

3.12 Need

Survey

3.12 In order to evaluate the size and type of dwellings currently being built in the area, a survey was undertaken by the planning team. To ensure that the survey represented the current breakdown of new builds in Doncaster a sample amount of recent developments, across different viability zones, was studied to determine the breakdown of property sizes generally being delivered. The breakdown was then used as the base percentage for each size of property (based on bedrooms) in the sample survey. The original target sample size for the space standards survey was 250 dwellings. The breakdown of bedroom sized in the sample recent developments was as follows:

Bedroom 1 2 3 4 5+ Total Sizes Total 41 421 826 415 30 1733 % 2.4 24.3 47.7 23.9 1.7 100

Using the above percentages, the breakdown of the sample survey was as follows:

Bedroom 1 2 3 4 5+ Total Sizes % 2.4 24.3 47.7 23.9 1.7 100 Total 6 61 119 60 4 250

77 | P a g e

3.13 It was decided that the current numbers to be surveyed for one bedroom and five and above bedroom properties was too low. To ensure that the space standards survey better reflected a more diverse building number the sample survey for those two property sizes was increased. To ensure that the space standards took into account developments with different viability pressures, the sample size also reflected a rough even distribution across the three different viability zones (as extracted from the Viability Study 19 document and shown in Appendix 2) which are also geographically spread around Doncaster.

3.14 A range of sites were then chosen to extract the information needed to complete the survey. In total 47 sites were selected across the borough. These were mainly submitted and delivered over the past five years but some older sites were selected to reach the number of housing types required. The Council acknowledges that different housing developers will approach housing space standards differently, and it could not be expected that smaller and larger developers be consistent under current policy requirements. As such, the survey sample reflected a range of different developers and development sizes ranging from sites with a few units, to sites with over a hundred units, smaller independent developers to large volume national housebuilders.

3.15 For each development, different house types were measured in accordance with the bedroom size requirements stated above. With the increases to one and five bedroom dwellings and trying to take into account the different site characteristics explained in paragraph’s 3.12 and 3.13, this meant that the following was surveyed:

Bedroom 1 2 3 4 5+ Total Sizes % 6.9 20.7 35.0 33.3 4.1 100 Total 17 51 86 82 10 246105

3.16 Data from each site was taken from planning application documents. From this, each individual house type could be identified and the number of bedrooms and intended number of occupants could be identified from the relevant plans and the number of storeys recorded. Each selected house type was measured using the submitted plans to determine the floor space and width of each bedroom, gross internal floor area of the property and the floor space of any designated storage space. This data was inputted into a spreadsheet, which was set up to compare the sizes measured against the requirements in the NDSS. This allowed the Council to analyse whether or not the proposed number of bedrooms was adequate based on the actual measurements of the bedrooms, and whether or not the proposed floor plan and storage space was adequate based on the number of intended habitants.

3.17 For the purposes of the survey, the lowest number of occupants attributed to the house storey, size and number of bedrooms from the NDSS was used. This was because that despite

105 The total number of dwellings surveyed was lower than the intended 250, due to restrictions on some of the plans that did not allow for adequate measurements. 78 | P a g e

some plans outlining a single or double bed in a bedroom (and therefore one or two person for that bedroom) it is impossible to determine how many people will actually make up that household.

3.18 Out of the 246 homes surveyed:106  Only 23 met the full requirements of the NDSS when using the standards required for the proposed number of bedrooms on the plan. 7 (30.4 percent) were two beds, 10 (43.5 percent) were three beds, 4 (17.4 percent) were four beds, and 2 (8.7 percent) were five beds. When this was broken down into the different reasons why plans failed:  142 (57.7 percent) met the size requirements for their proposed number of bedrooms;  133 (60.7 percent) of the 219 two or more bedroom properties had at least one room of double bedroom standard. Out of the 86 that did not, 10 should only be classified as a one bedroom property.  54 (22 percent) met the space requirements for storage based on their proposed number of bedrooms. This number only increases to 58 (23.6 percent) if the space requirements for storage was based on the number of actual bedrooms according to the measurements.  201 (81.7 percent) met the gross internal floor area based on their proposed number of bedrooms. This number increases to 225 (91.5 percent) if the gross internal floor measured was based on the number of actual bedrooms according to the measurements.

3.19 Further analysis was undertaken to establish how close homes that missed the NDSS figures around storage space and floor area were to the standard. This was based around the properties required space for each criteria according to the number of proposed bedrooms in that property. It found that:  To hit the minimum storage space requirement: 7 houses were up to 10 percent away from hitting the standard; 45 houses were up to 25 percent away; and 117 were up to 50 percent away. 54 houses were more than 50 percent away from hitting the standard.  To hit the minimum internal floor space requirement: 14 houses were up to 5 percent away from hitting the standard; 25 were up to 10 percent away; 43 were up to 25 percent away; and 45 were up to 32 percent away.

3.20 The above analysis highlights that currently just under half of the surveyed properties failed to make all stated bedrooms the adequate size, enough to be classified as a bedroom. As such the survey found that an overwhelming amount of properties advertised as a particular size actually only had the bedroom space capacity for one bedroom less, so a three bedroom would most likely be a two bedroom house due to the size of the final bedroom.

106 A simplified version of the spreadsheet is available in Appendix 3. 79 | P a g e

3.21 When looking at the internal storage space the vast majority of plans analysed fell short, with 30 not providing any at all. Even when the storage space provided was assessed against the actual number of bedrooms according to their sizes, which as outlined above normally meant there was less bedrooms and therefore a lower standard to hit, the majority still do not meet the NDSS requirements. Storage space was the most common reason as to why houses did not meet the NDSS.

3.22 The majority of plans assessed did meet the gross internal floor area based on the number of bedrooms proposed. This increased if the plans were assessed based on the number of actual bedrooms in the dwelling that met the NDSS.

3.23 When the results for each of the space requirements in the NDSS are considered holistically it is clear that the majority of dwellings fail on their current storage space and bedroom standards. The issue was not normally down to the actual floor area of the dwelling, indicating that increases in plot size would not be a significant issue if the standards were implemented in Doncaster. What this highlights is that dwellings recently built in Doncaster could have been compliant with the NDSS if the internal designs of the properties were adjusted to ensure appropriate internal storage space and that all bedrooms were of a decent standard.

Density

3.24 As discussed earlier at Paragraph 2.77, the emerging Local Plan aims to deliver at least 920 (net) new homes each year over the plan period. This housing target for the borough is higher than the standard methodology minimum and accompanies the economic aspirations of the Council. The Council’s Inclusive Growth Strategy 2018-2021 indicates that under the current ‘business as usual’ model there will be an additional 13,000 net new jobs over the next 15 years. However, given the full package of the Strategy the ambition is to achieve a higher than the usual jobs growth rate which would add a further 13,000 jobs.107 Therefore meeting this pressing need for housing that will result from economic growth in Doncaster must be done in a way that makes it a pleasant, high quality place to live and work. This is reiterated within the Inclusive Growth Strategy, as part of the quality of life inclusive growth driver is the need for quality homes.108 This will accompany the increase in jobs to make Doncaster an attractive place to work and live. Ensuring adequate space is a key part of ensuring the long term sustainability of Doncaster, particularly if families are to be accommodated as part of the economic growth aspirations of the borough.

3.25 One of the challenges that faces such high housing targets is around increased densities within the area. As the population and land scarcity increases, densification will slowly become the norm for expanding places such as Doncaster. Densification can yield certain benefits, which considering the Green Belt and Flood Zone issues within Doncaster

107 Doncaster Inclusive Growth Strategy 2018-2021, pg 26. 108 ibid, pg 36. 80 | P a g e

could become increasingly important. The New Climate Economy 2018 report of the Global Commission on the Economy and Climate puts forward some of the benefits of densification, especially in emerging towns and cities. These are notoriously around avoiding the high costs of sprawl, including congestion, CO2 emissions, air pollution, traffic accidents, and the increased investments needed to extend critical infrastructure to more dispersed populations.109 The NPPF also reiterates that planning decisions should avoid homes being built at low densities.110 As consideration is increasingly made for sustainability in the face of ever-critical climate change predictions, high housing targets will be pushed towards this approach. However, without adequate quality control densification could produce profound negative consequences.

3.26 A report into the history of space standards by Julia Park argues that if success is only measured in numbers, smaller and cheaper housing will always win.111 It is reasonable to presume that the high housing targets put forward in the emerging Local Plan could lead to some developers taking this approach. However, floor space minimums ensure that quality is not sacrificed in order to achieve other policy priorities such as housing targets.112 The New Climate Economy Report reiterates the point that densification can only be considered a success if the compactness does not impact upon the quality of life for all groups but most importantly lower-income residents.113 Adopting the NDSS can help provide this safeguard by helping promote sustainable and high quality developments.

3.27 As argued by Julia Park, floor space minimums can help ensure quality is not scarified as a result of building as much housing as developmentally possible on sites. Doing so not only ensures that there is attractive and liveable housing but also reduces risks to developers. Using the space standards survey discussed earlier, current new builds in Doncaster are more often than not big enough to meet the NDSS for gross internal floor area based on the number of proposed bedrooms. It would therefore be illogical in the context of Doncaster to argue that the Plans higher than minimum housing target and borough’s ambitious jobs growth can only be achieved by increasing housing density on sites and therefore incompatible with the objectives of the NDSS. In contrast applying the NDSS to Doncaster will provide high quality new builds and in turn the local housing market will stabilise to reflect this and become more sustainable. Reducing quality for higher density will also risk the notion of ‘cramming’ new homes onto sites, negatively affecting such properties to have limited utility and therefore only suited for a narrower market.114 In turn this may deter buyers, who may find it difficult to sell on in the future, especially as other local authorities apply the NDSS to their area. Consequently, this could restrict the number of people moving to Doncaster despite the jobs growth in the area; meaning lost economic opportunity for our local communities and increased unnecessary travel from other areas not

109 The New Climate Economy, Unlocking the Inclusive Growth Story of the 21st Century: Accelerating Climate Action in Urgent Times 2018, pg 74. 110 NPPF 2019 (n 1) para 123. 111 Julia Park, One Hundred Years of Housing Space Standards: What Now? 2017, pg 74. 112 UCL and CABE, Space Standards: The Benefits 2010, pg 11. 113 The New Climate Economy (n 109). 114 CABE (n 112) pg 12. 81 | P a g e

in the borough as people decide not to relocate to Doncaster. This creates the potential for lower sales and empty new builds and is therefore an increased risk for developers.

Ventilation and Climate Change

3.28 It is also important to ensure that new developments have access to adequate natural light and ventilation. According to a report produced by University College London for the Chartered Association of Building Engineers (CABE)115 having more space in homes helps improve day light and ventilation.116 The NDSS requires all new dwellings to have a minimum floor to ceiling height of 2.3m for at least 75 percent of the Gross Internal Area. Having such minimum quality control standards is significantly important for high density dwellings.

3.29 Adequate ventilation is particularly important given the current trend of climatic projections for Doncaster. In 2018 the Met Office released the most up-to-date assessment of how the climate of the UK may change over the 21st century. The UK Climate projections 2018 (UKCP18) was an update from their 2009 predictions. The raw data available on the Met Office UKCP User Interface allows for various projections of different climatic indicators to be analysed at different geographical levels. For the purposes of presenting the specific potential impact of climate change, in relation to needing adequate ventilation in new builds, the mean air temperature predictions for Doncaster was analysed.

3.30 Figure 62 below shows the change in annual mean air temperature for probabilistic projections. The data did not allow for the whole of the Doncaster Council geographical area to be selected so Doncaster town centre was pin pointed instead. The graph is broken down into four different future scenarios, with each scenario showing the temperature based on different percentage presumptions. For example, T10 indicates that there is a 10 percent probability of the temperature its associated with being less than that, T50 equates to 50 percent probability, T90 to 90 percent probability. Therefore, T50 can be considered as the average mean air temperature for that scenario at the stage, as it shows the temperature where it is just as likely for it to be less than that, as it is actually to be higher than that temperature. The different scenarios are explained below:  RCP 2.6 = A future scenario where greenhouse gas emissions are strongly reduced. Best estimate global temperature rise of 1.6 deg C by 2100;  RCP 4.5 = A future scenario with medium level of greenhouse gas reduction. Best estimate global temperature rise of 2.4 deg C by 2100;  RCP 6.0 = A future scenario with medium level of greenhouse reduction. Best estimate global temperature rise of 2.8 deg C by 2100;  RCP 8.5 = A future scenario where greenhouse gas emissions continue to grow unmitigated. Best estimate global temperature rise of 4.3 deg C by 2100.

115 Hereby known as the CABE Report. 116 CABE (n 112) pg 7. 82 | P a g e

For contextual purposes of the likely future scenario, the Paris Agreement signed in 2016 commits all Parties, including the UK, to try attempt to keeping a global temperature rise this century below 2 deg C. However, even if we take action on emissions soon, instituting immediately all of the commitments made in the Paris accords, we are still likely to get an average of 3.2 deg C of global warming by 2100.117

6

5

4

3

2

Change Change in Temperature(Degrees C) 1

0 2020s 2030s 2040s 2050s 2060s 2070s 2080s RCP 2.6 T50 RCP 2.6 T10 RCP 2.6 T90 RCP 4.5 T50 RCP 4.5 T10 RCP 4.5 T90 RCP 6.0 T50 RCP 6.0 T10 RCP 6.0 T90 RCP 8.5 T50 RCP 8.5 T10 RCP 8.5 T90

Source: Met Office UKCP18 PDF/CDF for Probabilistic Projections (25km) over UK, 1961-2100 Figure 62: Annual Mean Change Projections in Air Temperature in Doncaster

3.31 As can be seen, under current projections Doncaster, much like the rest of the UK and the globe, is expected to see a considerable annual mean increase in air temperature. If we used the T50 result for RCP 6.0, which under current greenhouse gas emissions reduction is a very likely scenario, the temperature could increase by 1.0 deg C by the 2030s, 1.5 deg C by the 2050’s and 2.4 deg C by the 2080s. Using the RCP 6.0 T50 scenario, the UKCP18 predicts that this temperature increase could be as high as 3.1 deg C by the 2080s in the summer months.

3.32 The effects of climate change are already being felt in Doncaster. In 2018 it was reported that there was a considerable surge in A&E visitors as the summer heatwave griped

117 David Wallace-Wells, The Uninhabitable Earth: A Story of the Future 2019, pg 11; Laurie Laybourn- Langton, Lesley Rankin and Darren Baxter, This is a Crisis: Facing up to the Age of Environment Breakdown Initial Report IPPR 2019, pg 7. 83 | P a g e

the borough; respiratory issues in particular soared.118 These temperature increases are a direct consequence of climate change with the Met Office stating that human-induced climate change made the 2018 record-breaking UK summer temperatures about 30 times more likely than it would be naturally.119 Therefore the predictions in Figure 62 would only exacerbate this phenomenon. Higher density areas will also contribute to the problem through the urban heat island effect.120 Without adequate ventilation within new dwellings, households will rely on electrical adaptations such as air-conditioning. This is particularly prevalent in higher density areas where there is increased noise pollution or concerns around safety, as households become reluctant to simply open a window to reduce internal heat.121 In turn this contributes to the urban heat island effect and overall greenhouse gas emissions, which then makes people increase their usage of air-conditioning and so on.

3.33 The minimum ceiling heights prescribed within the NDSS are therefore important and needed to ensure high quality new builds, especially in higher density developments, as well as protecting the health and well-being of residents in Doncaster. This is especially important in the context of Doncaster’s population demographics. The extent to which individuals are impacted by climate change and heat waves can be broken down into: exposure to the impact; sensitivity to the impact; and capability of adapting to the impact. It is therefore acknowledged that older people and those with mobility issues will be disadvantaged and at risk the most.122 As demonstrated earlier, it is projected that Doncaster’s population over 65 will increase by 19,900 people by 2035. High ceilings are therefore important to address overheating and ensure adequate ventilation,123 and provide a climate change adaptation to help combat the effects felt of the predicted increased temperature in Doncaster.

Occupancy of Dwellings

3.34 According to Julia Park one of the most compelling arguments for space standards is that it could lead us to live more efficiently.124 This is important under the context of climate change in Doncaster as provided above. Under-occupancy of current dwellings is a significant indicator of the lack of space within a property. When pressed on the number of bedrooms in new housing, developers acknowledged that a large proportion of second, third and fourth bedrooms are unlikely to be in regular use125 and therefore their size is

118 Doncaster Free Press, Surge in A&E visitors as heatwave grips Doncaster accessed 20 February 2019. 119 Met Office, Change of summer heatwaves now thirty times more likely accessed 20 February 2019. 120 The urban heat island effect is created by the thermal mass within a high density area through roads and buildings. Heat is absorbed into these structures and then slowly released; this keeps the temperature higher than what it would be otherwise. 121 Kevin Lomas and Stephen Porritt, Overheating in Buildings: Lessons from Research 2017, pg 3. 122 Living with Environmental Change, Heath Climate Change Impacts: Report card 2015 accessed 20 February 2019, pg 2. 123 Lomas (n 121). 124 Park (n 111) pg 72. 125 ibid. 84 | P a g e

inconsequential. As will be presented below this can be said to be true of the housing market in Doncaster, which helps produce a market driven cycle of under-occupancy. When this is accompanied alongside inadequate storage space, as highlighted in the Doncaster space size survey, households require spare bedrooms just to be comfortable. This, as Julia Park puts it, is a hugely inefficient way to live.

Bedrooms Doncaster Barnsley Rotherham Sheffield SCR Y&H Occupancy Rating +2 or more 47,959 35,458 39,889 78,341 281,079 784,372 (38%) (35%) (37%) (34%) (37%) (35%) +1 47,127 40,924 41,052 (38 78,912 284,508 819,567 (37%) (41%) %) (34%) (37%) (37%) 0 27,337 21,972 24,040 61,797 176,082 540,936 (22%) (22%) (22%) (27%) (23%) 24%) -1 3,520 (3%) 2,171 2,801 (3%) 9,209 21,494 68,264 (2%) (4%) (3%) (3%) -2 or less 544 (0%) 209 (0%) 511 (0%) 1,669 3,357 10,920 (1%) (0%) (0%) Total 126,487 100,734 108,293 229,928 766,520 2,224,059 Source: 2011 Census (Data Extracted from the 2015 Doncaster Housing Needs Survey) Figure 63: Bedroom Occupancy Rating

3.35 In comparison to other areas, there is a higher case of extreme under-occupancy in Doncaster with 38 percent of households having two or more unused bedrooms. By applying the NDSS to Doncaster, it seems highly plausible that any increased storage space and bedroom standards in general would help reduce the inclination to accumulate bedrooms in such a manner. This in turn would encourage people to downsize properties as they get older or children move away from home, without necessarily the need to sacrifice internal storage or space. This would free up existing stock within Doncaster, creating a more efficient housing market.

Storage

3.36 As demonstrated during the sample survey, current new builds in Doncaster have inadequate storage space in comparison to the minimum requirements set out in the NDSS. Inadequate internal storage space has consequential effects on the layout of developments and the quality of the external residential environment. Insufficient internal space and storage space increases the pressure for residents to utilise alternative spaces for the storage of large amounts of household items associated with modern life. In addition to utilising the 'spare bedroom' and therefore under-occupying dwellings as discussed above for storage, this can often lead to garages not being used for the designed intended purposes of vehicle and cycle storage. This can force vehicles to park outside on street or pavements close to the property resulting in car dominated street scenes and restricting the usability of footpaths and utility of

85 | P a g e

the public highway. A lack of space for cycles can discourage their ownership and use, with negative consequences for public health and sustainable active travel.

Overcrowding

3.37 Inadequate space standards and storage can have a negative impact upon individuals’ health and well-being, as well as educational attainment and anti-social behaviour. Various reports have tried to outline these and some can be applied to contextual information for Doncaster. The lack of space in dwellings can lead to those who cannot afford to under- occupy to live in overcrowded conditions. As shown with the bedroom occupancy rating, overcrowding is not a specific problem in Doncaster per say, however the HNS calculated that 3,734 out of 129,818 households (2.9 percent) were in over-crowded housing in Doncaster using the ‘bedroom standard’ model.126 As well as dealing with current housing quality issues, the NDSS will help prevent a future reduction of market standards and therefore quality as described in paragraph 3.27. As such analysing issues associated with overcrowding is important for evaluating the need for the standards in Doncaster.

Education

3.38 According to both the CABE report and the RIBA report, overcrowding and poor housing conditions result in educational underachievement, with less space for private study.127 This was supported in a report produced by Shelter which states that overcrowding causes reading and homework to be more difficult and consequently cause harm to a child’s education.128 Applying this to specific cases in Doncaster is not possible, however the average attainment 8 score for Doncaster can be compared to the regional and national average to determine whether education is an issue for the borough. The average attainment 8 score measures the average achievement of pupils in up to eight qualifications at GCSE level with points allocated according to grades.

126 HNS (n 52) pg 150 (page reference subject to the publication version of the HNS). 127 CABE (n 112) pg 7; RIBA (n 94) pg 13. 128 Shelter, Full House? Overcrowded Housing Affects Families 2005, pg 21. 86 | P a g e

52

50

48

46

44

42

40

38 2015/16 2016/17 2017/18

Doncaster SCR Y&H England

Source: Department for Education (Data Extracted from Local Government Association LG Inform) Figure 64: Average Attainment 8 Scores over the last Three Academic Years

3.39 Over the past few years, the average attainment 8 scores have fallen, with the exception of a slight increase for the England average in 2017/18, with Doncaster performing worse than regional and national averages. This indicates that educational attainment up to KS4 is below average in Doncaster. Because the score is an average for the borough, it cannot be compared to dwellings with low space standards. However, due to the area’s evidenced low educational achievement rates supporting influencing factors to education, such as adequate space for children amongst the home should be pursued.

Health and Well-being

3.40 Adequate space standards also helps promote general health and well-being. BRE published a briefing paper into the Cost of Poor Housing to the NHS in 2015. Using data from the EHS and a cost analysis model, BRE estimated that overcrowding cost the NHS £21,815,546 per year. The Shelter report into overcrowding also found negative impacts on health, in particular overcrowding contributing to mental health related issues, disturbed sleep, accidents around the home, and the risk of illness spreading quicker. Whilst there is no data to apply this specifically to Doncaster, promoting the health and well-being of the citizens within the borough is a high policy priority for the Council. Figures 33 and 34 showed the health and living environment deprivation domain’s across Doncaster. Reducing overcrowding and the subsequent impacts on the health service outlined in the BRE and Shelter reports will help ensure those deprivation domains levels are reduced.

Houses in Multiple Occupation

3.41 The emergence of Houses in Multiple Occupation (HMOs) in Doncaster highlights an indirect need for space standards in the borough. HMOs are dwellings that have been changed to allow numerous occupants to normally rent rooms and share communal facilities.

87 | P a g e

These are typically houses where the individual bedrooms are rented. There must be a consideration that houses built during the plan period could therefore be used as a HMO at some point in the future. It is therefore important to ensure that bedrooms in particular are of adequate size to prevent overcrowding and to allow those individuals to have a good standard of living.

3.42 From 1st October 2018, HMOs licensed in England under part 2 of the Housing Act 2004 are bound by space conditions. These were introduced by the Licensing of Houses in Multiple Occupation (Mandatory Conditions of Licenses) Regulations 2018, which states the minimum that the floor area of any rooms in a HMO used as sleeping accommodation can be. In comparison to the NDSS, the conditions required through the HMO regulation are smaller. This means that through applying the NDSS to all new dwellings, those built after adoption would be adequate enough to meet the bedroom size requirements if they were converted to a HMO at a later date and required a license.

3.43 By introducing the NDSS, it would also mean that any new dwellings that was converted to a HMO that did not require a licence, and therefore was not legally bound by the conditions set out in the HMO regulation, would have adequate floor area sizes, which would reduce the prevalence of overcrowding and unsafe occupation. The Council’s Enforcement Team has found that a large proportion of the small non-licensable HMOs that they visit are usually too small for safe occupation and/or are overcrowded. This has resulted in a substantial increase in concerns raised by residents in respect of over occupation, overcrowding and anti-social behaviour resulting from cramped housing conditions.129 By application of the NDSS to new builds in the borough, any future use of the dwellings for the purposes of becoming a HMO would ensure that there is adequate space for the occupants regardless of if they required a license or not. Doing so is important for the future concerns of HMOs and their impacts on those living in them and their surrounding communities.

Accessible and Adaptable Dwellings

3.44 The NDSS are also closely linked to the accessibility and adaptability of dwellings and therefore highly relevant to the work undertaken in section 2 of this report. The Government’s Housing Standards Review Consultation Implementation Impact Assessment considered the findings from the EC Harris report. EC Harris estimated the process costs associated with the accessibility standards commented upon earlier. They found that significant savings in process cost would occur due to the link between accessibility and space standards.130 The gross internal area specifications required in the NDSS would be adequate for the M4(2) optional building regulations and as such the introduction of both policies alongside each other will reduce development costs. It is acknowledged that the

129 Doncaster Council, Additional Licensing and Article 4 Direction Consultation Document 2017, pg 4. 130 DCLG, Housing Standards Review Consultation: Impact Assessment, para 126. 88 | P a g e

specifications would not be adequate enough for the M4(3) wheelchair adaptable optional building regulation.131

3.45 The CABE report outlines adaptability as one of the key benefits of space standards.132 This as the report acknowledges, is because larger floor spaces are inherently more adaptable and offer greater potential for rearrangement.133 Additional space for storage also makes for a less cluttered living space, which makes homes better suited to people with mobility impairment. All of which ensures that new housing is sustainable and can meet the changing demands of its residents: homes will become future proof. In the context of Doncaster, this is extremely important due to the evidence provided in section 2 of this report.

3.46 Space is also a key consideration for older people, one of the biggest emerging demographics in Doncaster. The HAPPI principles for the design of new retirement homes states that ventilation, generous internal space standards and homes designed to new technologies can be readily installed are key to meet older people’s housing need.134 Whilst this is targeted towards retirement homes, the emergence of older people wanting to live at home independently means that the principles become important for the development of all new market dwellings.

Summary

3.47 The purpose of this section has been to highlight the need for the NDSS policy in the emerging Local Plan. Currently, on average new dwellings built in the UK and in particular Y&H are significantly smaller than developments in Europe despite similar issues and restrictions.

3.48 By undertaking a sample survey of current new dwellings and their floor plans only 23 out of 246 dwellings would meet the NDSS as proposed. 201 out of the 246 plans assessed met the gross internal floor area based on their proposed number of bedrooms. Plans were more likely to fail against the NDSS based on storage space or bedroom size, highlighting an internal design issue as opposed to dwelling plot size.

3.49 The Plan’s approach is to adopt a higher housing target per annum than needed as per the standard methodology. As a result, one argument against applying the NDSS is that in doing so housing densities, and therefore the housing target would be affected. However, research indicates that for densification to prove successful it needs to be matched by high quality homes. In any case, the Council’s sample survey shows that individual housing plots need not be increased to hit the NDSS, but the internal design of housing types be adapted to meet the NDSS.

131 DCLG (n 103) para 9. 132 CABE (n 112) pg 9. 133 ibid. 134 Policy Exchange (n 59) pg 32. 89 | P a g e

3.50 The NDSS produces a minimum standard for ceiling height in each dwelling. Ceiling height is an important factor for adequate ventilation, which is important considering the future impact of climate change and the urban heat island effect that increased housing brings. In Doncaster, it is predicted that under current emission reduction targets the borough would be on average 2.4 deg C warmer, and 3.1 deg C warmer in summer months by 2080.

3.51 In Doncaster there is a high rate of under-occupancy with 38 percent of households having two or more unused bedrooms. Applying the NDSS would allow adequate storage space and all bedrooms to be of habitable size. This means households could buy properties intended for their household composition, without the risk of a lack of storage space and therefore having to use spare bedrooms, garages or general living space.

3.52 Overcrowding of dwellings that can occur from lack of appropriate space for intended households in a property has certain negative impacts. Overcrowding can have implications for education, health and the usage of HMOs. In Doncaster the average attainment 8 score has declined in recent years and is below the regional and national averages. The borough also experiences high levels of health and living environment deprivation. HMOs can produce overcrowded and dangerous accommodations that have been commented upon by Council officers.

3.53 It is recognised by the Government that the NDSS are inherently linked with adaptable and accessible dwellings, with larger floor spaces easier to adapt. The size requirements in the NDSS are also adequate enough to meet the requirements in the M4(2) optional building regulation.

90 | P a g e

3.54 Viability

3.54 The NPPF requires the planning system to take account of development viability when deciding planning applications and preparing the Local Plan. As such sites identified in the plan must be deliverable by avoiding a scale of policy requirements that together risks their ability to be developed.

Viability Testing

3.55 As well as considering the optional building regulations analysed earlier on in this report, the Government’s Final Implementation Impact Assessment of the Housing Standards Review and the EC Harris Cost Impact Study that it was supported by analysed the NDSS. The Tables below have been taken by the EC Harris study and show the cost implications per additional m2 of introducing the NDSS.

Source: DCLG and EC Harris Housing Standards Review: Cost Impacts 2014 Figure 65: Cost Impact of Nationally Described Space Standards

91 | P a g e

3.56 The council’s Viability Study 16, tested the policy requirement of all new buildings be built to the NDSS. Due to the time elapsed since the original testing and the subsequent changes in building costs since then, an updated assessment was conducted in 2019 to evaluate whether anything had changed since.

3.57 Using the space requirements for the different dwelling size scenarios in the NDSS, the original Viability Study 16 adopted a higher average house size than normally considered as part of a Local Plan viability study.135 This was applied to all dwellings across the different type of sites assessed. The Viability Study concluded that under the different scenario tests, the application of the NDSS to all dwellings had an insignificant impact on the viability of schemes.136 The Viability Study 19 incorporated the same house size presumptions as the Viability Study 16 and found again, that the standard had an insignificant impact on the viability of schemes.137

3.58 As mentioned in paragraph 3.23, the majority of the dwellings assessed as part of the space standards survey met the required gross internal floor area for the number of proposed bedrooms and storeys on the plan. When this is assessed concerning viability, this means that the majority of the dwellings did not need to be bigger, and therefore the costs associated with additional space in Figure 65 have no impact. Instead, the internal design of the dwelling means that either inadequate storage space or bedroom size for all dwellings resulted in many developments failing across all criteria of the NDSS. To combat this design team costs associated with internal re-design may be incurred by developers, but these are likely to be relatively insignificant and for the case of standard house designs a one off process which can therefore be used throughout the country.

3.59 Using the EC Harris Impact Assessment Report, the potential costs revolving around developing designs and checking compliance with the standard has been considered. It is these costs that the majority of dwelling plans surveyed would have to undertake to become complaint with the NDSS. The EC Harris Report breaks down the predicted cost by development size, estimating costs per dwelling type normally associated with a development of that size and then costs per dwelling.

135 DVS (n 73) pg 29. 136 ibid pg 71. 137 CP Viability Ltd (n 74) 138. 92 | P a g e

Source: DCLG and EC Harris Housing Standards Review: Cost Impacts 2014 Figure 66: Design Team Costs per Development Size

3.60 As can be seen, the estimated design costs per dwelling is small, especially when evaluated against the additional space costs in Figure 65. In fact, the design costs may be even lower when applied by national or regional developers. As more local authorities adopt the NDSS, developers have to adopt dwelling type designs that incorporate the specific standards required. The general layout of these dwellings can therefore be applied to developments in other local authorities as and when they also adopt the standards.

Affordability

3.61 There has to be some consideration taken for the impact of applying the NDSS to new dwellings on affordability. The affordability of housing in the borough was considered in the most recent HNS. In terms of relative affordability, Doncaster is the seventh most affordable local authority out of the thirteen areas listed in the HNS. Similarly, in terms of relative affordability based on median prices, Doncaster is the fifth most affordable local authority area.138 The Viability Report 19 concluded that the affordability of housing in Doncaster

138 HNS (n 52), pg 30 (page reference subject to the publication version of the HNS). 93 | P a g e

relative to other locations in South Yorkshire meant buyers are likely to be able to afford larger dwellings for their money.139

3.62 When considering how the NDSS would influence the affordability of housing mentioned above, it is important to consider how close the current new builds are to meeting the standard. This can be split into three different categories:  Those meeting the requirements of the NDSS;  Those meeting the gross internal floor area of the NDSS but failing on at least one of the other requirements; and  Those failing to meet the gross internal floor area of the NDSS.

For those developments already hitting the NDSS across all of its requirements, there would be no additional cost incurred and subsequently no increase in affordability for buyers. For those developments that are meeting the minimum NDSS requirements for the gross internal floor area despite not meeting the requirements for storage space and/or bedroom sizes, they would incur a small increase in cost. As explained in paragraphs 3.57-3.59, additional plot size will not be required for these developments to meet the NDSS, and any cost would be associated with design. On medium and large developments this would only account to an estimated £8/dwelling, and on small developments £36/development. This should result in no impact to affordability for buyers.

3.63 A minority of developments fall into the third category explored (45 out of 246 dwellings surveyed). These are plots where there would need to be an increase in space and subsequently additional space costs would be incurred. When analysing Figure 65, a three bed that required an additional 3m2 would cost a developer £381 after space cost recovery. The space cost recovery is based on the presumption of 80 percent of the sales cost would be recovered through sales value. This would mean a value increase of £1,515 passed on to the buyer. Given that new build three bedroom semi-detached properties in Doncaster are generally likely to be sold between £102,995 and £174,999140, a figure of £1,515 represents a very small increase; 1.47 percent - 0.87 percent. Also by purchasing a property that is more inherently flexible and appealing to the market due to meeting the NDSS, an owner may be prepared to offset the marginal cost increase in some case cases for increased saleability.

3.64 For those developments that require a bigger increase in space area there would inevitably be a greater impact upon affordability. According to the EC Harris report, the space cost recovery decreases to 60 percent as the area change increases to 10m2 required. If an assumption of an 80 percent space cost recovery was considered, this would mean a value increase of £5,056 passed on to the buyer. Using the same house values presented above, this would represent an increase of 4.9 percent – 2.89 percent. This would still produce a small, although slightly more significant increase to affordability. The dwelling that fell shortest against the NDSS, would require an additional 23.65m2. Doing so would affect affordability

139 CP Viability Ltd (n 74) 58. 140 Based on listings in Doncaster on 25/02/2019. 94 | P a g e

significantly, especially compared to the sites 10m2 or smaller away. There was only two dwelling types that measured over 20m2 away from the NDSS area required, with the majority of the 45 dwelling types surveyed that failed to meet the NDSS gross internal floor areas being below 10m2 away.

3.65 When considering the link between space standards and affordability, Shelter argued that weakening space standards would not necessarily make homes cheaper anyway, just smaller. Shelter argued that house prices are set by sky-high demand for homes in the right location and therefore building smaller would simply mean buyers get less for their money141 as they will still be bound by high costs due to location. According to the HNS, average house prices in Doncaster fluctuate drastically by ward and therefore follows the argument presented by Shelter. Figure 67, extracted from the HNS, shows that the average house prices in the cheapest wards are below £100,000, whilst in contrast the most expensive average price wards are above £140,000.

Source: Housing Needs Survey Figure 67: Median House Prices 2017 by Ward

3.66 Building new dwellings to the NDSS may also change the reasons behind why households buy certain properties, and thus allow the opportunity to buy houses with less bedrooms which would notoriously be more affordable. According to Julia Park, there is a tendency to measure social standing by how many bedrooms we have which is reinforced by the way that homes are currently valued for mortgage purposes.142 As explained in paragraphs 3.34-3.36, developers acknowledge that in many circumstances the final bedroom

141 Shelter, Weakening Space Standards won’t make Homes Cheaper – Just Smaller accessed 7 February 2019. 142 Park (n 111) 72. 95 | P a g e

in a house is not used for living purposes, and in Doncaster under-occupancy of dwellings is common. The NDSS will help provide adequate storage to new builds, meaning less cluttered rooms and potential reducing the need for an extra bedroom. According to the HNS, many households in Doncaster aspire to have less number of bedrooms.

Number of Bedrooms Demographic Aspiration (%) Expectation (%) Baseline (%) 1 8.3 22.4 5.6 2 19.4 37.6 44.8 3 52.6 46.1 42.2 4 19.7 -6.1 7.5 Total 100.0 100.0 100.0 Source: Housing Needs Survey Figure 68: Dwelling Size Scenario

3.67 In turn this would allow households the option to buy a new dwelling with the number of bedrooms they need to occupy their household size, knowing there is adequate storage space provided. Buying dwellings with less bedrooms than households may have previously had to buy would reduce the amount households are spending on buying their own property, allowing people to get more for their money.

Summary

3.68 The above section considers the impact on viability by the introduction of the NDSS.

3.69 The Council’s commissioned Viability Study considered the policy position of 100 percent of all new dwellings been built to the NDSS. Under different sensitivity analysis this was found to pose no viability issues. A new Viability Study is currently being commissioned and will consider the same percentage of new dwellings for the policy requirement.

3.70 The impact on affordability would differ depending on how far the current design is off the standard. In Doncaster, the sample survey indicated the vast majority of dwellings would only need internal design changes to meet the NDSS, and thus there would be non-to little extra cost incurred by the developer or buyer. Dwellings that were found to require an additional 3m2 to meet the NDSS floor area plan would potentially increase house prices by 0.87 percent – 1.47 percent, whilst dwellings found to require an additional 10m2 would potentially increase house prices by 2.89 percent – 4.9 percent. Whilst affordability impacts in Doncaster depends on how much floor space would be required, the vast majority did not need additional space and those that did, did not require much.

3.71 The benefit of increased storage space and bigger sized bedrooms could allow some households to buy a house with a bedroom less than they would original look for. This would match the size aspirations of Doncaster residents with houses with less bedrooms which typically cost less on the open market.

96 | P a g e

3.72 Timing

3.72 As explained in the NPPG, there may need to be a reasonable transitional period following adoption of the NDSS to enable developers to factor the cost of space standards into future land acquisitions.143 The NPPF states that local authorities may give weight to relevant policies in emerging plans according to the stage of the emerging plan, the extent to which there are unresolved objections to relevant policies and the degree of consistency of the relevant policies in the emerging plan to the NPPF.144

3.73 The emerging Local Plan is still to be formally submitted and examined during inspection. As such, the policy in question does not hold any formal weighting at the time of this evidence base. However, the Council’s decision to produce the evidence required to adopt the optional NDSS has been made clear to the development industry with the inclusion of the policy during an informal Local Plan consultation. This consultation took place in autumn 2018, and included the requirement for all new dwellings to be built to the NDSS. Consultation responses were recorded from the Home Builders Federation and developers highlighting their acknowledgment of the policy.

3.74 The space standards survey evaluated above shows that the majority of new builds in Doncaster already meet the gross internal space standard required for the number of bedrooms proposed on its plan. The reason a development was more likely to fall short of the NDSS was storage space or bedroom size, showing that the internal design of the internal floor area would need to be improved. As such, it is felt that the introduction of the standards would not reduce housing densities upon sites and have little to no impact on land acquisitions due to the minimal design costs required to ensure the NDSS is met. This is felt to be appropriate considering that other local authorities are adopting the standard as part of their Local Plans. Designs used by developers in other authorities to meet their NDSS requirement can be transferable across local authorities. This is recognised in the NPPG, where it states that planning authorities should accept evidence from either a building control body or another planning authority that has already assessed plan layouts that they meet the requirements.145

3.75 However, it is accepted, especially in relation to local or smaller developers that for some developments space standards may have an impact that would need to be considered and the policy wording will allow for this. This is equally considered under any potential economic pressure as a result of the UK’s impending planned departure from the European Union. Despite this, in light of the arguments presented above and the Council's inclusion of the policy in the informal consultation on the Plan, the Council feels that the exclusion of a transitional period is justified. To help assist developers Council Officers will be available to answer any questions with relation to the application of the NDSS.

143 NPPG (n 30) para 020, Ref ID 56-020-20150327. 144 NPPF 2019 (n 1) para 48. 145 NPPG (n 30) para 023, Ref ID 56-023-20160519. 97 | P a g e

3.76 The Case for Introducing the Standards

3.76 The Council considers that based on the evidence presented above that there is a strong need to introduce the NDSS. It is put forward that 100 percent of all new dwellings should meet the NDSS as a minimum. Exemptions to the policy will only be considered where the applicant can robustly demonstrate, with appropriate evidence, that adhering to the standards is not feasible due to physical constraints, or it is demonstrated that it is not viable to do so. Any deviation must be robustly justified and offset through exceptional or innovative design.

3.77 The evidence presented in this paper demonstrates the need for better designed and higher quality dwellings in Doncaster. The results of the sample survey indicate that, generally, dwellings within the borough have big enough plot sizes to meet the floor area set out in the NDSS for the number of bedrooms they are proposing. The research indicates that there is a low overall compliance with the NDSS measurements in terms of the internal configuration of dwellings, such as storage space and bedroom sizes. It is clear that minor adjustments, notably at the design stage, could be made to the internal layouts of plans to achieve NDSS compliance.

3.78 Minimum size requirements help ensure that quality is not sacrificed to for plot density. Doncaster’s aspirational Inclusive Growth Strategy and high housing rate target means arguments could be made from a developer point of view that space standards restricts this growth, however the Council’s survey highlights plot sizes need not be increased and compliance with the NDSS can be easily achieved at design stage. There is sufficient land allocated for housing in the Local Plan to meet Doncaster's needs.

3.79 External research and the Government’s assessment of the NDSS highlights other societal benefits to adopting minimum space standards for dwellings. Some of these can be directly considered in the context of Doncaster. Set minimum ceiling heights would help increase air ventilation and day light through new dwellings, reducing the risks of the urban heat island effect on households and helping increase adaptability in the face of predicted temperature increases. It is widely acknowledged in the development industry that the final bedroom in a house is unlikely to be used for habitation. Under-occupancy of dwellings is a prevalent issue in Doncaster and as shown in the survey current new builds has insufficient designated storage space, and bedrooms frequently too small to live in. This helps create a culture of buying more bedrooms than needed so the ‘spare’ room can be used for storage purposes. Allowing standards in Doncaster would therefore provide fit for purpose houses, giving the market the option of buying for their household size, which in turn would mean prospective buyers being able to get more for their money.

3.80 On the other end of the spectrum, the absence of minimum standards could lead to overcrowded housing which has profound impacts on education, health, and the impact of HMOs. Educational attainment is poor within Doncaster, with attainment 8 scores in the

98 | P a g e

borough lower than regional and national averages. Overcrowding costs the NHS an estimated £21,815,546 per year. Health and quality of housing deprivation is higher in Doncaster than the majority of local authorities in the country, indicating the impact of housing and health in the borough and adopting space standards will help solve this issue. The emergence of HMOs in Doncaster as a flexible way to live produces certain negative consequences with a link between overcrowding and anti-social behaviour, health and quality of life of those renting in a HMO. Considering the fact there is every chance new dwellings may be converted to a HMO in the future, ensuring that rooms and space is of a high quality is essential to ensure issues of overcrowding decrease in the future.

3.81 The Council as demonstrated during section 2 of this report, are aiming to adopt the optional building regulations for accessible and adaptable dwellings. Adopting the NDSS alongside M4(2) standards produces significant process cost reductions as the size requirements within the NDSS would be acceptable for the size requirements in the M4(2) standard.

3.82 The policy has been robustly evaluated through the Council’s Viability Study 16 and 19 that found the application of requiring all new dwellings meet the standards within the NDSS would not make sites unviable. Affordability is a key consideration made by the Council with the introduction of this policy. Currently, house prices in Doncaster are amongst some of the most affordable in the region and through using the sample survey, the introduction of the NDSS should incur insignificant increase to house prices if at all. As mentioned, most plans surveyed already had big enough floor area sizes to meet the standards. Any change in the plans was to the interior of the property and could be remedied at design stage. These costs are minimal and property prices will not need to be increased to take account of it. Any potential costs would occur when plot sizes needed to be increase, which in Doncaster is the exception not the norm. An additional 3m2 would only produce an estimated 0.87 – 1.47 percent increase, whilst an additional 10m2 would only produce an estimated 2.89 – 4.9 percent increase. As evidenced this is the exception not the norm, with only a minority of developers building new dwellings vastly smaller than the standards.

3.83 As summarised in this conclusion, it is imperative to ensure that minimum standards are applied in Doncaster so high quality, fit for purpose dwellings are built. Without the policy, dwellings will continue to be built without adequate storage and box rooms, meaning residents forced to buy more bedrooms than they actually need, or risk living in uncomfortable and unfit surroundings. The Council acknowledges that not everyone will require housing of this type, and micro-housing developments will only be considered in exceptional and clearly evidenced situations where there is an identified and proven need and demand. However, to ensure that Doncaster is an attractive and healthy place to live, a minimum quality must be ensured for the borough’s current and potential residents. As such, the Council finds it appropriate and justified to require that all new dwellings be built to the NDSS.

99 | P a g e

4.0 Appendixes

Appendix 1 – Statistical data used to produce map data

Data for Figures 29 and 30

WARD 65+ in that area % 65+ in that % Ranking area Adwick le Street & 2,547 15.36 19 Carcroft Armthorpe 2,837 19.50 10 Balby South 1,925 19.32 11 Bentley 2,880 15.89 18 Bessacarr 3,548 23.73 3 Conisbrough 3,123 18.90 14 Doncaster Total 58,002 18.77 Edenthorpe & Kirk 2,037 20.09 8 Sandall Edlington & 2,267 19.17 12 Warmsworth Finningley 3,626 22.30 5 Hatfield 3,399 18.97 13 Hexthorpe & Balby 1,546 11.42 21 North Mexborough 2,704 17.40 16 Norton & Askem 3,314 22.23 6 Roman Ridge 2,213 20.25 7 Rossington & Bawtry 3,474 19.97 9 Sprotbrough 2,700 24.53 1 Stainforth & Barnby 2,317 23.62 4 Dun Thorne & Moorends 3,298 18.86 15 Tickhill & Wadsworth 2,651 24.12 2 Town 2,588 11.57 20 Wheatley Hills & 3,008 16.58 17 Intake

100 | P a g e

Data for Figures 31 and 32

WARD Activities % Activities % Ranking Limited a Little Limited a Little or a Lot or a Lot Adwick 3,842 24.1 4 Armthorpe 3,146 21.8 11 Askem Spa 3,140 24.2 3 Balby 2,924 19.1 18 Bentley 3,207 22.6 8 Bessacarr and Cantley 3,027 21.0 13 Central 3,692 20.3 16 Conisbrough & Denaby 3,763 26.3 1 Doncaster Total 65,535 21.7 Edenthorpe, Kirk 2,538 19.0 19 Sandall and Barnby Dun Edlington & 3,017 22.1 10 Warmsworth Finningley 2,669 17.5 21 Great North Road 3,133 20.7 14 Hatfield 2,967 22.2 9 Mexborough 3,832 25.1 2 Rossington 3,087 22.8 7 Stainforth and 3,116 23.0 6 Moorends Sprotbrough 2,109 17.8 20 Tome Valley 2,517 20.6 15 Town Moor 2,881 20.0 17 Thorne 3,806 23.5 5 Wheatley 3,122 21.2 12

101 | P a g e

Data for Figure 48

WARD Private Social Total Accommodation Accommodation (%) (%) Adwick 943 (59.8) 634 (40.2) 1,577 Armthorpe 1,233 (77.1) 367 (22.9) 1,600 Askem Spa 1,277 (80.9) 302 (19.1) 1,579 Balby 1,000 (70.5) 419 (29.5) 1,419 Bentley 1,025 (66.4) 519 (33.6) 1,544 Bessacarr and Cantley 1,725 (81.1) 402 (18.9) 2,127 Central 944 (63.9) 533 (36.1) 1,477 Conisbrough & Denaby 974 (59.4) 665 (40.6) 1,639 Edenthorpe, Kirk 1,544 (88.9) 193 (11.1) 1,737 Sandall and Barnby Dun Edlington & 1,233 (76.3) 384 (23.7) 1,617 Warmsworth Finningley 1,674 (92) 146 (8) 1,820 Great North Road 1,389 (79) 369 (21) 1,758 Hatfield 1,290 (85.3) 223 (14.7) 1,513 Mexborough 1,078 (65.1) 579 (34.9) 1,657 Rossington 960 (70.2) 407 (29.8) 1,367 Sprotbrough 1,517 (96) 64 (4) 1,581 Stainforth and 1,009 (72.1) 391 (27.9) 1,400 Moorends Thorne 1,422 (79.3) 372 (20.7) 1,794 Tome Valley 1,744 (87.2) 255 (12.8) 1,999 Town Moor 1,234 (78.4) 340 (21.3) 1,574 Wheatley 1,011 (74.1) 353 (25.9) 1,364

102 | P a g e

Data for Figure 50

WARD Private Social Total Accommodation Accommodation (%) (%) Adwick 2,347 (63.1) 1,373 (36.9) 3,720 Armthorpe 2,298 (76.7) 697 (23.3) 2,995 Askem Spa 2,390 (79.6) 611 (20.4) 3,001 Balby 1,901 (66.5) 957 (33.5) 2,858 Bentley 2,117 (67.8) 1,006 (32.2) 3,123 Bessacarr and Cantley 2,227 (76.7) 676 (23.3) 2,903 Central 2,244 (64.3) 1,244 (35.7) 3,488 Conisbrough & Denaby 2,077 (57.2) 1,557 (42.9) 3,634 Edenthorpe, Kirk 2,212 (87.7) 310 (12.3) 2,522 Sandall and Barnby Dun Edlington & 2,252 (75.8) 720 (24.2) 2,972 Warmsworth Finningley 2,270 (88.2) 303 (11.8) 2,573 Great North Road 2,415 (86.4) 380 (13.6) 2,795 Hatfield 2,197 (87.3) 320 (12.7) 2,517 Mexborough 2,340 (63.6) 1,342 (36.4) 3,682 Rossington 2,098 (71.8) 823 (28.2) 2,921 Sprotbrough 1,921 (94.5) 111 (5.5) 2,032 Stainforth and 2,063 (67.6) 990 (32.4) 3,053 Moorends Thorne 2,527 (76) 800 (24) 3,327 Tome Valley 1,986 (83.3) 399 (16.7) 2,385 Town Moor 1,922 (69.5) 845 (30.5) 2,767 Wheatley 1,645 (65.5) 868 (34.5) 2,513

103 | P a g e

Appendix 2 – Map of the high, medium and low value viability areas in Doncaster

104 | P a g e

Appendix 3 – NDSS Survey Sample

Location House Type (number Storage Space National Storage Internal Gross Floor National Floor Area (Applicant/Developer) of storeys) Measured (m2) Space Standard Area Measured (m2) Standard Required Required (m2) (m2) One Bedroom Briars Lane, Stainforth (One) 0.8 1 41.15 39 (Prospect Estates Ltd) Kirby Ave, Bentley (Gr33n Type 4 (One) 1.7 1 34.37 39 Homes Ltd) Belle Vue, Bawtry Road Apartment 1a (One) 1.5 1 44.9 39 (Barratt Homes) Belle Vue, Bawtry Road Apartment 1b (One) 1.5 1 47.2 39 (Barratt Homes) Mill Street, Armthorpe C (One) 1.07 1 55.76 39 (Swan Homes) 278 Bawtry Road (Murvic Top Ground Floor (One) 0 1 87.05 39 Properties) 278 Bawtry Road (Murvic Bottom Right (One) 0 1 83.9 39 Properties) 278 Bawtry Road (Murvic Left Middle (One) 0 1 64.91 39 Properties) Bloomhill Court, Moorends A (Two) 1 1 82.48 39 (D Noble Ltd) 278 Bawtry Road (Davis Apartment 4 (One) 1.14 1 45 39 Highes) 278 Bawtry Road (Davis Apartment 7 (One) 0 1 45 39 Highes) Granby Inn High Street, A2 (One) 0.75 1 51.5 39 Bawtry (Ground Properties) Granby Inn High Street, A1 (One) 3.4 1 56.6 39 Bawtry (Ground Properties) Tickhill Road, Bawtry Apartment 1 (One) 0 1 49.85 39 (McCarthy & Stone)

105 | P a g e

Location House Type (number Storage Space National Storage Internal Gross Floor National Floor Area (Applicant/Developer) of storeys) Measured (m2) Space Standard Area Measured (m2) Standard Required Required (m2) (m2) Tickhill Road, Bawtry Apartment 17 (One) 0 1 50.07 39 (McCarthy & Stone) Tickhill Road, Bawtry Apartment 5 (One) 0 1 60.82 39 (McCarthy & Stone) Tickhill Road, Bawtry Apartment 23 (One) 0 1 46.34 39 (McCarthy & Stone) Two Bedrooms Athelstance Crescent Hadleigh (Two) 1.6 2 74 70 (Harron Homes) King Edward Rd, Thorne 201 (Two) 0.83 2 60.48 70 (Gleeson) King Edward Rd, Thorne 202 (Two) 1.52 2 62.37 70 (Gleeson) Brairs Lane, Stainforth A (Two) 1.75 2 63.2 70 (Prospect Estates Ltd) Brairs Lane, Stainforth A1 (Two) 1.75 2 72.3 70 (Prospect Estates Ltd) Brairs Lane, Stainforth F (One) 1.2 2 53.65 61 (Prospect Estates Ltd) Brairs Lane, Stainforth J (One) 0.85 2 64.1 61 (Prospect Estates Ltd) Brairs Lane, Stainforth Apartment (One) 1.7 2 62.75 61 (Prospect Estates Ltd) Station Road, Askern (Mr Apartment (One) 1.45 2 57.55 61 Richard Sharp) Belle Vue, Bawtry Road Apartment 2 (One) 1.6 2 63 61 (Barratt Homes) Belle Vue, Bawtry Road Alysham (One) 0 2 64.7 61 (Barratt Homes) Kirk Street, Hexthorpe Askham (Two) 1.8 2 54.85 70 (Persimmon Homes) Kirk Street, Hexthorpe Morden (Two) 0 2 47.85 70 (Persimmon Homes)

106 | P a g e

Location House Type (number Storage Space National Storage Internal Gross Floor National Floor Area (Applicant/Developer) of storeys) Measured (m2) Space Standard Area Measured (m2) Standard Required Required (m2) (m2) Kirk Street, Hexthorpe Flat B (One) 0.65 2 59.85 61 (Persimmon Homes) Station Road, Blaxton A (Two) 1.5 2 57.06 70 (Mandale Homes) Old Bawtry Rd, Finningley Greenwich (Two) 1.7 2 67.28 70 ( Homes Ltd) Carr House Rd, Belle Vue HL70 (Two) 2.3 2 72.79 70 (Hoober Ltd) Carr House Rd, Belle Vue HL70A (Two) 2.3 2 72.79 70 (Hoober Ltd) Woodfield Way, Balby T1 (Two) 1.64 2 76.33 70 (Strata Homes Ltd) Woodfield Way, Balby T1e (Two) 1.64 2 76.33 70 (Strata Homes Ltd) Woodfield Way, Balby 659 Ilke Holden (Two) 1.25 2 61.56 70 ( Homes) Woodfield Way, Balby 680 Apt Blk B (One) 1.68 2 62.03 61 (Keepmoat Homes) Woodfield Way, Balby 690 Apt Blk BC (One) 2.11 2 64.06 61 (Keepmoat Homes) Woodfield Way, Balby 690 Apt Blk BC1 (One) 2.11 2 64.06 61 (Keepmoat Homes) Woodfield Way, Balby 703 Apt Blk G (One) 2.17 2 65.18 61 (Keepmoat Homes) Woodfield Way, Balby 740 (Two) 2.16 2 69.11 70 (Keepmoat Homes) Woodfield Way, Balby 748 (Two) 1.36 2 69.74 70 (Keepmoat Homes) Woodfield Way, Balby 863 (Two) 1.69 2 73.39 70 (Keepmoat Homes) Woodfield Way, Balby 872 Ilke Holt (Two) 2.6 2 81.19 70 (Keepmoat Homes) Woodfield Way, Balby Apt Blk BD (One) 2.1 2 73.22 61 (Keepmoat Homes)

107 | P a g e

Location House Type (number Storage Space National Storage Internal Gross Floor National Floor Area (Applicant/Developer) of storeys) Measured (m2) Space Standard Area Measured (m2) Standard Required Required (m2) (m2) Woodfield Way, Balby Apt Blk BF (One) 1.67 2 62.08 61 (Keepmoat Homes) Malton Way, Adwick-le- Milan (Two) 0.73 2 60.35 70 Street (Strata Homes Ltd) Rossington Colliery 14/PA25 (AS-OP) (Two) 1.35 2 76.86 70 () Manor Farm, Bessacarr Swallow (Two) 0 2 77.5 70 (Persimmon Homes) Doncaster Road, Hatfield Harcourt Pair (Two) 1.5 2 74.14 70 (Linden Homes) Doncaster Road, Hatfield A22 (Two) 0.69 2 85.9 70 (Linden Homes) Lakeside 2, Airbourne Rd A2 (Two) 1.69 2 90.7 70 (Lovell Partnerships) Lakeside 2, Airbourne Rd H2 3 (Two) 0.9 2 83.46 70 (Lovell Partnerships) Lakeside 2, Airbourne Rd H2 4 (Two) 1.22 2 90 70 (Lovell Partnerships) Badgers Holt, Branton Welton (Two) 1.4 2 77.48 70 (Linden Homes) Branton House Farm (Mr CV-O2 (Two) 0 2 128.13 70 Thomas) Granby Inn High Street, A4 (One) 0.8 2 66.4 61 Bawtry (Ground Properties) Granby Inn High Street, A5 (One) 0 2 72.79 61 Bawtry (Ground Properties) Granby Inn High Street. A3 (One) 0 2 69.5 61 Bawtry (Ground Properties) Regent Court, Bawtry Apartment 3 (One) 0.65 2 91.15 61 (Zuka Ltd) Regent Court, Bawtry Apartment 1 (One) 0.65 2 91.42 61 (Zuka Ltd)

108 | P a g e

Location House Type (number Storage Space National Storage Internal Gross Floor National Floor Area (Applicant/Developer) of storeys) Measured (m2) Space Standard Area Measured (m2) Standard Required Required (m2) (m2) Tickhill Road, Bawtry Apartment 24 (One) 0 2 68.3 61 (McCarthy & Stone) Tickhill Road, Bawtry Apartment 34 (One) 0 2 67.1 61 (McCarthy & Stone) Tickhill Road, Bawtry Apartment 32 (One) 0 2 69.65 61 (McCarthy & Stone) Tickhill Road, Bawtry Apartment 22 (One) 0 2 76.3 61 (McCarthy & Stone) Tickhill Road, Bawtry Apartment 11 (One) 0 2 77.8 61 (McCarthy & Stone) Three Bedrooms Pastures Road, Phase 3 Allerton (Two) 2 2.5 77.48 84 (Ben Bailey) Pastures Road, Phase 3 Hamilton (Two) 2 2.5 86.49 84 (Ben Bailey) Athelstance Crescent Barnburgh (Two) 1.6 2.5 81 84 (Harron Homes) King Edward Rd, Thorne 301 (Two) 0 2.5 70.56 84 (Glesson) King Edward Rd, Thorne 303 (Two) 1.55 2.5 71.71 84 (Glesson) King Edward Rd, Thorne 304 (Two) 1.55 2.5 71.71 84 (Glesson) King Edward Rd, Thorne 309 (Two) 0.8 2.5 75 84 (Glesson) King Edward Rd, Thorne 310 (Two) 0.8 2.5 73.24 84 (Glesson) King Edward Rd, Thorne 311 (Two) 0 2.5 70.56 84 (Glesson) West End Lane, Milldale (Two) 2.5 2.5 80.73 84 Rossington (Taylor Wimpey)

109 | P a g e

Location House Type (number Storage Space National Storage Internal Gross Floor National Floor Area (Applicant/Developer) of storeys) Measured (m2) Space Standard Area Measured (m2) Standard Required Required (m2) (m2) West End Lane, Alton (Three) 0.75 2.5 100.8 90 Rossington (Taylor Wimpey) Briars Lane, Stainforth B (Two) 1.9 2.5 80.3 84 (Prospect Estates Ltd) Briars Lane, Stainforth D (Two) 1.85 2.5 92.9 84 (Prospect Estates Ltd) Briars Lane, Stainforth G (Two) 0.7 2.5 111 84 (Prospect Estates Ltd) Kirkby Ave, Bentley 1 (Three) 2.5 2.5 108 90 (Gr33n Homes Ltd) Kirkby Ave, Bentley 2 (Three) 2 2.5 94 90 (Gr33n Homes Ltd) Kirkby Ave, Bentley 3 (Three) 2.5 2.5 108 90 (Gr33n Homes Ltd) Station Road, Askern (Mr House (Two) 1.55 2.5 73.8 84 Richard Sharp) Belle Vue, Bawtry Road Dewsbury (Two) 2.05 2.5 74.1 84 (Barratt Homes) Belle Vue, Bawtry Road Finchley (Two) 1.6 2.5 77.5 84 (Barratt Homes) Belle Vue, Bawtry Road Dartmouth (Two) 1.65 2.5 84.1 84 (Barratt Homes) Belle Vue, Bawtry Road Falmouth (Two) 1.5 2.5 85.4 84 (Barratt Homes) Belle Vue, Bawtry Road Alston (Two) 2 2.5 93.3 84 (Barratt Homes) Belle Vue, Bawtry Road Brentwood (Three) 2.6 2.5 108.5 90 (Barratt Homes) Kirk Street, Hexthorpe Clandon (Two) 1.6 2.5 89.25 84 (Persimmon Homes) Kirk Street, Hexthorpe Hatfield (Two) 1.35 2.5 86.1 84 (Persimmon Homes) Kirk Street, Hexthorpe Bickleigh (Three) 2.8 2.5 81.95 90 (Persimmon Homes)

110 | P a g e

Location House Type (number Storage Space National Storage Internal Gross Floor National Floor Area (Applicant/Developer) of storeys) Measured (m2) Space Standard Area Measured (m2) Standard Required Required (m2) (m2) Kirk Street, Hexthorpe Rufford (Two) 0.65 2.5 91.05 84 (Persimmon Homes) Kirk Street, Hexthorpe Hanbury (Two) 2.25 2.5 67.6 84 (Persimmon Homes) Kirk Street, Hexthorpe Moseley (Three) 1.5 2.5 66.35 90 (Persimmon Homes) Doncaster Road, Hatfield KS101 (Two) 1.25 2.5 104.8 84 (Mr K Severn) Earlston Drive, Bentley Detached (Two) 0 2.5 117.05 84 (Mr W Price) Street, Tickhill Detached (Two) 5.65 2.5 310.4 84 (Mr Graham Fennel) Station Road, Blaxton B (Two) 1.28 2.5 83.4 84 (Mandale Homes) Station Road, Blaxton C (Two) 1.83 2.5 95.48 84 (Mandale Homes) Station Road, Blaxton C2 (Two) 1.83 2.5 95.48 84 (Mandale Homes) Station Road, Blaxton (The VG95 (Two) 2.6 2.5 95.97 84 Virgo Group) Old Bawtry Road, Bempton (Two) 2.04 2.5 78.27 84 Finningley (Bellway Homes Ltd) Old Bawtry Road, Hawthorne (Two) 2.58 2.5 87.7 84 Finningley (Bellway Homes Ltd) Old Bawtry Road, Purley (Two) 1.87 2.5 84.95 84 Finningley (Bellway Homes Ltd) Carr House Road, Belle HL89 (Two) 0.76 2.5 92.33 84 Vue (Hoober Ltd) Carr House Road, Belle HL94 (Two) 0.76 2.5 97.24 84 Vue (Hoober Ltd) Carr House Road, Belle HL95 (Two) 0.76 2.5 99.61 84 Vue (Hoober Ltd)

111 | P a g e

Location House Type (number Storage Space National Storage Internal Gross Floor National Floor Area (Applicant/Developer) of storeys) Measured (m2) Space Standard Area Measured (m2) Standard Required Required (m2) (m2) Carr House Road, Belle HL120 (Two) 1.05 2.5 101.73 84 Vue (Hoober Ltd) Thorne Road, Bawtry (Mr Plots 1,2,3 (Two) 0 2.5 89.79 84 David Eaton) Woodfield Way, Balby 832 (Two) 1.61 2.5 77.26 84 (Keepmoat Homes) Woodfield Way, Balby 857 (Two) 2.01 2.5 79.3 84 (Keepmoat Homes) Woodfield Way, Balby 867 (Two) 2.01 2.5 80.35 84 (Keepmoat Homes) Woodfield Way, Balby 872 Ilke Dalby (Two) 1.59 2.5 81.04 84 (Keepmoat Homes) Woodfield Way, Balby 995 (Two) 2.68 2.5 92.3 84 (Keepmoat Homes) Woodfield Way, Balby 1054 (Three) 1.08 2.5 84.86 90 (Keepmoat Homes) Woodfield Way, Balby 1114 Ilke Thetford 3.02 2.5 100.77 90 (Keepmoat Homes) (Three) Malton Way, Adwick-le- Pareti (Two) 1.69 2.5 79.48 84 Street (Strata Homes Ltd) Rossington Colliery 17/PT310 (Two) 0.86 2.5 94.69 84 (Taylor Wimpey) Rossington Colliery 18/PA34 (Two) 0.97 2.5 93.93 84 (Taylor Wimpey) Manor Farm, Bessacarr Clevedon (Two) 1.6 2.5 110.56 84 (Persimmon Homes) Manor Farm, Bessacarr Mayfair (Two) 2.54 2.5 151.26 84 (Persimmon Homes) Manor Farm, Bessacarr Hanbury (Two) 1.32 2.5 86.8 84 (Persimmon Homes) Manor Farm, Bessacarr Leicester (Three) 0.6 2.5 147 90 (Persimmon Homes) Manor Farm, Bessacarr Souter (Three) 1.13 2.5 119.91 90 (Persimmon Homes)

112 | P a g e

Location House Type (number Storage Space National Storage Internal Gross Floor National Floor Area (Applicant/Developer) of storeys) Measured (m2) Space Standard Area Measured (m2) Standard Required Required (m2) (m2) Manor Farm, Bessacarr Hatfield (Two) 1.33 2.5 119.66 84 (Persimmon Homes) Manor Farm, Bessacarr Rufford (Two) 0.63 2.5 96.1 84 (Persimmon Homes) Manor Farm, Bessacarr Swale (Three) 1.65 2.5 117.78 90 (Persimmon Homes) Manor Farm, Bessacarr Moseley (Three) 0.75 2.5 86.07 90 (Persimmon Homes) Manor Farm, Bessacarr Marlborough (Two) 1.68 2.5 161.4 84 (Persimmon Homes) Doncaster Road, Hatfield Mountford (Two) 1 2.5 106.6 84 (Linden Homes) Doncaster Road, Hatfield Eveleigh (Two) 1 2.5 96.6 84 (Linden Homes) Doncaster Road, Hatfield A30 (Two) 1.24 2.5 100.52 84 (Linden Homes) Mill Street, Armthorpe B (Two) 0.85 2.5 92.9 84 (Swan Homes) Mill Street, Armthorpe A (Two) 0.8 2.5 87.46 84 (Swan Homes) Repton Road, Skellow Plots 1-4 (Three) 6.15 2.5 126.65 84 (Rajesh Gupta) Repton Road, Skellow Plots 5-6 (Three) 6.42 2.5 126.65 90 (Rajesh Gupta) Repton Road, Skellow Plots 7-9 (Three) 6.45 2.5 126.65 90 (Rajesh Gupta) Lakeside 2, Airbourne A3 (Two) 1.59 2.5 107.42 84 Road (Lovell Partnerships) Lakeside 2, Airbourne H3 5 8 (Two) 1.76 2.5 103.4 84 Road (Lovell Partnerships) Lakeside 2, Airbourne H3 5 1015 (Two) 0.56 2.5 116 84 Road (Lovell Partnerships)

113 | P a g e

Location House Type (number Storage Space National Storage Internal Gross Floor National Floor Area (Applicant/Developer) of storeys) Measured (m2) Space Standard Area Measured (m2) Standard Required Required (m2) (m2) Lakeside 2, Airbourne H3 6 (Three) 2.74 2.5 140.5 90 Road (Lovell Partnerships) Lakeside 2, Airbourne H3 5 859 (Two) 1.6 2.5 100 84 Road (Lovell Partnerships) Lakeside 2, Airbourne H3 5 861 (Two) 1.53 2.5 100 84 Road (Lovell Partnerships) Badgers Holt, Branton Marston (Two) 1.82 2.5 96.74 84 (Linden Homes) Doncaster Road, Branton DD89A (Two) 1.63 2.5 107.18 84 (Danum Developments) Doncaster Road, Branton DD89 (Two) 1.63 2.5 107.18 84 (Danum Developments) Branton House Farm (Mr HT-01 (Two) 0.92 2.5 114.3 84 Thomas) Branton House Farm (Mr HT-02 (Two) 0 2.5 112.3 84 Thomas) Old Bawtry Road, Plot 1 (One) 1.32 2.5 112.22 74 Finningley (Mr Gray) Bancroft Farm, Bawtry Taylor (Two) 1.38 2.5 104.24 84 Road (Mr & Mrs Taylor) Four Bedrooms Pastures Road, Phase 3 Seanbury (Three) 2 3 116.13 103 (Ben Bailey) Pastures Road, Phase 3 Ashbury (Two) 2.7 3 111.29 97 (Ben Bailey) Pastures Road, Phase 3 Hanbury (Two) 1.7 3 112.59 97 (Ben Bailey) Pastures Road, Phase 3 Hartlebury (Two) 2.5 3 115.01 97 (Ben Bailey) Pastures Road, Phase 3 Kingsbury (Two) 3.6 3 121.23 97 (Ben Bailey) Pastures Road, Phase 3 Pendlebury (Two) 2 3 130.71 97 (Ben Bailey)

114 | P a g e

Location House Type (number Storage Space National Storage Internal Gross Floor National Floor Area (Applicant/Developer) of storeys) Measured (m2) Space Standard Area Measured (m2) Standard Required Required (m2) (m2) Pastures Road, Phase 3 Rosebury (Two) 2.2 3 132.85 97 (Ben Bailey) Athelstane Crescent Embsay (Two) 2 3 97 97 (Harron Homes) Athelstane Crescent Nidderdale (Two) 1.8 3 108 97 (Harron Homes) Athelstane Crescent Windsor (Two) 3 3 114 97 (Harron Homes) Athelstane Crescent Tonbridge (Two) 1.5 3 128 97 (Harron Homes) King Edward Rd, Thorne 400 (Two) 0 3 89.65 97 (Glesson) King Edward Rd, Thorne 401 (Two) 0.65 3 99 97 (Glesson) West End Lane, Charlbury (Three) 2.8 3 120.68 103 Rossington (Taylor Wimpey) West End Lane, Bradenham (Two) 1.5 3 107.12 97 Rossington (Taylor Wimpey) West End Lane, (Two) 2.5 3 115.57 97 Rossington (Taylor Wimpey) West End Lane, Whitford (Two) 1.8 3 115.94 97 Rossington (Taylor Wimpey) West End Lane, Eynsham (Two) 1.2 3 123.93 97 Rossington (Taylor Wimpey) West End Lane, Shelford (Two) 1.75 3 127.18 97 Rossington (Taylor Wimpey) Briars Lane, Stainforth C (Three) 1.5 3 124.4 103 (Prospect Estates Ltd)

115 | P a g e

Location House Type (number Storage Space National Storage Internal Gross Floor National Floor Area (Applicant/Developer) of storeys) Measured (m2) Space Standard Area Measured (m2) Standard Required Required (m2) (m2) Briars Lane, Stainforth E (Two) 1.75 3 110.5 97 (Prospect Estates Ltd) Briars Lane, Stainforth E1 (Two) 1.75 3 110.5 97 (Prospect Estates Ltd) Briars Lane, Stainforth H (Two) 0.4 3 128.9 97 (Prospect Estates Ltd) Russet Grove, Bawtry B2 (Two) 1.65 3 162.95 97 (Conroy Brook Ltd) Russet Grove, Bawtry B3 (Two) 1.35 3 220.09 97 (Conroy Brook Ltd) Russet Grove, Bawtry B4 (Two) 2.1 3 200.39 97 (Conroy Brook Ltd) Russet Grove, Bawtry B5 (Two) 0 3 206.24 97 (Conroy Brook Ltd) Belle Vue, Bawtry Road Fawley (Three) 2.75 3 111.1 103 (Barratt Homes) Belle Vue, Bawtry Road Heathfield (Two) 1.7 3 111.9 97 (Barratt Homes) Belle Vue, Bawtry Road Kennington (Two) 2.4 3 118.2 97 (Barratt Homes) Kirk Street, Hexthorpe Winster (Two) 1.65 3 126.1 97 (Persimmon Homes) Kirk Street, Hexthorpe Staunton (Three) 0.75 3 108.55 103 (Persimmon Homes) Kirk Street, Hexthorpe Chedworth (Two) 0.55 3 108.5 97 (Persimmon Homes) Kirk Street, Hexthorpe Lumley (Three) 2.2 3 109.2 103 (Persimmon Homes) Kirk Street, Hexthorpe Runswick (Three) 2.3 3 118 103 (Persimmon Homes) Kirk Street, Hexthorpe Roseberry (Two) 1.35 3 111.7 97 (Persimmon Homes) Thorne Road, Edenthorpe BH169 (Two) 1.2 3 169.1 97 (Braggott Homes Ltd)

116 | P a g e

Location House Type (number Storage Space National Storage Internal Gross Floor National Floor Area (Applicant/Developer) of storeys) Measured (m2) Space Standard Area Measured (m2) Standard Required Required (m2) (m2) Thorne Road, Edenthorpe BH205 (Two) 2.6 3 213.85 97 (Braggott Homes Ltd) Thorne Road, Edenthorpe BH206 (Two) 1.6 3 229 97 (Braggott Homes Ltd) Thorne Road, Edenthorpe BH207 (Three) 1.75 3 206.2 103 (Braggott Homes Ltd) Cedar Avenue, Townhouse (Three) 1.95 3 116.15 103 Mexborough (Synergy UK Developments) Doncaster Road, Hatfield KS102 (Two) 2.7 3 176.55 97 (Mr K Severn) Briar Road, Armthorpe (Mr End Terrace (Two) 3.2 3 100.7 97 Mumford) Station Road, Blaxton D (Two) 2.57 3 111.5 97 (Mandale Homes) Station Road, Blaxton E (Two) 1.58 3 139.45 97 (Mandale Homes) Station Road, Blaxton (The VG125 (Two) 2.36 3 128.95 97 Virgo Group) Station Road, Blaxton (The VG126 (Two) 2.01 3 130.18 97 Virgo Group) Station Road, Blaxton (The VG150 (Two) 2.95 3 150.84 97 Virgo Group) Old Bawtry Road, Addingham (Two) 2.48 3 100.23 97 Finningley (Bellway Homes Ltd) Old Bawtry Road, Barn (Two) 0 3 176.01 97 Finningley (Bellway Homes Ltd) Old Bawtry Road, Grassington (Two) 3.61 3 147.02 97 Finningley (Bellway Homes Ltd) Old Bawtry Road, Hambleton (Two) 3.02 3 134.58 97 Finningley (Bellway Homes Ltd)

117 | P a g e

Location House Type (number Storage Space National Storage Internal Gross Floor National Floor Area (Applicant/Developer) of storeys) Measured (m2) Space Standard Area Measured (m2) Standard Required Required (m2) (m2) Old Bawtry Road, Ilkley (Two) 1.73 3 112.82 97 Finningley (Bellway Homes Ltd) Old Bawtry Road, Plane (Two) 3.83 3 160.63 97 Finningley (Bellway Homes Ltd) Old Bawtry Road, Plots 1,4,6 (Two) 0 3 172.9 97 Finningley (G.A. Mell Ltd) Old Bawtry Road, Plots 2,3,8 (Two) 0 3 172.59 97 Finningley (G.A. Mell Ltd) Old Bawtry Road, Plot 5 (Two) 0 3 142.36 97 Finningley (G.A. Mell Ltd) Old Bawtry Road, Plot 9 (Two) 0.56 3 171.04 97 Finningley (G.A. Mell Ltd) Woodfield Way, Balby Allerton (Two) 3.37 3 147.58 97 (Fairgrove Homes) Woodfield Way, Balby Branswood (Three) 0.76 3 156.29 103 (Fairgrove Homes) Woodfield Way, Balby Hardale (Three) 0.63 3 160.62 103 (Fairgrove Homes) Woodfield Way, Balby Harwood (Two) 1.74 3 120.86 97 (Fairgrove Homes) Woodfield Way, Balby Roxham (Two) 1.85 3 109.58 97 (Fairgrove Homes) Woodfield Way, Balby Roxwood (Three) 2.7 3 147.17 103 (Fairgrove Homes) Woodfield Way, Balby T12 (Three) 0.73 3 114.94 103 (Strata Homes Ltd) Woodfield Way, Balby T13 (Two) 1.91 3 81.96 97 (Strata Homes Ltd) Woodfield Way, Balby T6 (Two) 1.3 3 120.92 97 (Strata Homes Ltd) Woodfield Way, Balby T8 (Three) 2.77 3 143.85 103 (Strata Homes Ltd)

118 | P a g e

Location House Type (number Storage Space National Storage Internal Gross Floor National Floor Area (Applicant/Developer) of storeys) Measured (m2) Space Standard Area Measured (m2) Standard Required Required (m2) (m2) Carr Lodge Phase 2 1028 Det (Two) 3.44 3 94.92 97 (Keepmoat Homes) Carr Lodge Phase 2 1028 semi (Two) 3.44 3 94.92 97 (Keepmoat Homes) Carr Lodge Phase 2 1224 (Three) 1.88 3 101.66 103 (Keepmoat Homes) Malton Way, Adwick-le- Lavello (Two) 2.01 3 109.41 97 Street (Strata Homes Ltd) Malton Way, Adwick-le- Oporto (Three) 2.69 3 123.36 103 Street (Strata Homes Ltd) Malton Way, Adwick-le- Palermo (Two) 1.48 3 119.78 97 Street (Strata Homes Ltd) Malton Way, Adwick-le- Rosas (Three) 1.95 3 103.03 103 Street (Strata Homes Ltd) Malton Way, Adwick-le- Sorrento (Two) 2.02 3 109.31 97 Street (Strata Homes Ltd) Rossington Colliery 34/PA48 (Two) 1.39 3 148.01 97 (Taylor Wimpey) Rossington Colliery 33/PA48 (Two) 1.4 3 147.19 97 (Taylor Wimpey) Rossington Colliery 32/PA48 (Two) 1.35 3 147.22 97 (Taylor Wimpey) Rossington Colliery 31/PA48 (Two) 1.43 3 147.98 97 (Taylow Wimpey) Rossington Colliery 30/PD410 OP (Two) 1.33 3 142.78 97 (Taylor Wimpey) Rossington Colliery 29/PD410 AS (Two) 1.61 3 142.92 97 (Taylor Wimpey) Five or More Bedrooms Pastures Road, Phase 3 Kirkham (Two) 2.7 3.5 181.06 110 (Ben Bailey) Russet Grove, Bawtry B1 (Three) 3.75 3.5 188.96 116 (Conroy Brook Ltd)

119 | P a g e

Location House Type (number Storage Space National Storage Internal Gross Floor National Floor Area (Applicant/Developer) of storeys) Measured (m2) Space Standard Area Measured (m2) Standard Required Required (m2) (m2) Plantation Avenue, Detached (Two) 0.6 3.5 399.05 110 Bessacarr (Mr H Gergis) Fenwick Common Lane, Detached (Three) 3.45 3.5 386.4 116 Fenwick (Mr K Simpson) Woodfield Way, Balby Brompton (Two) 3.22 3.5 219.07 110 (Fairgrove Homes) Woodfield Way, Balby Hamleton (Three) 2.8 3.5 211.18 116 (Fairgrove Homes) Woodfield Way, Balby Sherburn (Three) 1.96 3.5 170.25 116 (Fairgrove Homes) Woodfield Way, Balby Wellburn (Three) 1.43 3.5 167.38 116 (Fairgrove Homes) Bawtry Road, Bessacarr Withers (Two) 3.56 3.5 218 110 (Mr Marlon Withers) Station Road, Bawtry (Mr Detached (Three) 1.75 4 388.8 129 and Mrs Lukey)

120 | P a g e