East Bergholt
Housing Needs Assessment (HNA)
April, 2024
East Bergholt Neighbourhood Plan Housing Needs Assessment
2
Quality information
Prepared by Checked by Approved by
Matthew Kearney –
Senior Consultant
Paul Avery –
Principal Consultant
Paul Avery –
Principal Consultant
Revision History
Revision Date Authorized Position
1. First Draft February,
2024
MK Senior Consultant
2. Internal
Review
February,
2024
PA Principal Consultant
3. Group
Review
April, 2024 AL NP Group Consultant
4. Locality
Review
April, 2024 AO Neighbourhood Planning
Officer
5. Final
Report
April, 2024 MK Senior Consultant
Prepared for: East Bergholt Neighbourhood Plan Group
Prepared by:
AECOM Infrastructure & Environment UK Limited
Aldgate Tower
2 Leman Street
London E1 8FA
United Kingdom
aecom.com
© 2024 AECOM Infrastructure & Environment UK Limited. All Rights Reserved.
This document has been prepared by AECOM Infrastructure & Environment UK
Limited (“AECOM”) for sole use of our client (the “Client”) in accordance with generally
accepted consultancy principles, the budget for fees and the terms of reference agreed
between AECOM and the Client. Any information provided by third parties and referred
to herein has not been checked or verified by AECOM, unless otherwise expressly
stated in the document. No third party may rely upon this document without the prior
and express written agreement of AECOM.
East Bergholt Neighbourhood Plan Housing Needs Assessment
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Table of Contents
1. Executive Summary ………………………………………………………………………………….. 6
Tenure and Affordability …………………………………………………………………………………. 6
Type and Size ……………………………………………………………………………………………… 7
Specialist Housing for Older People ………………………………………………………………… 8
2. Context ………………………………………………………………………………………………….. 10
Local context ……………………………………………………………………………………………… 10
The NA boundary and key statistics ………………………………………………………………. 10
The housing market area context ………………………………………………………………….. 12
Planning policy context ………………………………………………………………………………… 12
Quantity of housing to provide ………………………………………………………………………. 13
3. Objectives and approach ………………………………………………………………………….. 14
Objectives …………………………………………………………………………………………………. 14
Affordability and Affordable Housing ……………………………………………………………… 14
Type and Size ……………………………………………………………………………………………. 14
Specialist Housing for Older People ………………………………………………………………. 15
Approach …………………………………………………………………………………………………… 15
4. Affordability and Affordable Housing …………………………………………………………… 17
Introduction ……………………………………………………………………………………………….. 17
Definitions …………………………………………………………………………………………………. 17
Current tenure profile ………………………………………………………………………………….. 18
Affordability………………………………………………………………………………………………… 19
House prices ……………………………………………………………………………………………… 19
Income ……………………………………………………………………………………………………… 20
Affordability Thresholds ……………………………………………………………………………….. 21
Estimates of the need for Affordable Housing …………………………………………………. 26
AECOM Estimates ……………………………………………………………………………………… 26
Evidence in the SHMA ………………………………………………………………………………… 27
Affordable Housing policies in Neighbourhood Plans ……………………………………….. 28
Application of Local Plan policies ………………………………………………………………….. 28
Affordable Housing at Neighbourhood level ……………………………………………………. 29
Conclusions – Tenure and Affordability …………………………………………………………… 30
5. Type and Size …………………………………………………………………………………………. 33
Introduction ……………………………………………………………………………………………….. 33
Definitions …………………………………………………………………………………………………. 33
The current housing mix ………………………………………………………………………………. 34
Dwelling type ……………………………………………………………………………………………… 34
Dwelling size ……………………………………………………………………………………………… 35
Population characteristics ……………………………………………………………………………. 36
Age …………………………………………………………………………………………………………… 36
Household composition and occupancy …………………………………………………………. 37
Future population and size needs …………………………………………………………………. 39
Age …………………………………………………………………………………………………………… 39
Tenure ………………………………………………………………………………………………………. 41
Type …………………………………………………………………………………………………………. 42
Conclusions – Type and Size ………………………………………………………………………… 43
East Bergholt Neighbourhood Plan Housing Needs Assessment
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6. Specialist housing for older people …………………………………………………………….. 44
Introduction ……………………………………………………………………………………………….. 44
Definitions …………………………………………………………………………………………………. 45
Specialist housing for older people………………………………………………………………… 45
Demographic characteristics ………………………………………………………………………… 45
Future needs for specialist accommodation and adaptations …………………………….. 47
Further considerations …………………………………………………………………………………. 48
Care homes ……………………………………………………………………………………………….. 49
The Role of Mainstream Housing ………………………………………………………………….. 50
Conclusions – Specialist Housing for Older People ………………………………………….. 51
7. Next Steps ……………………………………………………………………………………………… 53
Recommendations for next steps ………………………………………………………………….. 53
Appendix A : Assessment geography …………………………………………………………….. 54
Appendix B : Local Plan context ……………………………………………………………………. 55
Appendix C : Affordability calculations ……………………………………………………………. 56
Appendix D : Affordable Housing need and policy……………………………………………. 65
Appendix E : Specialist housing for older people …………………………………………….. 73
Appendix F : Housing Needs Assessment Glossary ………………………………………… 75
East Bergholt Neighbourhood Plan Housing Needs Assessment
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List of acronyms used in the text:
DLUHC Department for Levelling Up, Housing and Communities (formerly
MHCLG)
HMA Housing Market Area
HNA Housing Needs Assessment
HRF Housing Requirement Figure (the total number of homes the NA is
expected to plan for, usually supplied by LPAs)
HLIN Housing Learning and Improvement Network
HRP Household Reference Person
LA Local Authority
LHN Local Housing Need
LHNA Local Housing Needs Assessment
LPA Local Planning Authority
LSOA Lower Layer Super Output Area
MSOA Middle Layer Super Output Area
NA Neighbourhood (Plan) Area
NP Neighbourhood Plan
NPPF National Planning Policy Framework
OA Output Area
ONS Office for National Statistics
PPG Planning Practice Guidance
PRS Private Rented Sector
RQ Research Question
SHMA Strategic Housing Market Assessment
VOA Valuation Office Agency
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1. Executive Summary
1.1 East Bergholt is a Neighbourhood Area (NA) located in the district of Babergh. The NA
boundary covers the areas administered by East Bergholt Parish Council.
1.2 The 2021 Census recorded 2,714 individuals in East Bergholt, indicating a decrease of
1.8% since the 2011 Census.
1.3 There has been some development in East Bergholt in recent years. Babergh has
provided data showing that 51 new homes have been built since 2011. Of these, 4 were
delivered as Affordable Housing.
1.4 This Executive Summary details the conclusions of each chapter of this Housing Needs
Assessment (HNA), addressing each of the themes agreed with the East Bergholt
Neighbourhood Plan Group at the outset of the research.
1.5 Data from the 2021 Census is continuing to be released. At present, the available data
covers population, households, tenure, and dwelling stock characteristics. Some data
from the Census 2021 at the localised level is not yet available, as well as some data
comparing numerous variables. As such this HNA will draw on the latest available data
from the 2021 Census where possible and will also continue to use other data sets,
including 2011 Census, Valuation Office Agency data, and ONS projections where
necessary to build up evidence at the neighbourhood level.
Tenure and Affordability
Current tenure profile
1.6 Home ownership is the dominant tenure in East Bergholt at 79% of all households, which
is slightly higher than the district average. Of the remaining households, 12% live in
private rented housing and 10% in socially rented housing, but are both smaller
proportional shares than the district average.
1.7 Over the last decade, there has been a proportionally significant increase in number of
private renters, this is in contrast to much slower growth in the proportional share of
owner occupiers.
Housing Costs
1.8 Home values in East Bergholt have followed a clear upward trajectory over the last
decade. The current median house price (middle number when arranged from lowest to
highest) is £470,000, which is 62% higher than the median in 2013. The lower quartile
price (the lowest 25% of prices, used as a good proxy for entry-level housing) sits at
£378,000, which is 60% higher than in 2013. It is worth noting that the current median
house price in East Bergholt is significantly more expensive than the current median for
Babergh as a whole (£333,000).
1.9 AECOM has estimated the annual income required to afford various tenures of housing
in East Bergholt. These thresholds are compared to local incomes to determine which
East Bergholt Neighbourhood Plan Housing Needs Assessment
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options are the most appropriate for local people going forward. The average household
income in the NA was £48,900 in 2020, and the lower quartile income (per person) was
£19,700.
1.10 It was found that local households on average incomes are unable to access even entry-
level homes unless they have the advantage of a very large deposit. The median house
price would require an annual income of around 150% above the current average.
Private renting presents a similar affordability challenge, generally only allowing average
income households to access 2 bedroom rented homes. Households made up of two
lower earners could not afford the given rental thresholds and would need to rely on
social and affordable rented options.
1.11 Subsidised routes to home ownership like First Homes and shared ownership are
intended to target people who can afford to rent but not to buy. In East Bergholt, there is
a relatively large gap between the income needed to afford to rent (£40,800) and to buy
(£97,200), who may benefit from these products.
1.12 The discount on First Homes can be set at 30%, 40% or 50% in Neighbourhood Plans.
In East Bergholt, a 50% discount would be required to expand access to home ownership
to average earning households. However, it is worth noting a 50% discount is still only
marginally affordable to average earners. If seeking to take action on the appropriate
level of discount for East Bergholt in the Neighbourhood Plan, the Neighbourhood Plan
Group are advised to discuss this possibility with Babergh Council, who may be able to
supply evidence of development viability that is also relevant to this policy area.
1.13 Affordable rented housing appears generally affordable to households with two lower
earners (average earning households are unlikely to be eligible). Single lower earners
can afford average social rents and affordable rents but the lowest earners, if unable to
secure a social rented dwelling or additional subsidy, may need to live in a room in a
shared house using housing benefits.
The need for Affordable Housing
1.14 AECOM estimate a long-term surplus of 1 social/affordable dwelling per annum over the
East Bergholt Neighbourhood Plan period (2023 – 2040) when East Bergholt’s needs
are considered in isolation. Modelling contained in the main body of the report also
suggests that East Bergholt has a robust long-term demand of 5 affordable home
ownership dwellings per annum over the same period.
1.15 AECOM’s modelling suggests that the delivery of home ownership dwellings could be
prioritised in East Bergholt in order to address potential demand and to wider choice.
Type and Size
The current housing mix
1.16 The East Bergholt housing stock is significantly biased toward detached homes, which
make up approximately two thirds of the overall stock. Moreover, cumulatively detached
East Bergholt Neighbourhood Plan Housing Needs Assessment
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and semi detached dwellings make up close to 85% of the housing stock. The remainder
is made up of terraced dwellings and a smaller number of flats.
1.17 The size profile of homes in East Bergholt is fairly similar to the district, with a much
higher proportion of detached dwellings and a smaller proportion of the other housing
types.
1.18 The NA has a higher proportion of larger 4+ bedroom homes than is common across
Babergh.
Population characteristics
1.19 The East Bergholt population has declined by 1.8% over the last decade. There is a
distinction between the younger and older population in East Bergholt, with each cohort
aged younger than 64 showing population decline and the older population showing
proportional growth, notably in those aged 85+.
1.20 Household projections suggest that East Bergholt’s population will continue to age over
the NP period, with a potential increase of 81% in the population aged 65 and over. The
projections also suggest either slow growth or a contraction in their share over the overall
population over the NP period. It should be noted that these estimates are informed by
population projections for the wider district and may be more moderate in reality.
Future population and size needs
1.21 It is possible to estimate the size mix of future homes than might best accommodate
demographic trends and address imbalances in the existing housing stock. The result of
this process suggests that new developments should deliver a variety of dwellings with
between 1-3 bedrooms, with a focus on 2/3 bedroom homes.
1.22 It is important to remember that other factors should be considered in determining the
dwelling mix that is desirable in the NA or on any particular site. These include the
specific characteristics of the nearby stock of housing (such as its condition and design),
the role of the NA or site within the wider housing market area (linked to any Local
Authority strategies or plans) and site-specific factors. The size mix of Affordable Housing
also tends to be considered separately from market housing by the Local Planning
Authority and to focus on the smaller units for which the vast majority of those on the
waiting list in East Bergholt are eligible.
Specialist Housing for Older People
Characteristics of the current older population
1.23 There are currently estimated to be around 432 individuals aged 75 or over in East
Bergholt, a number that has grown from 318 in 2011 and is projected to rise to 691 over
by the end of the Neighbourhood Plan period (2040).
1.24 A clear majority (82%) of Babergh’s households aged between 55 and 75 in 2011 (and
therefore likely to reach the 75+ bracket by 2041) are owner occupiers and the remainder
predominantly rent from a social landlord. This is important because those currently
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owning will require specialist accommodation for market purchase, being largely
ineligible for subsidised housing, while those in private or social rent will need to rely on
subsidised rented housing because they are unlikely to have the funds to buy.
Projected demographic change and need for specialist housing
1.25 The 75+ population of the NA is projected to increase from 16% to 23% of the overall
population between 2021 and 2040. The growth of the older population should be
converted into households because some older people will be cohabiting. The projected
growth in the older population points to 185 new households made of persons aged 75+
over the Neighbourhood Plan period.
1.26 The potential need for specialist housing with some form of additional care for older
people can be estimated by bringing together data on population projections, rates of
disability, and what tenure of housing the current 55-75 cohort occupy in the NA. This
can be sense-checked using a toolkit based on national research.
1.27 The two methods for estimating the future need in East Bergholt produce a range of 65
to 79 specialist accommodation units that might be required during the plan period.
These estimates are based on the projected growth of the older population, thereby
assuming that today’s older households are already well accommodated.
1.28 Broadly, between 60-75% of the need can be accommodated through market purchase
(as opposed to Affordable Housing). Moreover, between 60-70% of the need can be
accommodated through either sheltered accommodation or adaptations to the existing
housing stock, rather than new extra care options. The potential need for care and
nursing home beds in East Bergholt by 2040 can be estimated at roughly 15.
1.29 The main unmet need in East Bergholt is for market sheltered accommodation which
may be satisfied by ensuring most or all new housing is accessible and adaptable for
people with lower support needs. Policy LP24 of the adopted Part 1 of the Babergh and
Mid Suffolk Local Plan suggests that 50% of new dwellings meet the requirements for
accessible and adaptable dwellings under Part M4(2) of Building Regulations. It is
unknown whether East Bergholt is expecting any delivery of specialist accommodation
over the plan period.
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2. Context
Local context
2.1 East Bergholt is a Neighbourhood Area (NA) located in the district of Babergh in the East
of England. The NA boundary was designated in 2014 and a Neighbourhood Plan was
adopted in 2016, which covers the period 2015 – 2030.
2.2 The Neighbourhood Plan Group are currently in the process of reviewing their adopted
Neighbourhood Plan. The new Plan is envisaged extend the Neighbourhood Plan period
to 2040. The evidence supplied in this report will look forward to the Plan end date of
2040, but where possible will also provide annualised figures which can be extrapolated
to a different term if the Plan period changes.
2.3 East Bergholt is a large village set in the county of Suffolk, and is to the north-west of
Manningtree, the closest town to the NA. The A12, which connects Ipswich and
Colchester, runs along the north-west boundary of the NA, and East Bergholt is located
roughly equidistant between the two lager settlements. The village benefits from a range
of services, including a high school, primary schools, pubs, cafes and a range of other
small-to-medium sized businesses.
The NA boundary and key statistics
2.4 For Census purposes, the NA is made up, like the rest of England, of statistical units
called Output Areas (OAs). A breakdown of the OAs relevant to East Bergholt is provided
in Appendix A. A map of the Plan area appears below in Figure 2-1.
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Figure 2-1: Map of the East Bergholt Neighbourhood Area
Source Designated East Bergholt Neighbourhood Area
1
2.5 At the time of the 2021 Census the NA was home to 2,714 residents, formed into 1,175
households and occupying 1,226 dwellings. The 2021 Census indicates population
decline of around 1.8% since 2011
2
, when the census recorded a total of 2,795 residents.
The average household size fell from 2.4 to 2.3.
2.6 The 2021 Census indicates that there are currently 1,226 dwellings in East Bergholt.
Completions data provided by Babergh suggests that there have been 51 new dwellings
completed, 4 of which were delivered as Affordable housing, and 21 dwellings lost over
the last decade.
2.7 There is a Community Land Trust currently in operation in the NA, and the East Bergholt
Neighbourhood Plan Group have indicated there are currently 14 people on the register.
1
Available at https://www.babergh.gov.uk/documents/d/babergh/east-bergholt-np-map
2
It is worth noting that this figure is an estimate only, based on data which is mostly available at local authority level such as administrative
registers of births and deaths, data on moves between local authorities, small-area population estimates and official population projections,
and not based on a survey count.
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The housing market area context
2.9 Whilst this Housing Needs Assessment (HNA) focuses on East Bergholt NA it is
important to keep in mind that neighbourhoods are not self-contained housing market
areas. Housing market areas are usually wider than local authority areas and often
stretch across a number of districts or boroughs. This is because housing market areas
are inherently linked to the labour market, employment patterns and travel to work areas.
2.10 In the case of East Bergholt, the NA sits within a housing market area which covers
Ipswich, Babergh, Mid Suffolk, the Suffolk Coastal area, and Waveney.
[1]
This means
that when households who live in these authorities move home, the vast majority move
within this geography.
2.11 At the neighbourhood scale it is not possible to be definitive about housing need and
demand because neighbourhoods, including East Bergholt, are closely linked to other
areas. In the case of East Bergholt, changes in need or demand in settlements nearby
is likely to impact on the neighbourhood.
2.12 In summary, East Bergholt functions within a wider strategic area. As well as fostering
good working relationships with the local planning authority (Babergh), it is therefore
useful to think about the role of the neighbourhood within the wider area. This HNA can
provide evidence to understand this role and the specific features of the neighbourhood
within this wider context. Neighbourhood Plans can have a significant impact in shaping
their neighbourhoods, enhancing the positive role the neighbourhood plays within the
wider housing market, or developing polices to change entrenched patterns and improve
housing outcomes in the neighbourhood and wider area.
Planning policy context
2.13 Neighbourhood Plans are required to be in general conformity with adopted strategic
local policies.
3
The relevant Local Plan literature for East Bergholt is Part 1 of the
Babergh and Mid Suffolk Local Plan, which was adopted in November 2023.
2.14 A detailed breakdown of the Local Plan policies relevant to housing need is provided in
Appendix B. Here, it is worth summarising the most important points of the adopted Part
1 of the Local Plan:
• Local Plan Policy SPO1 – Housing Needs identifies an overall housing target of
7,904 homes between 2018 and 2037 across Babergh, or an annual target of 416
dwellings;
• Policy SP02 – Affordable Housing states that 35% of new housing in the district
should be delivered as Affordable Housing.
[1]
https://www.babergh.gov.uk/documents/d/asset-library-54706/ipswich-and-waveney-housing-market-areas-strategic-housing-market-
assessment-part-1-may-2017
3
A description of the Basic Conditions of Neighbourhood Planning is available at https://www.gov.uk/guidance/neighbourhood-planning–
2#basic-conditions-for-neighbourhood-plan-to-referendum
East Bergholt Neighbourhood Plan Housing Needs Assessment
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2.15 Consultation for Part 2 of the plan is expected in the Spring of 2024, and it will include
an updated settlement hierarchy and housing allocations for Neighbourhood Plan areas.
In the superseded Babergh Local Plan (2014) East Bergholt was designated as a Core
Village,
Quantity of housing to provide
2.16 The NPPF 2023 (paragraphs 67 and 68) requires LPAs to provide neighbourhood groups
upon request with a definitive or an indicative number of houses to plan for over the
Neighbourhood Plan period.
2.17 Babergh have not yet provided East Bergholt with either an indicative of definitive
Housing Requirement Figure, with this being expected as Part 2 of the new Joint Local
Plan. For the purpose of this study this figure is unknown, but once a figure has been
arrived at, the calculations presented in the following chapters can be applied to the HRF
to understand the expected delivery of, for example, Affordable Housing.
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3. Objectives and approach
Objectives
3.1 This HNA is structured according to a number of themes or topics that were agreed at
the outset of the research with the East Bergholt Neighbourhood Plan Group. These
themes are broadly aligned with the kinds of housing policy areas available to
neighbourhood plans, and each will form a distinct chapter of this report. The sub-
sections below give a brief overview of the objectives of each chapter.
Affordability and Affordable Housing
3.2 Neighbourhood plans may include policies that influence the scale of Affordable Housing
provision and the mix of different tenures and products provided through new housing
development.
3.3 This chapter has three aims, each given its own sub-section:
• To establish the existing tenure of homes within the NA at present (owner occupied,
private rented, social/affordable rented, shared ownership);
• To examine the affordability of different tenures by considering house prices, rents,
local incomes and earnings; and
• To estimate the scale of need for Affordable Housing, including the need for those
who cannot afford to rent and those who cannot afford to buy.
3.4 The evidence gathered here can be used to justify planning policies in the
Neighbourhood Plan, but it is likely that other supporting evidence may be needed, for
example on viability. Local Plans typically include policies on Affordable Housing and
whilst the Neighbourhood Plan must be in general conformity with these strategic
policies, there is scope for Neighbourhood Plan policies to adopt some local variety
where this is supported by the evidence.
Type and Size
3.5 It is common for neighbourhood plans to include policies that influence what form new
housing should take in terms of type and size. This requires evidence of what local
people need.
3.6 The focus of this chapter is to identify relevant trends and potential gaps in the market
that can be used to justify planning policies. It has three aims, each given its own sub-
section:
• To establish what mix of housing exists in the NA at present;
• To describe relevant characteristics of the local population; and
• To look to the future, considering how the population is likely to evolve and what mix
of homes would be most appropriate to build.
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3.7 In addition to the direction of travel revealed by statistics, a variety of reasons sit behind
people’s housing choices that are less easy to predict, including wealth, accessibility
requirements and personal preference. The conclusions and recommendations given
here are sufficient for justifying planning policies but are not definitive. It is also
appropriate to take into account other factors and evidence if desired.
Specialist Housing for Older People
3.8 It may be appropriate for neighbourhood plans in areas with aging populations to include
policies relating to specialist housing for older persons.
3.9 This chapter supplements the demographic evidence relating to Type and Size, including
the potential demand for downsizing, to consider the quantity and characteristics of need
for housing for older people with some form of additional care. Its approach is as follows:
• To review the current provision of specialist housing in the NA;
• To estimate the potential demand for this form of accommodation with reference to
the projected growth in the older population and current rates of mobility limitation;
and
• To discuss the potential for meeting this need through adaptations to the mainstream
stock and other additional considerations.
3.10 This element of the HNA recognises that the majority of older people will live in the
mainstream housing stock and that there is no single way to meet their needs. It may
also be inappropriate to focus excessively on the needs of one group or to promote a
specialist scheme in a location that lacks adequate services. These issues will be drawn
out.
Approach
3.11 This HNA assesses a range of evidence to ensure its findings are robust for the purposes
of developing policy at the neighbourhood plan level. This includes data from the 2021
and 2011 Censuses and a range of other data sources, including:
• ONS population and household projections for future years;
• Valuation Office Agency (VOA) data on the current stock of housing;
• Land Registry data on prices paid for housing within the local market;
• Rental prices from Home.co.uk;
• Local Authority housing waiting list data; and
• Ipswich and Waveney Housing Market Areas SHMA Parts 1 & 2 (2017)
3.12 Data from the 2021 Census continues to be released. At present, the available data
covers population, households, tenure, and dwelling stock characteristics. Some data at
the localised level, including parishes, will not be available until later in 2024, as well as
data comparing numerous variables. As such, neighbourhood level HNAs will draw on
East Bergholt Neighbourhood Plan Housing Needs Assessment
16
the latest available data from the 2021 Census where possible and will also continue to
use other data sets, including 2011 Census, Valuation Office Agency data, and ONS
parish projections to build up evidence at the neighbourhood level.
East Bergholt Neighbourhood Plan Housing Needs Assessment
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4. Affordability and Affordable Housing
Introduction
4.1 Neighbourhood plans may include policies that influence the scale of Affordable Housing
provision and the mix of different tenures and products provided through new housing
development.
4.2 This chapter has three aims, each given its own sub-section:
• To establish the existing tenure of homes within the NA at present (owner occupied,
private rented, social/affordable rented, shared ownership);
• To examine the affordability of different tenures by considering house prices, rents,
local incomes and earnings; and
• To estimate the scale of need for Affordable Housing, including the need for those
who cannot afford to rent and those who cannot afford to buy.
4.3 The evidence gathered here can be used to justify planning policies in the
Neighbourhood Plan, but it is likely that other supporting evidence may be needed, for
example on viability. Local Plans typically include policies on Affordable Housing and
whilst the Neighbourhood Plan must conform with these policies, there is scope for
Neighbourhood Plan policies to adopt some local variety where this is supported by the
evidence.
Definitions
4.4 This section uses a range of technical terms which are useful to define at the outset:
• Tenure refers to the way a household occupies their home. Broadly speaking, there
are two categories of tenure: market housing (such as homes available to purchase
outright or rent from a private landlord) and Affordable Housing (including
subsidised products like social rent and shared ownership).
• Affordability refers to the relationship between the cost of housing to buy or rent
and the incomes and earnings of households.
• The definition of Affordable Housing is set out in the NPPF 2023 (Annex 2) as
‘Housing for sale or rent, for those whose needs are not met by the market…’ We
refer to Affordable Housing, with capital letters, to denote the specific tenures that
are classified as affordable in the current NPPF (Annex 2). A relatively less
expensive home for market sale may be affordable but it is not a form of Affordable
Housing.
• A range of affordable home ownership opportunities are included in the
Government’s definition of Affordable Housing, to meet the needs of those aspiring
East Bergholt Neighbourhood Plan Housing Needs Assessment
18
to own a home. As part of this, the Government has introduced a new product
called First Homes, although this is not yet reflected in Annex 2 of the NPPF.
4
• First Homes is a new product and expected to be an important part of the strategy
for improving access to home ownership. Its key features are explained in greater
detail in Appendix C.
Current tenure profile
4.5 The current tenure profile is a key feature of the Neighbourhood Area (NA). Patterns of
home ownership, private renting and affordable/social renting reflect demographic
characteristics including age (with older households more likely to own their own homes),
and patterns of income and wealth which influence whether households can afford to
rent or buy and whether they need subsidy to access housing.
4.6 Table 4-1 presents data on tenure in East Bergholt compared with Babergh and England
from the 2021 Census. It shows that home ownership is the dominant tenure in East
Bergholt, accounting for roughly four fifths of the overall tenure profile. The remainder is
made up of social and private renters, and a very small proportion of shared ownership
homes.
4.7 The tenure profile of the NA generally tracks that of the wider district, with a high
proportion of owner occupiers, albeit with a slightly smaller proportion of homeowners in
Babergh. In turn, there are more social and private renters across Babergh than there
are in East Bergholt.
Table 4-1: Tenure (households) in East Bergholt, 2021
Tenure East Bergholt Babergh England
Owned 78.6% 71.0% 61.3%
Shared ownership 0.3% 0.7% 1.0%
Social rented 9.5% 13.3% 17.1%
Private rented 11.5% 15.0% 20.6%
Sources: Census 2021, AECOM Calculations
4.8 It is also worth comparing how the tenure mix has changed in the last ten years, using
the 2011 Census (see Table 4-2). The most striking change over the last 10 years is the
26% increase in private renters. When accounting for the fact that there has not been
significant development in the NA over the last decade, this change can be interpreted
as an expression of deepening affordability challenges, with those unable to afford to
buy a home being forced into the private rental market.
4
The shape that the new First Homes product will take is set out in a Ministerial Statement issued in May 2021, available here:
https://questions-statements.parliament.uk/written-statements/detail/2021-05-24/hlws48. The relevant update to PPG is available here:
https://www.gov.uk/guidance/first-homes#contents.
East Bergholt Neighbourhood Plan Housing Needs Assessment
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Table 4-2: Tenure change (households) in East Bergholt, 2011-2021
Tenure 2011 2021 % change
Owned 899 924 2.8%
Shared ownership 5 4 -20.0%
Social rented 105 112 6.7%
Private rented 107 135 26.2%
Sources: Census 2021 and 2011, AECOM Calculations
Affordability
House prices
4.9 House prices provide an indication of the level of demand for homes within an area. The
relationship between house prices and incomes determines whether housing is
affordable to local households and, to a large extent, what tenure, type and size of home
they occupy. Changes in affordability over time can indicate pressures in the housing
market. As such, it is useful for the evidence base for plans to examine trends in prices
and consider what this reveals about the local housing market.
4.10 Figure 4-1 looks at the average and lower quartile house prices in East Bergholt based
on sales price data published by the Land Registry. It shows that median house prices,
which represent the middle number when the data is sorted from smallest to largest,
have experienced relatively steady upward growth over the last decades despite some
year-on-year fluctuations.
4.11 The current median house price in East Bergholt is £470,000, which is 62% higher than
the median price in 2013. The current mean is higher at £531,000, which is 29% more
expensive than in 2013. Because the mean reflects every transaction in the sample there
is potential for outlaying data to skew the overall result (making it usually higher than the
median). This can be seen in Figure 4-1, where the mean consistently sits above the
median, and has experienced a few spikes in price.
4.12 The current lower quartile (LQ) price, which is the middle figure of the lowest 50% of
sales and acts as a good representation of entry level housing, stands at £378,000 and
is 60% higher than the 2013 LQ figure.
4.13 House prices in East Bergholt appear to be significantly more expensive than the district
as a whole, where the 2022 median house price was £333,000.
East Bergholt Neighbourhood Plan Housing Needs Assessment
20
Figure 4-1: House prices by quartile in East Bergholt, 2013-2022
Source: Land Registry PPD
4.14 Table 4-3 breaks down house prices by type, presenting the median within each type. It
shows that semi-detached and terraced dwellings are appreciating in value at a faster
rate than other housing types. There has been slow growth the price of detached
dwellings, but they remain the most expensive on offer, and started off at a relatively high
base in 2013 when compared to other housing types. There has also been limited growth
in the price of flats, but sales of this housing type were only recorded in three of the last
ten years.
Table 4-3: Median house prices by type in East Bergholt, 2013-2022
Type 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 Growth
Detached £458K £340K £382K £400K £395K £389K £490K £505K £475K £543K 18.6%
Semi-detached £245K £243K £230K £257K £343K £375K £362K £370K £310K £378K 54.3%
Terraced £175K £167K £180K £204K £231K £278K £248K £275K £260K £278K 58.6%
Flats – £133K – – £148K – – £139K – – 4.9%
All Types £290K £305K £334K £301K £350K £363K £350K £428K £435K £470K 62.1%
Source: Land Registry PPD
Income
4.15 Household incomes determine the ability of households to exercise choice in the housing
market, and consequently the level of need for affordable housing products. Two sources
of data are used to examine household incomes in the NA.
4.16 The first source is ONS’s estimates of incomes in small areas. This is locally specific but
limited to the overall average income (i.e. it does not provide the average income of lower
earners). The average total household income locally was £48,900 in 2020 (the most
recent year for this dataset). Discussion about the area to which this data applies is
provided in Appendix A.
£0
£100,000
£200,000
£300,000
£400,000
£500,000
£600,000
2013201420152016201720182019202020212022
Mean Median Lower quartile
East Bergholt Neighbourhood Plan Housing Needs Assessment
21
4.17 The second source is ONS’s annual estimates of UK employee earnings. This provides
lower quartile average earnings (i.e. the income of the lowest 25% of earners). However,
it is only available at the Local Authority level. It also relates to individual earnings. While
this is an accurate representation of household incomes where there is only one earner,
it does not represent household income where there are two or more people earning.
Babergh’s gross individual lower quartile annual earnings were £19,700 in 2022. To
estimate the income of households with two lower quartile earners, this figure is doubled
to £39,400.
4.18 It is immediately clear from this data that there is a large gap between the spending
power of average earning households and those earning the lowest 25% of incomes,
particularly where the household in question has one earner only.
Affordability Thresholds
4.19 To gain a clearer understanding of local affordability, it is useful to understand what levels
of income are required to afford different tenures. This is done using ‘affordability
thresholds’: the estimated amount of annual income required to cover the cost of rent or
a mortgage given local housing prices.
4.20 AECOM has determined thresholds for the income required in East Bergholt to buy a
home in the open market (average and entry-level prices), and the income required to
afford private rent and the range of Affordable Housing tenures as set out in the NPPF.
These calculations are detailed and discussed in more detail in Appendix C.
4.21 The key assumptions made in assessing the affordability of different tenures are
explained alongside the calculations, but it is worth noting here that we have assumed
that the maximum percentage of household income that should be spent on rent is 30%
and that mortgage financing will be offered at a maximum of 3.5 times household income.
These are standard assumptions across housing needs assessments at neighbourhood
and local authority scale although different approaches are sometimes taken and a case
can be made for alternatives. This is discussed in more detail at the start of Appendix C.
4.22 Table 4-4 summarises the estimated cost of each tenure, the annual income required to
support these costs within the NA, and whether local incomes are sufficient. The income
required column assumes the household already has access to a deposit (which we have
assumed to be 10% of the value to be purchased) but does not reflect the possibility that
households may already hold equity from an existing property. Although these factors
may be crucial to whether housing will be affordable, they are highly dependent on
individual circumstances that cannot be anticipated here.
East Bergholt Neighbourhood Plan Housing Needs Assessment
22
Table 4-4: Affordability thresholds in East Bergholt (income required, £)
Tenure
Mortgage
value (90%
of price)
Annual
rent
Income
required
Affordable
on average
incomes?
Affordable
on LQ
earnings
(single
earner)?
Affordable
on LQ
earnings (2
earners)?
£48,900 £19,700 £39,400
Market Housing
Median House Price £347,351 – £120,857 No No No
Estimated NA New Build
Entry-Level House Price
£99,243 No No No
LQ/Entry-level House Price £340,200 – £97,200 No No No
LA New Build Median House
Price
£306,000 – £87,429 No No No
Average Market Rent – £19,200 £64,000 No No No
Entry-level Market Rent – £12,240 £40,800 Yes No No
Affordable Home
Ownership
First Homes (-30%) £243,146 – £69,470 No No No
First Homes (-40%) £208,411 – £59,546 No No No
First Homes (-50%) £173,676 – £49,622 Marginal No No
Shared Ownership (50%) £173,676 £4,824 £65,703 No No No
Shared Ownership (25%) £86,838 £7,236 £48,932 Marginal No No
Shared Ownership (10%) £34,735 £8,684 £38,870 Yes No Yes
Affordable Rented Housing
Affordable Rent – £5,460 £18,182 Yes Yes Yes
Social Rent – £4,784 £15,931 Yes Yes Yes
Source: AECOM Calculations
4.23 Before considering each tenure category in turn, it is important to stress that these
affordability thresholds have been calculated to give an indication of the costs of various
tenures to inform Neighbourhood Plan policy choices. These figures rely on existing data
and assumptions, and it is not possible to estimate every possible permutation. The
income figures also disguise a large degree of variation. For simplicity the analysis below
speaks in terms of tenure products being ‘affordable’ or ‘not affordable’ for different
groups, but individual circumstances and the location, condition and other factors of
specific properties in each category have a large impact. These conclusions should
therefore be interpreted flexibly.
Market housing for purchase and rent
4.24 Thinking about housing for purchase on the open market, it appears that local
households on average incomes are unable to access even entry-level homes unless
they have the advantage of a very large deposit. Market housing, even with the benefit
of a higher than average income, is likely to remain out of reach to most. The median
house price would require an annual income 150% higher than the current average.
4.25 Private renting is generally only affordable to higher earners, but entry level rents are
accessible for average earners. Households made up of two lower quartile earners
cannot afford the given rental thresholds. Affordability is improved if households are able
East Bergholt Neighbourhood Plan Housing Needs Assessment
23
or willing to dedicate a larger proportion of their incomes to rental costs, although this
has repercussions for other quality of life aspects and cannot be assumed to suit all
individuals’ circumstances.
Affordable home ownership
4.26 There is a relatively large group of households in East Bergholt who may be able to
afford to rent privately but cannot afford home ownership. They are typically earning
between around £40,800 per year (at which point entry-level rents become affordable)
and £97,200 (at which point entry-level market sale homes become affordable). This ‘can
rent, can’t buy’ cohort may benefit from the range of affordable home ownership products
such as First Homes and shared ownership.
4.27 First Homes are to be offered at a discount of at least 30% on equivalent market prices
(i.e. new build, entry-level properties). Local authorities and neighbourhood plan
qualifying bodies will have discretion to increase the discount on First Homes to 40% or
50% where there is evidence to suggest this is appropriate.
4.28 This report has estimated the income required to afford First Homes and tested the
implications of 30%, 40% and 50% discount levels. Given the generally high house
prices in the NA, First Homes at a discount of 50% would be required, though this would
still be only marginally affordable to average earning households.
4.29 It is important to note that this evidence based on affordability does not provide a
complete picture: evidence about the financial viability of development is also relevant.
The question is whether demanding higher discount levels on First Homes will create a
financial burden on developers that leads them to argue either that the discount level is
not feasible or that the total amount of Affordable Housing may need to be decreased.
This could effectively sacrifice the provision of affordable rented housing to provide a
more attractive First Homes product. The issue of development viability is a specialist
matter involving analysis of land values and build costs that is outside the scope of this
assessment. If the East Bergholt Neighbourhood Plan Group intend to set a higher First
Homes discount level than that set at district level, further discussions with the LPA are
advised.
4.30 Shared ownership appears to be similar to First Homes but is broadly accessible to the
same groups. Government has recently announced that the minimum equity share for
shared ownership will fall to 10% of the property value.
5
If this is delivered in the NA, it
will make shared ownership easier to access for more people. However, while the
income threshold for a 10% equity shared ownership home is lower, this product may
not necessarily be more attractive than the alternatives (such as shared ownership at
higher equity shares and First Homes) for those who can afford them.
4.31 Rent to Buy provides households with the option to rent at a discount whilst saving for a
deposit to buy their property within a set period (usually within 7 years). The income
5
The previous minimum equity share was 25%. This change took effect from 28 June 2021 and transitional arrangements are in place for
planning policy documents that are prepared during the implementation timeframe. Changes are also introduced to make the process of
staircasing to full ownership more gradual with lower minimum increments of 1%. The ministerial statement confirming and detailing the
changes is available here: https://questions-statements.parliament.uk/written-statements/detail/2021-05-24/hlws48.
East Bergholt Neighbourhood Plan Housing Needs Assessment
24
required to access Rent to Buy is assumed to be the same as that required to afford
market rents. However, affordability to local households would depend on how rents are
set. If Rent to Buy is offered at a discount to entry level rents, this would expand this
route to home ownership quite significantly, but not to LQ earners. However, discounts
on average rents would make Rent to Buy affordability, in terms of the household income
required, comparable to First Homes and Shared Ownership. However, for some
households, the availability of a deposit rather than income level per se is the key barrier
to accessing home ownership. Rent to Buy may therefore offer a useful product to meet
the needs of some households.
4.32 These three affordable home ownership products need to be considered in relation to
what they offer occupants in the long term beyond simply being affordable to access or
not:
• First Homes allow for a greater ownership stake in the property, enabling occupiers
to benefit from price appreciation over time. Monthly outgoings are also limited to
mortgage costs alone, which tend to be cheaper than renting.
• Shared ownership at high equity shares performs a similar function to First Homes,
but there are additional costs associated with the rented portion.
• Shared ownership at low equity shares can usually be accessed by lower earning
households (than First Homes) and requires a smaller deposit. However, this is a
potentially less attractive route to eventual ownership because monthly outgoings
remain high. The occupant has to pay a significant monthly rent as well as service
charges and other costs, so it can be harder for them to save funds to buy out a
greater share in the property over time.
• Rent to Buy requires no deposit, thereby benefitting those with sufficient incomes
but low savings. It is more attractive than renting but results in a much slower
accumulation of the funds that can provide an eventual route to ownership than the
other tenures discussed above.
Affordable rented housing
4.33 Affordable rents set out in the table above are substantially below market rents. Whilst
affordable rents can be set at up to 80% of market rents, in many locations Registered
Providers (housing associations) set them to ensure that they are affordable to those
claiming housing benefit, i.e. at or below Local Housing Allowance levels. This means
that they are in practice below 80% of market levels. This appears to be the case in East
Bergholt.
4.34 Affordable rented housing is generally affordable to households with one and two lower
earners depending on their household size (average earning households are unlikely to
be eligible). However, many individuals will, if unable to secure a social rented dwelling
require additional subsidy through Housing Benefit to access housing.
4.35 The evidence in this chapter suggests that the affordable rented sector performs a vital
function in East Bergholt as the only option for a large segment of those in the greatest
East Bergholt Neighbourhood Plan Housing Needs Assessment
25
need. Social rents are cheaper and would therefore leave households on lower earnings
better off and better able to afford their other living costs, such as food and fuel etc.
Where households are supported by housing benefit the difference in the cost of
affordable and social rents may be irrelevant as the level of housing benefit flexes
according to the rent. This means that households supported by housing benefit may be
no better off in social rented accommodation because they receive a lower rate of
housing benefit to cover their rent.
East Bergholt Neighbourhood Plan Housing Needs Assessment
26
Estimates of the need for Affordable Housing
4.36 This section seeks to quantify the long-term potential need for Affordable
Housing, which should be considered separately for affordable rented housing
and affordable routes to ownership. The appropriate approach is taken based on
the evidence available at Local Authority and NA scale.
4.37 The relevant SHMA for Babergh was conducted in 2017. Given that the current
assessment is over 6 years old, it is likely that the figures presented in this
document do not reflect the current need for Affordable Housing in the District
and its constituent settlements. As such, AECOM have provided new estimates
for East Bergholt specifically.
AECOM Estimates
4.38 AECOM estimates an annual surplus (rather than need) of 1 affordable rented
homes per annum in East Bergholt, equating to a total of 15 over the plan period.
The estimate and assumptions used are detailed in Appendix D and summarised
in Table 4-5 below. This surplus is largely for social/affordable rent as it relates to
households who live in unsuitable housing and who cannot afford to access
market rents.
4.39 This result may initially be surprising since there is understood to be a current
backlog of need (in the region of 21 households). The reason for the affordable
rented housing need being met over the long-term is that model assumes a rate
of turnover in the existing stock: of the affordable rented accommodation existing
currently, it can be expected that some will come vacant in any given year as
their current occupants move to a new location, pass away or cease to be eligible
as their circumstances change. Because of the size of the existing stock, and
historic turnover rates, existing stock is able to satisfy the projected newly arising
need as well as some of the backlog, which is effectively spread out over the 10-
year period to produce an annualized figure.
4.40 An important caveat to this finding is that the NA may be meeting wider needs
within the District. As such, whilst it may be possible to address localised needs
through the existing stock, new affordable rented housing may be required to
continue to provide homes for households in acute need living elsewhere in the
wider area.
4.41 A further caveat worth emphasizing is that one unit of Affordable Housing does
not necessarily service one household worth of need, since the unit might have
2 bedrooms while the applicant household might require 4 bedrooms, may be
located in an inappropriate location, or be otherwise unsuitable.
4.42 As such, it may be appropriate for East Bergholt to encourage the delivery of
some affordable rented housing, with the understanding even if this would meet
all of the localised need, it may also help to meet needs from elsewhere in the
district. The NA’s wider strategic role in the delivery of Affordable Housing should
be discussed with the LPA.
East Bergholt Neighbourhood Plan Housing Needs Assessment
27
Table 4-5: Estimate of need for Affordable Housing for rent in East Bergholt
Component of need or supply in the AECOM estimate Per annum
Current need 1.2
Newly arising need 1.1
Supply 3.3
Net surplus 0.9
Source: AECOM model summary of estimates. Full estimate included in Appendix D
4.43 AECOM estimate potential demand for 5 affordable home ownership dwellings
per annum in East Bergholt, equating to a total of 76 over the Neighbourhood
Plan period. The estimate and assumptions used are detailed in Appendix D and
summarised in Table 4-6 below.
4.44 It is important to keep in mind that the households identified in this estimate are,
by and large, adequately housed in the private rented sector, Affordable Housing,
or living in other circumstances. They do not necessarily lack their own housing
but would prefer to buy rather than rent. They have been included in the national
planning definition of those in need of Affordable Housing, but their needs are
less acute than those on the waiting list for affordable rented housing.
Table 4-6: Estimate of need for Affordable Housing for sale in East Bergholt
Component of need or supply in the AECOM estimate Per annum
Current need 4.0
Newly arising need 0.6
Supply 0.2
Net shortfall 4.5
Source: AECOM model summary of estimates. Full estimate included in Appendix D
Evidence in the SHMA
4.45 A SHMA was undertaken for Ipswich and Waveney in 2017. This study estimates
the need for affordable housing in the district based on analysis of the Council’s
housing waiting list and analysis of other data sets in line with Planning Practice
Guidance at the time.
4.46 The SHMA identifies the need for 508 additional affordable homes in the housing
market area as a whole (including Ipswich, Babergh, Mid Suffolk and Suffolk
Coastal).
4.47 The SHMA uses 2014-2015 ONS population figures that indicate there were
449,499 people living in the HMA. When the SHMA projection of 508 additional
Affordable Homes is pro-rated to East Bergholt based on its fair share of the
population (East Bergholt representing 0.62% of the ONS population figures
used in the SHMA), this equates to 3.2 units per annum or 54.4 over the
East Bergholt Neighbourhood Plan Housing Needs Assessment
28
Neighbourhood Plan period (2023 – 2040). The SHMA does not differentiate
between affordable tenures.
4.48 Given the age of SHMA it is suggested that AECOM’s modelling (using 2021
Census data and up to date waiting lists) represents a more accurate picture of
the current need for Affordable Housing in East Bergholt. However, the disparity
between the two figures produced from each source is worthy of note, and would
appear to justify continuing to secure some affordable rented housing in the NA
where possible.
Affordable Housing policies in Neighbourhood Plans
4.49 This section outlines a common Neighbourhood Plan policy level around the
tenure mix of affordable housing, provides a recommendation and summarises
relevant considerations.
Application of Local Plan policies
4.50 Part 1 of the Babergh and Mid Suffolk Local Plan requires 35% of all new housing
to be affordable. Given that Affordable Housing made up 8% of new housing in
East Bergholt over the last decade according to Babergh completions figures, it
is understood that this target is not usually met on sites in the NA.
4.51 The overall proportion of housing that must be affordable is not an area of policy
that a Neighbourhood Plan can usually influence, but it is worth emphasizing that
the HNA finds there to be robust evidence of need for Affordable Housing in the
NA, and every effort should be made to maximise delivery where viable.
Changing or influencing the overall proportion of housing that must be affordable
is uncommon in Neighbourhood Plans and would demand a high standard of
evidence to depart from the Local Plan. If this is of interest, it should first be
discussed with the LPA to ensure their support and to determine what additional
evidence (e.g. about development viability) would be needed.
4.52 How the Affordable Housing that comes forward through mainstream
development sites is broken down into specific tenures – such as the balance
between rented tenures and routes to home ownership – is informed by the latest
evidence.
4.53 Babergh and Mid Suffolk (in their joint working capacity) have, however,
highlighted the requirement that emerging Neighbourhood Plans in the area are
in general conformity with the emerging Joint Local Plan and emphasised that
this should apply to Affordable Housing policy. One specific point of note is that
the council seeks to put in place Affordable Housing policies where affordable
housing units (where appropriate) are allocated to households with a local
connection to either Babergh or Mid Suffolk, rather than to specific parishes or
Neighbourhood Areas (an exception to this is Rural Exception Sites and
Community Land Trusts). As such, the aim is to meet District-wide needs in the
context of the parish rather than solely to meet parish-level needs.
East Bergholt Neighbourhood Plan Housing Needs Assessment
29
Affordable Housing at Neighbourhood level
4.54 The HNA can provide more localised evidence and this may be used to support
Neighbourhood Plan polices. This section suggests an Affordable Housing
tenure mix that might be suitable for East Bergholt on the basis of identified
housing need and a range of other considerations detailed in Appendix D.
4.55 As noted above, Babergh and Mid Suffolk has expressed a desire for
Neighbourhood Development Plans to reflect a general conformity with the Joint
Local Plan and adopted Local Plans for each district, and that Neighbourhood
Development Plans adopt policies which contribute toward the wider needs of
the District.
4.56 Part 1 of the Joint Local Plan seeks a tenure mix where 56% of new Affordable
Homes are provided as social/affordable rent, 25% are shared ownership and
19% are discount home ownership / First Homes. The tenure mix included below
is a response to the desired housing mix from Babergh and Mid Suffolk, which
the evidence gather in this HNA suggests is also an appropriate means of
meeting localised needs as far as is practically possible.
4.57 The indicative mix below has been amended slightly to provide the full 25%
complement of First Homes in line with the national policy requirement. However,
Babergh and Mid Suffolk have expressed concerns that provision of this
discounted tenure option may present operational difficulties. In any case, the
provision of Affordable Housing and the distribution of affordable tenures
emerging from the Neighbourhood Plan should be left as a matter to be
discussed between East Bergholt and Babergh.
East Bergholt Neighbourhood Plan Housing Needs Assessment
30
Table 4-6: Indicative tenure split (Affordable Housing)
Tenure Indicative mix Considerations and uncertainties
Routes to home
ownership, of which
44%
First Homes 25%
Product untested so uncertainties around
viability, developer, lenders and buyer
appetite etc.
Shared ownership 19%
Recently confirmed changes to the model
to allow purchases of 10% share – impact
on viability unknown.
RPs business plans currently reliant on
shared ownership model. Impact of
displacement by First Homes unknown.
Rent to Buy –
Emerging product with popularity and
effectiveness as yet unknown.
Impact of displacement by First Homes
unknown.
Affordable Housing
for rent, of which
56%
Social rent
To be set by
Registered
Providers
Uncertain how much funding available to
support this tenure in local area.
Uncertain whether RPs willing to
own/manage stock in this area.
Affordable rent
To be set by
Registered
Providers
Uncertain whether RPs willing to
own/manage stock in this area.
Source: AECOM calculations
Conclusions – Tenure and Affordability
Current tenure profile
4.58 Home ownership is the dominant tenure in East Bergholt at 79% of all
households, which is slightly higher than the district average. Of the remaining
households, 12% live in private rented housing and 10% in socially rented
housing, but are both smaller proportional shares than the district average.
4.59 Over the last decade, there has been a proportionally significant increase in
number of private renters, this is in contrast to much slower growth in the
proportional share of owner occupiers.
Housing Costs
4.60 Home values in East Bergholt have followed a clear upward trajectory over the
last decade. The current median house price (middle number when arranged
from lowest to highest) is £470,000, which is 62% higher than the median in
2013. The lower quartile price (the lowest 25% of prices, used as a good proxy
for entry-level housing) sits at £378,000, which is 60% higher than in 2013. It is
East Bergholt Neighbourhood Plan Housing Needs Assessment
31
worth noting that the current median house price in East Bergholt is significantly
more expensive that the current median for Babergh as a whole (£333,000).
4.61 AECOM has estimated the annual income required to afford various tenures of
housing in East Bergholt. These thresholds are compared to local incomes to
determine which options are the most appropriate for local people going forward.
The average household income in the NA was £48,900 in 2020, and the lower
quartile income (per person) was £19,700.
4.62 It was found that local households on average incomes are unable to access
even entry-level homes unless they have the advantage of a very large deposit.
The median house price would require an annual income of around 150% above
the current average. Private renting presents a similar affordability challenge,
generally only allowing average income households to access 2 bedroom rented
homes. Households made up of two lower earners could not afford the given
rental thresholds and would need to rely on social and affordable rented options.
4.63 Subsidised routes to home ownership like First Homes and shared ownership
are intended to target people who can afford to rent but not to buy. In East
Bergholt, there is a relatively large gap between the income needed to afford to
rent (£40,800) and to buy (£97,200), who may benefit from these products.
4.64 The discount on First Homes can be set at 30%, 40% or 50% in Neighbourhood
Plans. In East Bergholt, a 50% discount would be required to expand access to
home ownership to average earning households. However, it is worth noting a
50% discount is still only marginally affordable to average earners. If seeking to
take action on the appropriate level of discount for East Bergholt in the
Neighbourhood Plan, the Neighbourhood Plan Group are advised to discuss this
possibility with Babergh Council, who may be able to supply evidence of
development viability that is also relevant to this policy area.
4.65 Affordable rented housing appears generally affordable to households with two
lower earners (average earning households are unlikely to be eligible). Single
lower earners can afford average social rents and affordable rents but the lowest
earners, if unable to secure a social rented dwelling or additional subsidy, may
need to live in a room in a shared house using housing benefits.
The need for Affordable Housing
4.66 AECOM estimate a long-term surplus of 1 social/affordable dwelling per annum
over the East Bergholt Neighbourhood Plan period (2023 – 2040) when East
Bergholt’s needs are considered in isolation. Modelling contained in the main
body of the report also suggests that East Bergholt has a robust long-term
demand of 5 affordable home ownership dwellings per annum over the same
period.
4.67 AECOM’s modelling suggests that the delivery of home ownership dwellings
could be prioritised in East Bergholt in order to address potential demand and to
wider choice.
East Bergholt Neighbourhood Plan Housing Needs Assessment
32
4.68 However, it should be noted that the social/affordable housing modelling results
are chiefly a response to the size of the current housing waiting list, and the
relatively high proportion of social housing currently in the NA (details in main
body of the report). The households eligible for affordable home ownership
products typically do not necessarily lack their own housing but would prefer to
buy rather than rent. They have been included in the national planning definition
of those in need of Affordable Housing, but their needs are less acute than those
on the waiting list for affordable rented housing.
4.69 As such, there is justification for deviating from the modelling results to maintain
a supply of social/affordable housing to meet the needs of those facing the most
acute housing needs both currently on the waiting list in the NA and across the
wider borough.
Affordable Housing policy
4.70 Affordable Housing is typically provided and made financially viable by Local and
Neighbourhood Plan policies that require it to be included at a set proportion of
market housing developments. The adopted Part 1 of the Babergh and Mid
Suffolk Local Plan policy on this subject requires 35% of all new housing to be
affordable.
4.71 AECOM recommends that the tenure mix of Affordable Housing secured in future
years is meeting some of the significant potential demand for affordable home
ownership dwellings (44% – 25% First Homes and 19% Shared Ownership),
whilst also maintaining a healthy supply of social/affordable dwellings (56%).
Despite the low potential need for social/affordable rental units presented above,
a modest supply of social/affordable rental units is recommended as a response
to the particularly acute level of unaffordability established through this analysis
and a notable backlog on the waiting list for Affordable Housing. While
addressing any unmet need for social/affordable rental homes is important,
adopting the mix above would still increase the supply of affordable home
ownership products.
4.72 This indicative tenure mix deviates slightly from the emerging district wide policy
in its recommendation for Affordable Home Ownership, but is a response to the
national policy requirement for 25% of all Affordable Housing to be provided as
First Homes. There is no obligation to follow this recommendation or to depart
from emerging Local Plan policy if that is more in line with the community’s
objectives. However, this is a matter for discussion between the East Bergholt
Neighbourhood Plan group and the district council.
4.73 Affordable housing is typically provided and made financially viable by its
inclusion as a proportion of larger market developments, as guided by Local Plan
policy. However, if the community wishes to boost the supply of affordable
housing, there are other, more proactive routes available for its provision. For
example, using neighbourhood development orders, identifying exception sites
or developing community land trusts are all ways of boosting the supply of
affordable housing.
East Bergholt Neighbourhood Plan Housing Needs Assessment
33
5. Type and Size
Introduction
5.1 It is common for neighbourhood plans to include policies that influence what form
new housing should take in terms of type and size. This requires evidence of
what local people need.
5.2 This can be done using statistics to identify relevant trends and potential gaps in
the market. That is the focus of this chapter of the HNA. The evidence gathered
here can be used to justify planning policies either on its own or in combination
with survey results expressing the specific wants and concerns of local residents.
It will also build up a picture of the population and existing range of homes that
may provide useful context for the neighbourhood plan.
5.3 This chapter has three aims, each given its own sub-section:
• To establish what mix of housing exists in the NA at present;
• To describe characteristics of the local population that are relevant to housing
need; and
• To look to the future, considering how the population is likely to evolve and
what mix of homes would be most appropriate to build.
5.4 It is important to keep in mind that housing need is not an exact science. To get
from a set of facts about the population to an ideal mix of homes requires making
assumptions. For example, there are clear patterns about what size of home
families tend to live in at different stages of life. However, a variety of other
reasons sit behind people’s housing choices that are less easy to predict,
including wealth, accessibility requirements and personal preference. Some
trends can also change rapidly over time, such as the increasing preference for
home working.
5.5 The conclusions and recommendations given here are therefore not definitive.
Rather, they are what the statistics suggest future needs will look like based on
current trends. This is sufficient for justifying planning policies, but it is also
appropriate to take into account other factors and evidence if desired.
Definitions
• Dwelling type: whether a home is detached, semi-detached, terraced, a flat,
bungalow or other type. Which a household chooses to occupy tends to be
more about wealth and preference than a specific need.
• Dwelling size: how many rooms or bedrooms a home contains. While this
could also mean floor area or number of storeys, the number of bedrooms is
most reliably recorded in housing statistics. Bedroom numbers are also closely
linked to family size and life stage.
East Bergholt Neighbourhood Plan Housing Needs Assessment
34
• Household: a unit of people who live together, commonly a family, couple or
single person. Not all dwellings contain a household, including properties that
are vacant and second homes, so the number of dwellings and the number of
households in an area is usually different.
• Household composition: the specific combination of adults and children who
form a household. The Census offers a number of categories, for example
distinguishing between families with children who are dependent or non-
dependent (i.e. adults). ‘Other’ households in the Census include house-
sharers, groups of students, and multi-family households.
• Household life stage: the age of the lead member of a household – usually
the oldest adult, or what used to be called the ‘head of household’. Life stage
is correlated with dwelling size as well as wealth.
• Housing mix: the range of home sizes and types in an area.
• Over- and under-occupancy: the degree to which the size and composition
of a household lines up with the number of bedrooms in their home. If there
are more bedrooms than the household would be expected to need, the home
is considered under-occupied, and vice versa.
The current housing mix
5.6 This section establishes the current housing mix of East Bergholt, highlighting
recent changes to it and comparing the mix to wider averages.
5.7 Currently there are 1,226 dwellings in East Bergholt, occupied by 1,175
households (Census, 2021). Completions data provided by Babergh suggests
that there have been 51 new dwellings completed and 21 dwellings lost over the
last decade.
Dwelling type
5.8 Table 5-1 below shows that East Bergholt has a high proportion of detached
dwellings, which make up two-thirds of the overall housing stock. Cumulatively,
detached and semi-detached dwellings account for approximately 85% of the
overall housing stock. The remainder is made up of terraced dwellings and a
small proportion of flats.
5.9 The limited stock of flats explains the finding of the pervious chapter that sales
for this dwelling type were only recorded in three of the last years in the last
decade. Moreover, the high proportion of detached dwellings further highlights
the affordability challenges being experienced in the NA, and helps to explain the
generally high median house price in comparison to the wider district, with the
previous chapter highlighting that detached dwellings were significantly more
expensive than other dwelling types.
5.10 It should be noted that the 2021 total is slightly smaller than the total for 2011.
This is because the table compares dwellings in 2011 with households in 2021,
due to a change in how Census data for this metric is presented. However, when
East Bergholt Neighbourhood Plan Housing Needs Assessment
35
comparing the two data sets there is little proportional variation between the two.
Given the completions data provided by Babergh and Mid Suffolk does not
express significant development over the last decade it is unlikely that dwelling
totals from the 2021 Census will deviate significantly from the household totals
in terms of the proportional share of different housing types.
Table 5-1: Accommodation type, East Bergholt, 2011-2021
Type 2011 % 2021 %
Detached 744 62.9% 732 62.2%
Semi-detached 226 19.1% 225 19.1%
Terrace 169 14.3% 170 14.5%
Flat 42 3.6% 36 3.1%
Total 1,182 1,176
Source: ONS 2021 and 2011, VOA 2021, AECOM Calculations
5.11 Table 5-2 compares the NA mix to wider benchmarks. It shows that East
Bergholt’s housing stock is quite unusual when compared to the wider district,
with the NA being characterised by a much higher proportion of detached
dwellings. In comparison, there is a smaller proportional share of the other
housing types that are more common across the district.
5.12 This would go some way to explain the high median house price in the NA when
compared to the wider district, with a much higher proportion of more expensive
detached dwellings present in the NA than is common across Babergh.
Table 5-2: Accommodation type, various geographies, 2021
Type East Bergholt Babergh England
Detached 62.2% 41.7% 22.9%
Semi-detached 19.1% 30.1% 31.5%
Terrace 14.5% 20.6% 23.0%
Flat 3.1% 7.2% 22.2%
Source: Census 2021, AECOM Calculations
Dwelling size
5.13 Table 5-3 below presents the current housing mix in terms of size. It shows that
East Bergholt has a high proportion of larger dwellings, with more than 3
bedrooms occupying over three-quarters of the overall housing stock and in turn
a very small proportion of 1 bed homes.
5.14 The table also presents figures from 2011 to show how the mix has changed over
the last 10 years. There are a few significant changes over the last decade, but
it is worth noting the increase in the number of larger 4+ bedroom homes.
East Bergholt Neighbourhood Plan Housing Needs Assessment
36
Table 5-3: Dwelling size (bedrooms), East Bergholt, 2011-2021
Number of bedrooms 2011 % 2021 %
1 31 2.7% 24 2.0%
2 232 20.5% 239 20.2%
3 475 41.9% 456 38.6%
4+ 395 34.9% 462 39.1%
Total 1,133 1,181
Source: ONS 2021 and 2011, AECOM Calculations
5.15 Again, it is useful to look at the percentage breakdown of dwelling sizes in
comparison with the wider district and country. Table 5-4 shows that the housing
profile in East Bergholt differs from the average across the district and country,
with a much larger proportion of larger 4+ bedroom homes.
Table 5-4: Dwelling size (bedrooms), various geographies, 2021
Number of
bedrooms
East Bergholt Babergh England
1 2.0% 6.7% 11.6%
2 20.2% 24.7% 27.3%
3 38.6% 40.9% 40.0%
4+ 39.1% 27.8% 21.1%
Source: Census 2021, AECOM Calculations
Population characteristics
5.16 This section examines key characteristics of the local population that have a
bearing on what housing might be needed in future years. Where available,
recent data is used. However, for some information it is necessary to fall back on
the 2011 Census.
Age
5.17 Table 5-5 shows the most recent age structure of the NA population, alongside
2011 Census figures. The overall population in East Bergholt contracted by 1.8%
over the last decade, which equates to 61 less people living in the NA than there
were in 2011. The table shows that the population contraction is generally being
experienced in the younger population, with each cohort younger than 45 having
less people than the same grouping in 2011. The contraction in the younger
population is in contrast to growth in the older population, with the cohort aged
85+ showing the most notable growth. The figures presented below suggest a
general trend within the NA population, with younger people moving out of East
Bergholt and an older population moving in. Together, these changes indicate a
gradual aging of the East Bergholt population.
East Bergholt Neighbourhood Plan Housing Needs Assessment
37
Table 5-5: Age structure of East Bergholt, 2011 and 2021
Age group 2011 (Census) 2021 (Census) Change
0-14 466 16.9% 357 13.2% -23.4%
15-24 270 9.8% 257 9.5% -4.8%
25-44 489 17.7% 417 15.4% -14.7%
45-64 854 30.9% 862 31.8% 0.9%
65-84 602 21.8% 698 25.7% 15.9%
85 and over 84 3.0% 123 4.5% 46.4%
Total 2,765 100.0% 2,714 100.0% -1.8%
Source: ONS 2011, ONS 2021, AECOM Calculations
5.18 For context, it is useful to look at the NA population structure alongside that of
the district and country. Figure 5-1 (using 2021 Census data) reflects the analysis
directly above, and suggests there is an older population in East Bergholt when
compared to the district and national averages.
Figure 5-1: Age structure in East Bergholt, 2021
Source: ONS 2021, AECOM Calculations
Household composition and occupancy
5.19 Household composition (the combination and relationships of adults and children
in a dwelling) is an important factor in the kinds of housing needed over the
Neighbourhood Plan period. Table 5-6 shows that East Bergholt has a slightly
higher proportion of ‘family’ households than Babergh, and a smaller proportion
of single person households in turn. The NA also has a higher proportion of older
households (families and older people) than the district.
0.0%
5.0%
10.0%
15.0%
20.0%
25.0%
30.0%
35.0%
0-14 15-24 25-44 45-64 65-8485 and over
Percentage of Population
East Bergholt Babergh England
East Bergholt Neighbourhood Plan Housing Needs Assessment
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Table 5-6: Household composition, East Bergholt, 2021
Household
composition
East
Bergholt
Babergh England
One person
household
Total
26.9% 28.3% 30.1%
Aged 66 and over 17.6% 15.6% 12.8%
Other 9.2% 12.7% 17.3%
One family only Total 69.1% 67.7% 63.1%
All aged 66 and over 17.6% 14.8% 9.2%
With no children 19.4% 19.5% 16.8%
With dependent children 22.1% 22.7% 25.8%
With non-dependent
children
6
10.1% 10.4% 10.5%
Other
household types
Total
4.0% 3.9% 6.9%
Source: ONS 2021, AECOM Calculations
5.20 The tendency of households to over- or under-occupy their homes is another
relevant consideration to the future size needs of the NA. A person is considered
to under-occupy their home when there are more bedrooms in their home than a
family of their size and composition would normally be expected to need. This is
expressed as an occupancy rating of +1 or +2, indicating that there is one surplus
bedroom or at least two surplus bedrooms (respectively). Over-occupancy works
in the same way, with a rating of -1 indicating at least one bedroom too few.
5.21 The table shows that the NA’s population is generally well housed, with only 0.5%
of households being overcrowded. However, the data shows that the majority of
households in the parish tend to have more at least one more bedroom than they
would be expected to need (90%). This dynamic appears to be most prevalent in
the older population.
Table 5-7: Occupancy rating by age in East Bergholt, 2021
Household type +2 rating
+1
rating
0 rating
-1 rating
Family 66+ 81.1% 17.5% 1.5% 0.0%
Single person 66+ 62.8% 31.9% 5.3% 0.0%
Family under 66 – no children 80.1% 19.0% 0.9% 0.0%
Family under 66 – dependent children 43.2% 34.0% 21.2% 1.5%
Family under 66 – adult children 32.2% 42.6% 25.2% 0.0%
Single person under 66 47.6% 45.7% 6.7% 0.0%
All households 59.6% 29.5% 10.4% 0.5%
Source: ONS 2021, AECOM Calculations
5.22 As noted in the introduction to this chapter, the life stage of households is strongly
correlated with the size of home they tend to occupy. Figure 5-2 sets out this
relationship for Babergh in 2011 (because this data is not available at smaller
6
Refers to households containing children who are older than 18 e.g students or young working people living at home.
East Bergholt Neighbourhood Plan Housing Needs Assessment
39
scales). The graph shows how the youngest households tend to occupy the
smallest dwellings, before rapidly taking up larger homes as their families
expand, and then more gradually downsizing to smaller homes again as they
age.
Figure 5-2: Age of household reference person by dwelling size in Babergh, 2011
Source: ONS 2011, AECOM Calculations
Future population and size needs
5.23 This section projects the future age profile of the population in East Bergholt at
the end of the Neighbourhood Plan period and then estimates the mix of dwelling
sizes they may need.
Age
5.24 The result of applying Local Authority level household projections to the age
profile of East Bergholt households in 2011 is shown in Table 5-8. This makes
clear that the general aging of the East Bergholt population is expected to
continue over the Neighbourhood Plan period, with the population aged 65+
expected to grow by 81% by 2040 while other age groups stagnate or contract.
Table 5-8: Projected age of households, East Bergholt, 2011 – 2040
Year
24 and
under
25 to 34 35 to 54 55 to 64
65 and
over
2011 11 52 405 226 439
2040 10 53 377 235 793
% change 2011-
2040
-8% 2% -7% 4% 81%
Source: AECOM Calculations
5.25 The demographic change discussed above can be translated into an ideal mix of
dwelling sizes. This is achieved through a model that maps the dwelling size
preferences by life stage shown earlier (in Figure 5-2) onto the projected age
profile for the NA in Table 5-8 immediately above. The resulting ‘ideal’ future mix
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Age 16
to 24
Age 25
to 29
Age 30
to 34
Age 35
to 39
Age 40
to 44
Age 45
to 49
Age 50
to 54
Age 55
to 59
Age 60
to 64
Age 65
to 69
Age 70
to 74
Age 75
to 79
Age 80
to 84
Age 85
or over
1 bedroom 2 bedrooms 3 bedrooms 4 bedrooms 5 bedrooms 6 or more bedrooms
East Bergholt Neighbourhood Plan Housing Needs Assessment
40
of dwelling sizes can then be compared to the current stock of housing to identify
how future development might best fill the gaps.
5.26 This approach has limitations, in that it embeds existing size preferences and
does not anticipate changes in what people want from their homes. As such, it is
appropriate for the results to be taken as a baseline scenario – what would occur
if current trends persisted. It may well be the intention of the community to
intervene to produce a different outcome more in line with their interpretation of
emerging trends and their place- and community-shaping objectives. Layering
these factors on top of the indicative picture provided by this model is appropriate
for the purpose of drafting neighbourhood plan policies.
5.27 The result of this exercise is presented in Table 5-9. It suggests that in order to
diversify its housing offer, any future housing delivery should focus on providing
smaller homes with between 1 and 3 bedrooms. It should be noted that this
suggested mix is chiefly a response to projected changes to the population and
to differences between local size characteristics and those of the wider district.
5.28 If the neighbourhood plan is seeking to influence the future size mix of homes in
the parish it would be worthwhile to consider these figures alongside the average
price of housing presented in the previous chapter. Policies on housing should
reflect the lived experience of persons in parish and aim to deliver housing that
meets the needs of the population, whilst also being within reach of average
earners in terms of pricing.
Table 5-9: Suggested dwelling size mix to 2040, East Bergholt
Number of
bedrooms
Current mix
(2011)
Suggested mix
(2040)
Balance of new
housing to reach
suggested mix
1 2.6% 6.5% 18.3%
2 20.5% 26.4% 42.9%
3 41.9% 41.9% 38.7%
4 26.0% 19.5% 0.0%
5+ 8.8% 5.7% 0.0%
Source: AECOM Calculations
5.29 The following points sense-check the results of the model against other evidence
and suggest ways to interpret them when thinking about policy options.
• The preceding chapter found that affordability is a serious and worsening
challenge in the NA. While the provision of Affordable Housing (subsidised
tenure products) is one way to combat this, another is to ensure that homes
come forward which are of an appropriate size, type and density for local
residents’ budgets.
• Continuing to provide smaller homes with fewer bedrooms would help to
address this situation, although it should be considered whether large
numbers of 1-bedroom homes are suitable given the area’s character and
current density.
East Bergholt Neighbourhood Plan Housing Needs Assessment
41
• To best meet the needs of the growing cohort of older households expected
to be present by the end of the Plan period, it should also be considered
whether the existing options are well tailored to older people’s requirements
in terms of space, flexibility, quality, location and accessibility.
• Variety should be sought within the mid-sized homes that are built in future to
attract both newly forming households on lower budgets and older households
with equity from their existing larger homes. While the number of bedrooms
required may be similar, other preferences and levels of purchasing power
could be very different. Facilitating downsizing among older households may
also release those larger homes for use by families who need more bedrooms
if they existing stock of larger homes is sufficiently affordable.
Tenure
5.30 The recommendation discussed immediately above applies to all housing in the
NA over the Plan period. This is considered proportionate for devising policy at
neighbourhood scale. However, in practice different size mixes may be
appropriate for market housing and Affordable Housing. While this distinction
may not be appropriate to make in Neighbourhood Plan policy, since Local
Authorities tend to define the precise mix of Affordable Housing required on
applicable sites, it is worth thinking through the factors at play.
5.31 Generally speaking, the size mix needed within affordable tenures, particularly
affordable and social rent, is smaller than the size mix of market housing. This is
because there tend to be higher proportions of single people and couples in need
of affordable rented housing, and they are likely to be eligible only for 1 or 2
bedroom properties. In contrast, people buying their own homes tend to want
more space than they technically ‘need’, such as spare rooms for guests, home
working or other uses. This fact is established in the data on under-occupancy
presented earlier in this chapter.
5.32 There are three key sources of information for thinking through the size needs of
different categories. These are:
• The relevant SHMA or LHNA for the Local Authority, which will (usually) set
out the projected need by size within each tenure over the long-term. In this
case, the SHMA recommends the following tenure mix for Affordable
Housing:
– 1 Bed: 10.6%
– 2 Bed: 30.7%
– 3 Bed: 39.4%
– 4 Bed: 19.3%
• The waiting list for affordable rented housing, kept by the Local Authority.
This provides a more current snapshot of the size needs of applicant
households. As this changes over time, individual planning applications can
be decided in ways that meet evolving needs. For East Bergholt, the
majority of applications for Affordable Housing are for 1/2 bedroom homes.
East Bergholt Neighbourhood Plan Housing Needs Assessment
42
• Any relevant household survey or consultation work in the NA can also
highlight any specific gaps in the market within particular segments of the
population.
5.33 To summarise, the overall size mix recommendation presented above applies
generally to new housing in the NA. Within this mix, Affordable Housing might
require a greater weighting towards smaller sizes while market homes focus on
mid-sized homes and some larger options. It is not necessary (and is potentially
not appropriate) for Neighbourhood Plans to be prescriptive about the size mix
within different tenures, but a range of data sources exist that indicate a direction
of travel, which Local Planning Authorities will draw upon when determining
applications, and which it is possible for the neighbourhood planners to monitor.
Type
5.34 Planning policy also tends to be less prescriptive about the mix of dwelling types
that are needed than the mix of home sizes. This is because the choice to occupy
a terraced rather than a detached home, for example, is primarily a matter of
wealth, personal preference, and the amount of outdoor space or other features
sought than ‘need’ in the strict sense. This stands in contrast to the matter of
dwelling size, where it can be more clearly established that a household with a
certain number of members, closely correlated with age, requires a particular
number of bedrooms.
5.35 The key distinctions when it comes to dwelling type are between flats and houses
and, to a lesser extent, bungalows, each of which tend to appeal to occupants
with different life circumstances. However, it remains difficult to generalise about
this, particularly when drawing on demographic evidence.
5.36 The benefits of delivering a certain blend of dwelling types are more closely
related to affordability, which is clearly established as an issue in East Bergholt,
and which favours more dense options (e.g. terraces and flats). This imperative
to improve affordability is often in conflict with matters of character, which in rural
areas tend to favour lower density options that blend in with the existing built
environment. This is particularly relevant in the case of flats, a large block of
which may not be a welcome proposition in the NA. That said, it is possible to
deliver flats in the form of low-rise maisonettes that resemble terraces from street
level, which can counter this issue.
5.37 In summary, there is a balance to be struck between, on the one hand, improving
affordability and choice in the market by encouraging flats and terraces, and, on
the other hand, preserving the distinctive character and other features that
residents like about the NA today. How far the Neighbourhood Plan should guide
on this issue, and in what direction, is a policy decision for the East Bergholt
Neighbourhood Plan Group and community to consider.
East Bergholt Neighbourhood Plan Housing Needs Assessment
43
Conclusions – Type and Size
The current housing mix
5.38 The East Bergholt housing stock is significantly biased toward detached homes,
which make up approximately two thirds of the overall stock. Moreover,
cumulatively detached and semi detached dwellings make up close to 85% of
the housing stock. The remainder is made up of terraced dwellings and a smaller
number of flats.
5.39 The size profile of homes in East Bergholt is quite similar to the district, with a
much higher proportion of detached dwellings and a smaller proportion of the
other housing types.
5.40 The NA has a higher proportion of larger 4+ bedroom homes than is common
across Babergh.
Population characteristics
5.41 The East Bergholt population has declined by 1.8% over the last decade. There
is a distinction between the younger and older population in East Bergholt, with
each cohort aged younger than 64 showing population decline and the older
population showing proportional growth, notably in those aged 85+.
5.42 Household projections suggest that East Bergholt’s population will continue to
age over the NP period, with a potential increase of 81% in the population aged
65 and over. The projections also suggest either slow growth or a contraction in
their share over the overall population over the NP period. It should be noted that
these estimates are informed by population projections for the wider district and
may be more moderate in reality.
Future population and size needs
5.43 It is possible to estimate the size mix of future homes than might best
accommodate demographic trends and address imbalances in the existing
housing stock. The result of this process suggests that new developments should
deliver a variety of dwellings with between 1-3 bedrooms, with a focus on 2/3
bedroom homes.
5.44 It is important to remember that other factors should be considered in determining
the dwelling mix that is desirable in the NA or on any particular site. These include
the specific characteristics of the nearby stock of housing (such as its condition
and design), the role of the NA or site within the wider housing market area
(linked to any Local Authority strategies or plans) and site-specific factors. The
size mix of Affordable Housing also tends to be considered separately from
market housing by the Local Planning Authority and to focus on the smaller units
for which the vast majority of those on the waiting list in East Bergholt are eligible.
East Bergholt Neighbourhood Plan Housing Needs Assessment
44
6. Specialist housing for older people
Introduction
6.1 It is relatively common for neighbourhood plans in areas with aging populations
to include policies relating to specialist housing for older people. This chapter
considers in detail the specialist housing needs of older people in East Bergholt.
It focuses on specialist forms of provision but recognises that the majority of older
people will live in the mainstream housing stock. The approach is as follows:
• To review the current provision of specialist housing in the NA;
• To estimate the potential demand for this form of accommodation with
reference to the projected growth in the older population and current rates
of mobility limitation; and
• To discuss the potential for meeting this need through adaptations to the
mainstream stock and other additional considerations.
6.2 Because of the wide variation in the level of support needed, as well as the
financial capabilities of those affected, the estimates of need presented here
should be viewed with caution – as an idea of the broad scale of potential need
rather than an obligatory target that must be met.
6.3 It is important to note that the need for housing for particular groups of people
may well exceed, or be proportionally high in relation to, the total housing need
or requirement. This is because the needs of particular groups will often be
calculated having consideration to the whole population of an area as opposed
to the projected new households which form the baseline for estimating housing
need overall.
7
6.4 This study covers the need for housing, i.e. buildings that the planning system
classifies as Use Class C3 (private dwellings).
8
Residences that fall into Use
Class C2 (institutions including prisons, boarding schools and some care homes
for older people) are largely beyond the scope of this research. However, it is
possible to estimate the likely need for residential and nursing care over the
Neighbourhood Plan period.
6.5 The distinction between care homes for older people that fall into use class C2
and those where accommodation is counted as C3 is blurred. As such, the
findings of this chapter may justify the provision of extra-care C3 housing and/or
C2 care home units, but it is not possible to state definitively how much of each
would be required. C3 specialist accommodation is typically self-contained with
its own front door, made available on an individual basis with support provided in
7
See Paragraph: 017 Reference ID: 2a-017-20190220, at https://www.gov.uk/guidance/housing-and-economic-development-
needs-assessments)
8
For a full description of Planning Use Classes, please refer to
https://www.planningportal.co.uk/info/200130/common_projects/9/change_of_use
East Bergholt Neighbourhood Plan Housing Needs Assessment
45
the home or not at all if the resident does not require it, and offered for sale or
rent on the open market.
Definitions
• Older people: people over retirement age, ranging from the active newly retired
to the very frail elderly. Their housing needs tend to encompass accessible and
adaptable general needs housing as well as the full spectrum of retirement and
specialised housing offering additional care.
• Specialist housing for older people: a wide range of housing types
specifically aimed at older people, which may often be restricted to those in
certain older age groups. This could include residential institutions, sheltered
housing, extra care housing, retirement housing and a range of other potential
types of housing which has been designed and built to serve the needs of older
people, including often providing care or other additional services.
• Sheltered Housing
9
: self-contained flats or bungalows where all the residents
are older people. Schemes on the whole provide independent, self-contained
homes, either to rent or buy. Properties in most schemes have features like
raised electric sockets, lowered worktops, walk-in showers, and so on, as well
as being linked to an emergency alarm service. Some will be designed to
accommodate wheelchair users. Managed schemes will also usually have
some shared or communal facilities such as a lounge for residents to meet, a
laundry, guest flats and gardens.
• Extra Care Housing: housing which usually consists of purpose-built or
adapted flats or bungalows with a medium to high level of care available if
required. Residents are able to live independently with 24-hour access to
support services and staff, and meals are often also available. In some cases,
these developments are included in retirement communities or villages – the
intention is for residents to benefit from varying levels of care as time
progresses.
• Category M4(2): accessible and adaptable dwellings.
• Category M4(3): wheelchair user dwellings.
Specialist housing for older people
6.6 There is currently no provision of specialist accommodation in the NA at present.
The 2021 Census indicates that at this time there were 396 individuals aged 75
or over in East Bergholt.
Demographic characteristics
6.7 The starting point for estimating the need for specialist housing for older people
is to project how the overall number of older people in East Bergholt is likely to
change in future. This is calculated by extrapolating population projections from
9
See http://www.housingcare.org/jargon-sheltered-housing.aspx
East Bergholt Neighbourhood Plan Housing Needs Assessment
46
the ONS Sub-National Population Projections for Babergh. The results are set
out in Table 6-1.
6.8 The table estimates that by 2040 the population over 75 years old will make up
approximately 23% of the overall population, up from 16% in 2021. These
projections generally follow the trend identified in the previous chapter, which
suggests that the majority of population growth is expected in the older age
bracket.
6.9 A key assumption for the estimate given at the end of this section is that the older
people living in the NA currently are already suitably accommodated, either
because they occupy the existing stock of specialist accommodation, have made
appropriate adaptations to their own homes or do not require support or
adaptations. This is unlikely to be completely true, but it is not possible to
determine how many such individuals are inadequately housed without evidence
from a household survey (which itself may not give a complete picture). As such,
the growth in the older population rather than the total at the end of the Plan
period is the key output of this calculation.
Table 6-1: Modelled projection of older population in East Bergholt by end of
Plan period
Age group
2021 2040
East Bergholt Babergh East Bergholt Babergh
All ages 2,714 92,343 2,726 100,849
75+ 432 11,757 634 18,819
% 15.9% 12.7% 23.3% 18.7%
Source: ONS SNPP 2020, AECOM Calculations
6.10 The next step is to consider the need for different tenures of dwelling for older
people. It is assumed that those currently occupying their own home will wish to
do so for as long as practicably possible in future, even where downsizing or
moving into specialist accommodation. Equally, those who currently rent, either
in the private or social sectors, are projected to need affordable rented specialist
accommodation.
6.11 The 2011 55-75 age bracket is considered the best proxy for the group likely to
fall into need for specialist accommodation during the Plan period to 2040. The
top row in Table 6-2 outlines the tenure mix among households aged 55-75 at
Local Authority level, which indicates that the vast majority of older people own
their own homes, with some social renters and very few private renters.
6.12 The expected growth in the 75+ population in the NA is 238 additional individuals
by the end of the plan period. This can be converted into 170 households based
on the average number of people per household aged 75+ at Local Authority
scale. Multiplying this figure by the percentages of 55-75 year olds occupying
each tenure gives a breakdown of which tenures East Bergholt households are
likely to need in 2040, and is shown in the bottom row of Table 6-2.
East Bergholt Neighbourhood Plan Housing Needs Assessment
47
Table 6-2: Tenure of households aged 55-75 in Babergh (2011) and projected
aged 75+ in East Bergholt (2040)
All
owned
Owned
outright
Owned
(mortgage)
or Shared
Ownership
All
Rented
Social
rented
Private
rented
Living
rent
free
Babergh
(2011 mix)
82.2% 61.2% 21.1% 17.8% 9.9% 6.4% 1.5%
East
Bergholt
(2040
projection)
152 113 39 33 18 12 3
Source: Census 2011
6.13 It is also important to consider rates of disability by tenure. The tendency for
people in rented housing to have higher disability levels is well established. It
arises partly because people with more limiting disabilities tend to have lower
incomes. It also reflects the fact that as people develop support and care needs
they may find that the only suitable and affordable option to them is available in
the social rented sector. Table E-2 in Appendix E presents this data for East
Bergholt from the 2011 Census.
Future needs for specialist accommodation and adaptations
6.14 Based on the evidence outlined above, the number of households falling into
potential need for specialist accommodation over the Plan period is calculated to
be 79.
6.15 AECOM’s modelling, summarised in Table 6-3, is based on the assumption that
those whose day-to-day activities are limited a lot may need housing with care
(e.g. extra care housing, with significant on-site services, including potentially
medical services), while those with their day to day activities limited only a little
may simply need adaptations to their existing homes, or alternatively sheltered
or retirement living that can provide some degree of oversight or additional
services. However, it is important to note that, even those people who have high
support or care needs can often be supported to live in their own homes. This is
often reflected in policy of local authorities, with explicit aim to reduce the need
to commission increasing numbers of care home beds.
6.16 The table suggests there may be an opportunity to provide a large share of the
need for specialist housing in the NA through adaptions to the existing housing
stock and the provision of sheltered or retirement living. However, there remains
a robust demand for housing with care.
6.17 AECOMs modelling also suggest that the balance of tenure options in both forms
of specialist housing should be weighted in favour of market rather than socially
rented housing. This is because of the high rates of ownership among the
existing older population.
East Bergholt Neighbourhood Plan Housing Needs Assessment
48
Table 6-3: AECOM estimate of specialist housing for older people need in East
Bergholt by the end of the Plan period
Type Affordable Market Total
Housing with care 7 23 30
Adaptations, sheltered,
or retirement living
11 38 49
Total 18 61 79
Source: Census 2011, AECOM Calculations
6.18 It is worth comparing these findings with the recommendations of the Housing
Learning and Improvement Network (HLIN), one of the simplest and widely used
models estimating for the housing needs of older people. Table E-2 in Appendix
E reproduces the key assumptions of HLIN’s Strategic Housing for Older People
(SHOP) toolkit. Applying those assumptions to the growth in the older population
of East Bergholt results in a total of 65 specialist dwellings that might be required
to the end of the Plan period. This is set out in Table 6-4.
Table 6-4: HLIN estimate of specialist housing for older people need in East
Bergholt by the end of the Plan period
Type Affordable Market Total
Housing with care 8 10 18
Adaptations, sheltered,
or retirement living
16 31 47
Total 24 42 65
Source: Housing LIN, AECOM calculations
Further considerations
6.19 The above estimates suggest that potential need for specialist accommodation
could be in the range of 65-79 units over the Neighbourhood Plan period.
However, it may not be possible or appropriate to deliver this scale of new
accommodation. It is proportionally high in relation to the likely housing delivery
expectation in the NA, and therefore should not necessarily be prioritised to the
exclusion of other groups, such as those in need of Affordable Housing.
6.20 In addition, specialist housing for older people should only be provided in
sustainable, accessible locations that offer services and facilities, public transport
options, and the necessary workforce of carers and others.
6.21 Alongside the need for specialist housing to be provided in accessible locations,
another important requirement is for cost effectiveness and economies of scale.
This can be achieved by serving the specialist older persons housing needs
arising from a number of different locations and/or Neighbourhood Areas from a
single, centralised point (i.e. what is sometimes referred to as a ‘hub-and-spoke’
model).
East Bergholt Neighbourhood Plan Housing Needs Assessment
49
6.22 It is considered that East Bergholt’s position in the settlement hierarchy makes it
a relatively less suitable location for specialist accommodation on the basis of
the accessibility criteria and the considerations of cost-effectiveness above. As
such, noting that there is no specific requirement or obligation to provide the
specialist accommodation need arising from East Bergholt entirely within the
Neighbourhood Area boundaries, it is recommended it could be provided in a
‘hub and spoke’ model. In the case of East Bergholt, Manningtree is considered
to have potential to accommodate the specialist housing need arising from the
Neighbourhood Area (i.e. to be the hub in the hub-and-spoke model).
6.23 It is also important to emphasise that the potential need for specialist housing for
older people overlaps with the need for care home bedspaces and the need for
adaptations to mainstream housing. These topics are considered in the sections
below.
Care homes
6.24 Residential and nursing care homes are not defined as housing because they do
not provide self-contained accommodation where an older person can live
independently. Care home accommodation is defined as institutional
accommodation rather than housing.
6.25 However, residents of care homes may be similar in terms of their care and
support needs as those living in specialist housing, or even mainstream housing
with appropriate care and support delivered in their homes. There may be some
scope for older people who would otherwise have been accommodated in care
homes to meet their needs within specialist or mainstream housing if sufficient
appropriate accommodation can be provided. Nevertheless, there is likely to be
continued need for care home accommodation to meet more acute and severe
needs, and to offer choice to some older people and their families about how they
are cared for and supported.
6.26 Given the overlap between people who might enter care home accommodation
and those who might take up specialist housing or care and support in their own
home if available, estimates of the future need for care home accommodation,
as with estimates of the need for specialist housing above, are uncertain and
depend on both local and national policies, delivery, and the appetite of private
developers.
6.27 AECOM has estimated the likely need for care home accommodation over the
plan period, based on the HLIN SHOP toolkit prevalence rates for residential and
nursing care homes for older people (aged 75+). This estimate applied the
prevalence rates in the ‘More Choice, Greater Voice’ 2008 report which informed
the development of the HLIN toolkit. This report suggested that 65 residential
care beds per 1,000 people aged 75+ was an appropriate rate. For nursing care
beds this is an extra 45 care beds per 1,000 people aged 75+. Based on these
rates, applied to the growth in the older population for consistency with the
calculations above, it is estimated that in 2040 there would be a need for 15
East Bergholt Neighbourhood Plan Housing Needs Assessment
50
residential care beds and 11 nursing care beds in the NA. There is currently no
provision of residential care in the NA.
6.28 It is important to note that as these estimates relate to care homes (or the
population in institutions) rather than independent housing, these figures are in
addition to the overall need for housing in the NA. However, as discussed in this
section, some of the need for care home beds might be met by independent
housing accommodation and vice versa.
The Role of Mainstream Housing
6.29 The majority of older people live in mainstream housing and will continue to do
so all of their lives. Based on there currently being no provision of specialist
housing in the NA, it is expected that all of the East Bergholt population aged 75
and over is likely to live in the mainstream housing stock
10
.
6.30 It is not possible to be precise about how well older people are accommodated
within mainstream housing, in terms of whether their accommodation in suitable
to their needs and whether adequate care or support is provided within the home
when they need.
6.31 However, given that there is unlikely to be a large volume of additional specialist
supply during the Plan period, another key avenue to addressing those with
relevant needs is to discuss the standards of accessibility and adaptability in new
development to be met in the Local Plan with Babergh.
6.32 It is relatively common for Local Plans to require that all or a majority of new
housing meets Category M4(2) standards in response to the demographic shifts
being observed nationwide. Government is considering mandating M4(2) on
newly erected dwellings
11
, although changes to Building Regulations have not
yet been made.
6.33 The current adopted Local Plan policy LP06 provides explicit encouragement for
development to accommodate specific groups such as older people. Moreover,
Policy LP24 suggests that 50% of new housing that might be required to meet
national standards for accessibility and adaptability (Category M4(2)), or for
wheelchair users (Category M4(3)). The evidence gathered here may justify the
East Bergholt Neighbourhood Plan Group approaching the LPA to discuss setting
requirements on accessibility and adaptability at district level. It is unclear
whether Neighbourhood Plans can set their own requirements for the application
of the national standards of adaptability and accessibility for new housing and so
discussions with the LPA are advised if this is a key priority.
6.34 The proportion of new housing that might accommodate those using wheelchairs
is harder to define at small scales. Typically, at Local Authority scale, this might
be set with reference to the proportion of Affordable Housing applicants in the
11
See Raising accessibility standards for new homes: summary of consultation responses and government response –
GOV.UK (www.gov.uk)
East Bergholt Neighbourhood Plan Housing Needs Assessment
51
Local Authority area falling into this category or to wider data from surveys and
other sources where available.
6.35 The national average proportion of wheelchair users is either 0.6% if the
population using a wheelchair all of the time or 3% if the population using a
wheelchair part of the time. A common method for understanding how much of
the housing stock should be wheelchair accessible is applying these percentages
to any new housing stock which may come forward in future. However, as East
Bergholt does not currently have an active Housing Requirement Figure it is
difficult to project forward the need for wheelchair accessible housing that might
be expected or needed. However, when the HRF is known, applying the
percentage figures above will give the East Bergholt Neighbourhood Plan Group
an understanding of the potential need for this type of housing.
Conclusions – Specialist Housing for Older People
Characteristics of the current older population
6.36 There are currently estimated to be around 432 individuals aged 75 or over in
East Bergholt, a number that has grown from 318 in 2011 and is projected to rise
to 691 over by the end of the Neighbourhood Plan period (2040).
6.37 A clear majority (82%) of Babergh’s households aged between 55 and 75 in 2011
(and therefore likely to reach the 75+ bracket by 2041) are owner occupiers and
the remainder predominantly rent from a social landlord. This is important
because those currently owning will require specialist accommodation for market
purchase, being largely ineligible for subsidised housing, while those in private
or social rent will need to rely on subsidised rented housing because they are
unlikely to have the funds to buy.
Projected demographic change and need for specialist housing
6.38 The 75+ population of the NA is projected to increase from 16% to 23% of the
overall population between 2021 and 2040. The growth of the older population
should be converted into households because some older people will be
cohabiting. The projected growth in the older population points to 185 new
households made of persons aged 75+ over the Neighbourhood Plan period.
6.39 The potential need for specialist housing with some form of additional care for
older people can be estimated by bringing together data on population
projections, rates of disability, and what tenure of housing the current 55-75
cohort occupy in the NA. This can be sense-checked using a toolkit based on
national research.
6.40 The two methods for estimating the future need in East Bergholt produce a range
of 65 to 79 specialist accommodation units that might be required during the plan
period. These estimates are based on the projected growth of the older
population, thereby assuming that today’s older households are already well
accommodated.
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52
6.41 Broadly, between 60-75% of the need can be accommodated through market
purchase (as opposed to Affordable Housing). Moreover, between 60-70% of the
need can be accommodated through either sheltered accommodation or
adaptations to the existing housing stock, rather than new extra care options.
The potential need for care and nursing home beds in East Bergholt by 2040 can
be estimated at roughly 15.
6.42 The main unmet need in East Bergholt is for market sheltered accommodation
which may be satisfied by ensuring most or all new housing is accessible and
adaptable for people with lower support needs. Policy LP24 of the adopted Part
1 of the Babergh and Mid Suffolk Local Plan suggests that 50% of new dwellings
meet the requirements for accessible and adaptable dwellings under Part M4(2)
of Building Regulations. It is unknown whether East Bergholt is expecting any
delivery of specialist accommodation over the plan period.
East Bergholt Neighbourhood Plan Housing Needs Assessment
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7. Next Steps
Recommendations for next steps
7.1 This Neighbourhood Plan housing needs assessment aims to provide East
Bergholt Neighbourhood Plan Group with evidence on a range of housing trends
and issues from a range of relevant sources. We recommend that the
neighbourhood planners should, as a next step, discuss the contents and
conclusions with Babergh with a view to agreeing and formulating draft housing
policies, bearing the following in mind:
• All Neighbourhood Planning Basic Conditions, but in particular Condition E,
which is the need for the Neighbourhood Plan to be in general conformity
with the strategic policies of the adopted development plan;
• The views of Babergh;
• The views of local residents;
• The views of other relevant local stakeholders, including housing
developers and estate agents; and
• The numerous supply-side considerations, including local environmental
constraints, the location and characteristics of suitable land, and any
capacity work carried out by Babergh.
7.2 This assessment has been provided in good faith by AECOM consultants on the
basis of housing data, national guidance and other relevant and available
information current at the time of writing.
7.3 Bearing this in mind, it is recommended that the East Bergholt Neighbourhood
Plan Group should monitor carefully strategies and documents with an impact on
housing policy produced by the Government, Babergh or any other relevant party
and review the Neighbourhood Plan accordingly to ensure that general
conformity is maintained.
7.4 At the same time, monitoring on-going demographic or other trends over the
Neighbourhood Plan period will help ensure the continued relevance and
credibility of its policies.
East Bergholt Neighbourhood Plan Housing Needs Assessment
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Appendix A : Assessment geography
A.1 For Census purposes, the whole of England is divided into statistical units of
similar population size called Output Areas (OAs) and their larger equivalents.
OAs are the smallest units. They make up Lower Layer Super Output Areas
(LSOAs), which in turn make up Middle Layer Super Output Areas (MSOAs).
The NA equates to the following combination of OAs:
• E00152274
• E00152275
• E00152276
• E00152277
• E00152278
• E00152279
• E00152280
• E00152281
A.2 As noted in the analysis of affordability in the main body of the report,
household income data for small areas is only provided down to the scale of
MSOAs. The relevant MSOA, in which the NA is located and which will need
to serve as a proxy for it, is:
• E02006236 (East Bergholt sits close to the middle of this MSOA area, with
the boundary extending in each direction north, east, south and west.)
East Bergholt Neighbourhood Plan Housing Needs Assessment
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Appendix B : Local Plan context
Policies in the adopted local plan
B.1 Table B-1 below summarises adopted Local Plan policies that are relevant to
housing need and delivery in East Bergholt.
Table B-1: Summary of relevant adopted policies in the Babergh and Mid Suffolk
Joint Local Plan (2018 – 2037) – Part 1 (November 2023)
Policy Provisions
SPO1 – Housing
Needs
Babergh will seek to deliver a minimum of 7,904 net additional dwellings over
the Plan period – or 416 dwellings per annum.
The Affordable Housing Mix over the plan period is as follows:
– Shared Ownership (25%)
– Discount home ownership (19%)
– Social/Affordable rent (56%)
SP02 – Affordable
Housing
On site of 10 or more dwellings, a contribution of 35% affordable housing will
be required on greenfield sites. For brownfield sites a contribution of 25%
affordable housing will be required.
LP24 – Design and
Residential Amenity
I). At least 50% of dwellings will meet the requirements for accessible and
adaptable dwellings under Part M4 (2) of Building Regulations.
Source: Babergh and Mid Suffolk Joint Local Plan – Part 1 (November, 2023)
East Bergholt Neighbourhood Plan Housing Needs Assessment
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Appendix C : Affordability calculations
C.1 This section outlines how the affordability thresholds discussed in the
Affordability and Affordable Housing have been calculated.
Market housing
C.2 Market housing is not subsidised and tends to be primarily accessible to
people on higher incomes.
i) Market sales
C.3 The starting point for calculating the affordability of a dwelling for sale from the
perspective of a specific household is the loan to income ratio which most
mortgage companies are prepared to agree. This ratio is conservatively
estimated to be 3.5. In practice this can be highly variable. Multipliers up to
4.5 or even above 5 times income increasingly available, although the actual
average in practice tends to be lower, particularly where applicants are dual
earning. The Financial Conduct Authority uses 3.5 or more as its standard
assumption for single applicants and 2.75 or more for dual applicants.
C.4 To produce a more accurate assessment of affordability, the savings required
for a deposit should be taken into account in addition to the costs of servicing
a mortgage. However, unlike for incomes, data is not available for the savings
available to households in East Bergholt, and the precise deposit a mortgage
provider will require of any buyer will be determined by their individual
circumstances and the state of the mortgage market. An assumption is
therefore made that a 10% purchase deposit is required and is available to
the prospective buyer. In reality it is possible that the cost of the deposit is a
greater barrier to home ownership than the mortgage costs.
C.5 The calculation for the purchase threshold for market housing is as follows:
• Value of a median NA house price (2022) = £470,000;
• Purchase deposit at 10% of value = £47,000;
• Value of dwelling for mortgage purposes = £423,000;
• Divided by loan to income ratio of 3.5 = purchase threshold of £121,000.
East Bergholt Neighbourhood Plan Housing Needs Assessment
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C.6 The purchase threshold for an entry-level dwelling is a better representation
of affordability to those with lower incomes or savings, such as first-time
buyers. To determine this threshold, the same calculation is repeated but with
reference to the lower quartile rather than the median house price. The lower
quartile average in 2022 was £378,000, and the purchase threshold is
therefore £97,200.
C.7 It is also worth assessing the purchase threshold for new build homes, since
this most closely represents the cost of the new housing that will come forward
in future. Land Registry records no sales of new build properties in the NA in
2022. There were too few recent sales in the NA specifically to determine an
accurate average for the cost of new build housing in East Bergholt. It is,
however, important to understand the likely cost of new housing because new
housing is where the Neighbourhood Plan has most influence, and is the
appropriate benchmark for understanding the costs of affordable home
ownership tenures (considered below).
C.8 Therefore, an estimate has been calculated by determining the uplift between
all house prices in 2022 across Babergh and new build house prices in 2022
in the same area. This percentage uplift (or ‘new build premium’) is then
applied to the 2022 lower quartile house price in the NA to give an estimated
NA new build entry-level house price of £386,000 and purchase threshold of
£99,000.
C.9 In order to provide a comparison with the wider local authority area, it is helpful
to also look at the cost of new build housing across Babergh in 2022. The
median cost of new build dwellings in Babergh was £340,000, with a purchase
threshold of £87,500.
i) Private Rented Sector (PRS)
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C.10 It is assumed here that rented housing is affordable if the annual rent does not
exceed 30% of the household’s gross annual income. The percentage of
income to be spent on rent before the property is considered affordable varies
considerably for individuals, and it is increasingly common for households to
dedicate a larger proportion of their earnings to rent. When considering
affordability it is considered good practice to be conservative, and the 30%
benchmark is used as ONS’s current standard assumption.
C.11 This is an important assumption because it is possible that a household will
be able to afford tenures that are deemed not affordable in this report if they
are willing or able to dedicate a higher proportion of their income to housing
costs. It is becoming increasingly necessary for households to do so.
However, for the purpose of planning it is considered more appropriate to use
this conservative lower benchmark for affordability on the understanding that
additional households may be willing or able to access housing this way than
to use a higher benchmark which assumes that all households can afford to
do so when their individual circumstances may well prevent it.
C.12 The property website rightmove.co.uk rental values for property in the
Neighbourhood Area. The best available data is derived from properties
available for rent within the CO7 postcode area, which covers a larger area
than the Plan area itself but can be used as a reasonable proxy for it.
Moreover, because it forms a larger geography with a greater number of rental
properties offered, the larger sample size is likely to generate more robust
findings.
C.13 According to rightmove.co.uk, there were 37 properties for rent at the time of
search in January, 2024, with an average monthly rent of £1,600. There were
15 one/two-bed properties listed, with an average price of £1,020 per calendar
month.
C.14 The calculation for the private rent income threshold for entry-level (2
bedroom) dwellings is as follows:
• Annual rent = £1,020 x 12 = £12,240;
• Multiplied by 3.33 (so that no more than 30% of income is spent on rent) =
income threshold of £40,800.
C.15 The calculation is repeated for the overall average to give an income threshold
of £64,000.
Affordable Housing
C.16 There are a range of tenures that constitute the definition of Affordable
Housing within the NPPF 2023: social rent and affordable rent, discounted
market sales housing, and other affordable routes to home ownership. The
new First Homes was been introduced in 2021 but is not yet included in the
NPPF. Each of the affordable housing tenures are considered below.
i) Social rent
East Bergholt Neighbourhood Plan Housing Needs Assessment
59
C.17 Rents in socially rented properties reflect a formula based on property values
and average earnings in each area, resulting in substantial discounts to
market rents. As such, this tenure is suitable for the needs of those on the
lowest incomes and is subject to strict eligibility criteria.
C.18 To determine social rent levels, data and statistical return from Homes
England is used. This data is only available at Local Authority scale so must
act as a proxy for East Bergholt. This data provides information about rents
and the size and type of stock owned and managed by private registered
providers and is presented for Babergh in Table C-1.
C.19 To determine the income needed, it is assumed that no more than 30% of
income should be spent on rent. This is an assumption only for what might
generally make housing affordable or unaffordable – it is unrelated to the
eligibility criteria of Affordable Housing policy at Local Authority level. The
overall average across all property sizes is taken forward as the income
threshold for social rent.
Table C-1: Social rent levels (£)
Size 1 bed 2 beds 3 beds 4 beds All
Average social rent
per week
£77.00 £89.00 £98.00 £109.00 £92.00
Annual average £4,004 £4,628 £5,096 £5,668 £4,784
Income needed £13,333 £15,411 £16,970 £18,874 £15,931
Source: Homes England, AECOM Calculations
East Bergholt Neighbourhood Plan Housing Needs Assessment
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i) Affordable rent
C.20 Affordable rent is controlled at no more than 80% of the local market rent.
However, registered providers who own and manage affordable rented
housing may also apply a cap to the rent to ensure that it is affordable to those
on housing benefit (where under Universal Credit the total received in all
benefits to working age households is £20,000).
C.21 Even a 20% discount on the market rent may not be sufficient to ensure that
households can afford this tenure, particularly when they are dependent on
benefits. Registered Providers in some areas have applied caps to larger
properties where the higher rents would make them unaffordable to families
under Universal Credit.
C.22 Data on the most realistic local affordable rent costs is obtained from the same
source as social rent levels for Babergh. Again it is assumed that no more
than 30% of income should be spent on rent, and the overall average is taken
forward.
C.23 Comparing this result with the average 2 bedroom annual private rent above
indicates that affordable rents in the NA are actually closer to 50% of market
rates than the maximum of 80%, a feature that is necessary to make them
achievable to those in need.
Table C-2: Affordable rent levels (£)
Size 1 bed 2 beds 3 beds 4 beds All
Average affordable
rent per week
£84.00 £101.00 £121.00 £144.00 £105.00
Annual average £4,368 £5,252 £6,292 £7,488 £5,460
Income needed £14,545 £17,489 £20,952 £24,935 £18,182
Source: Homes England, AECOM Calculations
i) Affordable home ownership
C.24 Affordable home ownership tenures include products for sale and rent
provided at a cost above social rent, but below market levels. The three most
widely available are discounted market housing (a subset of which is the new
First Homes product), shared ownership, and Rent to Buy. These are
considered in turn below.
C.25 In paragraph 66 of the NPPF 2023, the Government introduces a
recommendation that “where major development involving the provision of
housing is proposed, planning policies and decisions should expect at least
10% of the total number of homes to be available for affordable home
ownership.” There are exemptions to this requirement, including where:
• The provision would exceed the level of affordable housing required in an
area;
• The provision would significantly prejudice the ability to meet the identified
affordable housing needs of specific groups;
East Bergholt Neighbourhood Plan Housing Needs Assessment
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• A proposed development provides solely Build to Rent homes;
• A proposed development provides specialist accommodation for a group
of people with specific needs (such as purpose built accommodation for
students or the elderly);
• The development is proposed to be developed by people who wish to
build or commission their own homes; or
• The proposed development is exclusively for affordable housing, a
community-led development exception site, or a rural exception site.
First Homes
C.26 Because First Homes are a new tenure product, it is worth explaining some of
their key features:
• First Homes should be available to buy with a minimum discount of 30%
below their full market value (i.e. the value of an equivalent new home);
• The discount level can be set higher than 30% – at 40% or 50% – where
this can be suitably evidenced. The setting and justifying of discount levels
can happen at neighbourhood as well as local authority scale;
• After the discount is applied the initial sale price must not exceed £250,000
(or £420,000 in Greater London), and lower caps can be set locally;
• Purchasers must be first-time buyers with an income less than £80,000 (or
£90,000 in Greater London), and First Homes can be prioritised for local
people and/or key workers;
• They will be subject to legal restrictions ensuring the discount is retained
for future occupants, and renting out or sub-letting will not normally be
permitted;
• In addition to setting the discount level, local authorities and neighbourhood
planning groups can apply additional criteria, such as a lower income cap,
local connection test or prioritisation for key workers through adopted plans,
emerging policy or Supplementary Planning Documents.
• 25% of all homes delivered through section 106 developer contributions on
sites enabled through the planning process should be sold as First Homes.
In simpler terms, 25% of all subsidised Affordable Housing on mainstream
housing developments should be First Homes. This is likely to mean that
First Homes will take the place of shared ownership housing in many
circumstances, and in some cases may also displace social or affordable
rented homes.
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C.27 The starting point for considering whether First Homes are affordable is the
estimated cost of new build entry-level housing in the NA noted above of
£386,000.
C.28 For the minimum discount of 30% the purchase threshold can be calculated
as follows:
• Value of a new home (estimated NA new build entry-level) = £386,000;
• Discounted by 30% = £270,160;
• Purchase deposit at 10% of value = £27,000;
• Value of dwelling for mortgage purposes = £243,150;
• Divided by loan to income ratio of 3.5 = purchase threshold of £69,500.
C.29 The income thresholds analysis in the Affordability and Affordable Housing
chapter also compares local incomes with the costs of a 40% and 50%
discounted First Home. This would require an income threshold of £59,500
and £49,600 respectively.
C.30 All of the income thresholds calculated here for First Homes are below the cap
of £80,000 above which households are not eligible. All thresholds are below
the cap of eligibility.
C.31 Note that discounted market sale homes may be unviable to develop if the
discounted price is close to (or below) build costs. Build costs vary across the
country but as an illustration, the build cost for a 2 bedroom home (assuming
70 sq. m and a build cost of £1,750 per sq. m
12
) would be around £122,500.
This cost excludes any land value or developer profit. This would not appear
to be an issue in East Bergholt.
C.32 Table C-3 shows the discount required for First Homes to be affordable to the
three income groups. The cost of a typical First Home is calculated using an
estimate for new build entry-level housing in the NA. However, it is worth
thinking about First Homes in relation to the cost of new build prices in the
wider area, as well as median and entry-level existing prices locally to get a
more complete picture. The discount levels required for these alternative
benchmarks are given below.
Table C-3: Discount on sale price required for households to afford First Homes
House price
benchmark
Mean
household
income
Single LQ
earner
Dual LQ
earning
household
NA median house price 60% 84% 67%
NA estimated new build entry-level
house price
51% 80% 60%
NA entry-level house price 50% 80% 59%
LA median new build house price 44% 77% 55%
12
It is estimated that in 2022, build costs for a house are between £1,750 and £3,000 per square metre –
https://urbanistarchitecture.co.uk/cost-to-build-a-house-uk/
East Bergholt Neighbourhood Plan Housing Needs Assessment
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Source: Land Registry PPD; ONS MSOA total household income
Shared ownership
C.33 Shared ownership involves the purchaser buying an initial share in a property,
typically of between 25% and 75% (but now set at a minimum of 10%), and
paying rent on the share retained by the provider. Shared ownership is flexible
in two respects, in the share which can be purchased and in the rent payable
on the share retained by the provider. Both of these are variable. The share
owned by the occupant can be increased over time through a process known
as ‘staircasing’.
C.34 In exceptional circumstances (for example, as a result of financial difficulties,
and where the alternative is repossession), and at the discretion of the
provider, shared owners may staircase down, thereby reducing the share they
own. Shared equity is available to first-time buyers, people who have owned
a home previously and council and housing association tenants with a good
credit rating whose annual household income does not exceed £80,000.
C.35 To determine the affordability of shared ownership, calculations are again
based on the estimated costs of new build housing as discussed above. The
deposit available to the prospective purchaser is assumed to be 10% of the
value of the dwelling, and the standard loan to income ratio of 3.5 is used to
calculate the income required to obtain a mortgage. The rental component is
estimated at 2.5% of the value of the remaining (unsold) portion of the price.
The income required to cover the rental component of the dwelling is based
on the assumption that a household spends no more than 30% of the income
on rent (as for the income threshold for the private rental sector).
C.36 The affordability threshold for a 25% equity share is calculated as follows:
• A 25% equity share of £386,000 is £96,500;
• A 10% deposit of £9,650 is deducted, leaving a mortgage value of £86,840;
• This is divided by the loan to value ratio of 3.5 to give a purchase threshold
of £24,800;
• Rent is charged on the remaining 75% shared ownership equity, i.e. the
unsold value of £289,500;
• The estimated annual rent at 2.5% of the unsold value is £7,240;
• This requires an income of £24,120 (annual rent multiplied by 3.33 so that
no more than 30% of income is spent on rent).
• The total income required is £48,920 (£24,800 plus £24,120).
C.37 The same calculation is repeated for equity shares of 10% and 50% producing
affordability thresholds of £38,900 and £65,700 respectively.
C.38 All thresholds are below the £80,000 cap of eligibility.
East Bergholt Neighbourhood Plan Housing Needs Assessment
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Rent to Buy
C.39 Rent to Buy is a relatively new and less common tenure, which through
subsidy allows the occupant to save a portion of their rent, which is intended
to be used to build up a deposit to eventually purchase the home. It is therefore
estimated to cost the same as private rents – the difference being that the
occupant builds up savings with a portion of the rent.
Help to Buy (Equity Loan)
C.40 The Help to Buy Equity Loan is not an affordable housing tenure but allows
households to afford market housing through a loan provided by the
government. With a Help to Buy Equity Loan the government lends up to 20%
(40% in London) of the cost of a newly built home. The household must pay a
deposit of 5% or more and arrange a mortgage of 25% or more to make up
the rest. Buyers are not charged interest on the 20% loan for the first five
years of owning the home.
C.41 It is important to note that this product widens access to market housing but
does not provide an affordable home in perpetuity.
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Appendix D : Affordable Housing need
and policy
Affordable Housing estimates
D.1 In Table D-1 AECOM has calculated, using PPG as a starting point,
13
an
estimate of the total need for affordable rented housing in East Bergholt over
the Plan period. It should, however, be noted that the accuracy of the findings
generated by the model is only as strong as the evidence available. However,
given the test of proportionality for evidence supporting neighbourhood plans,
and the need to be in conformity with Local Authority strategic polices, the
calculations set out here are considered a reasonable basis for understanding
and planning for neighbourhood-level affordable housing need.
D.2 It should also be noted that figures in Table D-1 are largely dependent on
information provided by Babergh in its capacity as manager of the local
housing waiting list.
13
Paragraphs 024-026 Reference ID: 2a-026-20140306, at https://www.gov.uk/guidance/housing-and-economic-land-
availability-assessment
East Bergholt Neighbourhood Plan Housing Needs Assessment
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Table D-1: Estimate of need for Affordable Housing for rent in East Bergholt
Stage and Step in Calculation Total Description
STAGE 1: CURRENT NEED
1.1 Current households in need 21.0 Neighbourhood Waiting list data
provided by Babergh and Mid Suffolk
1.2 Per annum 1.2 Step 1.1 divided by the plan period to
produce an annualised figure.
STAGE 2: NEWLY ARISING NEED
2.1 New household formation
149.8
DLUHC 2018-based household
projections for the LA between start
and end of plan period. % increase
applied to NA.
2.2 Proportion of new households unable
to rent in the market
13.0%
(Steps 1.1 + 2.2.1 + 2.2.2) divided by
number of households in NA.
2.2.1 Current number of social renters in
NA
109.0
2021 Census social rented occupancy
2.2.2 Number of private renters on
housing benefits
34.1
Housing benefit caseload May 2018.
Pro rata for NA.
2.3 New households unable to rent 19.5 Step 2.1 x Step 2.2.
2.4 Per annum 1.1 Step 2.3 divided by plan period.
STAGE 3: TURNOVER OF AFFORDABLE HOUSING
3.1 Supply of social/affordable re-lets
(including transfers) %
3.0%
Assumed proportion of stock re-let
each year.
3.2 Supply of social/affordable re-lets
(including transfers)
3.3
Step 3.1 x NA social rented stock
(2.2.1).
NET SURPLUS OF RENTED UNITS PER ANNUM
Overall surplus per annum 0.9 Step 1.2 + Step 2.4 – Step 3.2
Source: AECOM model, using Census 2011, English Housing Survey 2018, DLUHC 2018 based household projections and net
additions to affordable housing stock. 2018 is the latest reliable data for some datasets so is used throughout for consistency.
Figures may not sum due to rounding.
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D.3 Turning to Affordable Housing providing a route to home ownership, Table D-
2 estimates the potential demand in East Bergholt. This model aims to
estimate the number of households that might wish to own their own home but
cannot afford to. The model is consistent with methods used at Local Authority
scale in taking as its starting point households currently living in or expected
to enter the private rented sector who are not on housing benefit.
D.4 There may be other barriers to these households accessing home ownership
on the open market, including being unable to save for a deposit, or being
unable to afford a home of the right type/size or in the right location. The model
also discounts 25% of households potentially in need, assuming a proportion
will be renting out of choice. This assumption is based on consistent results
for surveys and polls at the national level which demonstrate that most
households (typically 80% or more) aspire to home ownership.
14
No robust
indicator exists for this area or a wider scale to suggest aspirations may be
higher or lower in the NA.
14
http://www.ipsos-mori-generations.com/housing.html
East Bergholt Neighbourhood Plan Housing Needs Assessment
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Table D-2: Estimate of the potential demand for affordable housing for sale in
East Bergholt
Stage and Step in Calculation Total Description
STAGE 1: CURRENT NEED
1.1 Current number of renters in NA
124.0
Census 2021 private rented
occupancy.
1.2 Percentage renters on housing benefit
in LA 27.5%
% of renters in 2021 on Housing
Benefit / Universal Credit with housing
entitlement
1.3 Number of renters on housing benefits
in the NA
34.1
Step 1.1 x Step 1.2.
1.4 Current need (households)
67.4
Current renters minus those on
housing benefit and minus 25%
assumed to rent by choice.
15
1.5 Per annum 4.0 Step 1.4 divided by plan period.
STAGE 2: NEWLY ARISING NEED
2.1 New household formation
149.8
LA household projections for plan
period (2018 based) pro rated to NA.
2.2 % of households unable to buy but
able to rent
5.6%
(Step 1.4 + Step 3.1) divided by
number of households in NA.
2.3 Total newly arising need 8.3 Step 2.1 x Step 2.2.
2.4 Total newly arising need per annum 0.6 Step 2.3 divided by plan period.
STAGE 3: SUPPLY OF AFFORDABLE HOUSING
3.1 Supply of affordable housing
3.0
Number of shared ownership homes in
the NA (Census 2021).
3.2 Supply – intermediate resales
0.2
Step 3.1 x 5% (assumed rate of re-
sale).
NET SHORTFALL PER ANNUM
Overall shortfall per annum 4.5 (Step 1.5 + Step 2.4) – Step 3.2.
Source: AECOM model, using Census 2011, English Housing Survey 2018, DLUHC 2018 based household projections and net
additions to affordable housing stock. 2018 is the latest reliable data for some datasets so is used throughout for consistency.
15
The assumption of approximately 25% preferring to rent and 75% preferring to buy is AECOM’s judgement, based on
national level polls which consistently reveal that most households who prefer home ownership eg http://www.ipsos-mori-
generations.com/housing.html and informed by our experience across numerous neighbourhood level HNAs. The assumption
is based on the fact that some households choose to rent at certain stages in their life (e.g. when young, when needing
flexibility in employment market, or when new migrants move into an area). While most households prefer the added security
and independence of owning their own home, private renting is nevertheless a tenure of choice at a certain points in many
households’ journey through the housing market. The actual percentage of preference will differ between areas, being higher in
large metropolitan areas with younger households and more new migrants, but lower in other areas. 25% is used as a
reasonable proxy and for consistency across HNAs and similar assumptions are used in some larger scale assessments such
as LHNAs and SHMAs. If the neighbourhood planning group feel this is not an appropriate assumption in their particular locality
they could use the results of a local residents survey to refine or confirm this calculation.
East Bergholt Neighbourhood Plan Housing Needs Assessment
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D.5 There is no policy or legal obligation on the part either of the Local Authority
or Neighbourhood Plan to meet affordable housing needs in full, though there
are tools available to the Steering Group that can help ensure that it is met to
a greater extent if resources permit (e.g. the ability to allocate sites for
affordable housing).
D.6 It is also important to remember that even after the Neighbourhood Plan is
adopted, the assessment of need for Affordable Housing, the allocation of
affordable rented housing to those in need, and the management of the
housing waiting list all remain the responsibility of the Local Authority rather
than the neighbourhood planning group.
Affordable housing policy
D.7 The following table reviews the relevant factors in developing a policy on the
Affordable Housing tenure mix, which inform the recommendation given in the
main body of the report.
Table D-3: Wider considerations in developing Affordable Housing mix
policy
Consideration Local Evidence
A. Evidence of need for Affordable
Housing:
The need for affordable rent and affordable
home ownership is not directly equivalent:
the former expresses the identified need of
a group with acute needs and no alternative
options; the latter expresses potential
demand from a group who are generally
adequately housed in rented
accommodation and may not be able to
afford the deposit to transition to ownership.
This HNA suggests there is a surplus of 1
affordable rented home per annum. There
is, however, a potential need for 5 units of
affordable home ownership dwellings per
annum over the Plan period. Both forms of
Affordable Housing appear to be valuable in
meeting the needs of people on various
incomes.
The relationship between these figures
suggests that affordable home ownership
should be prioritized over affordable rent to
meet the needs of households in the NA. But
district wide pressures and the local waiting
list backlog are likely to demand provision of
affordable rented housing to meet acute
needs.
B. Can Affordable Housing needs be met
in full?
How far the more urgently needed
affordable rented housing should be
prioritised in the tenure mix depends on the
quantity of overall housing delivery
expected.
The Local Plan sets an Affordable Housing
target at 35% of new housing development
in the District. East Bergholt’s housing target
is not yet known, with this being expected in
Part 2 of the Babergh and Mid Suffolk Local
Plan. As such, it is not known whether the
NA can fully meet the Affordable Housing
East Bergholt Neighbourhood Plan Housing Needs Assessment
70
Need identified in this HNA through
expected development.
C. Government policy (eg NPPF)
requirements:
Current NPPF policy requires 10% of all
homes to be delivered for affordable home
ownership. There can be exceptions to this
requirement if it would prevent the delivery
of other forms of Affordable Housing.
For 10% of all housing to be affordable
ownership in East Bergholt, where 35% of
all housing should be affordable, 29% of
Affordable Housing should be for affordable
ownership. This complies with the guideline
tenure split sought in the Local Plan.
D. Local Plan policy:
The adopted Local Plan seeks a tenure split
of 56% affordable rent and 44% affordable
home ownership.
E. First Homes policy:
The Government recently concluded a
consultation on the introduction of First
Homes (to provide at least 30% discount on
new build home prices). The proposals have
now been enacted through a ministerial
statement. A minimum of 25% of all
Affordable Housing secured through
developer contributions are now required to
be First Homes.
After the 25% First Homes requirement has
been met, the remaining 75% of Affordable
Housing units should as a first priority
protect the provision for social rent set out in
the Local Plan. The remaining units should
then be allocated to other tenure products in
the relative proportions set out in the Local
Plan.
AECOM is aware that some Local Planning
Authorities are considering ‘top slicing’ their
affordable housing quota to provide 25%
First Homes and then allocating the
remaining proportion according to their
existing policy tenure split. Some LPAs are
considering this approach because of the
existing business models of registered
providers which have relied on shared
ownership to cross subsidise affordable
rented housing and uncertainty over
This new minimum requirement may have
the effect of displacing other products in any
established tenure mix, and will reduce the
amount of social or affordable rent if this was
proposed to be more than 75% of Affordable
Housing. Given that the alteration to the
Babergh and Mid Suffolk Local Plan
requires 35% of all homes to be provided as
affordable home ownership options, the
provision of First Homes would not have a
displacement effect on other affordable
housing products.
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whether First Homes could replace this
model.
F. Viability:
HNAs cannot take into consideration the
factors which affect viability in the
neighbourhood area or at the site-specific
level. Viability issues are recognised in the
Local Plan and it is acknowledged that this
may affect the provision of affordable
housing, the mix of tenures provided and the
discounts that can be sought on First Homes
properties.
G. Funding:
The availability of funding to support the
delivery of different forms of Affordable
Housing may also influence what it is
appropriate to provide at a particular point in
time or on any one site.
The East Bergholt Neighbourhood Plan
Group may wish to keep this in mind so that
it can take up any opportunities to secure
funding if they become available.
H. Existing tenure mix in East Bergholt:
The current stock of homes in an area, in
terms of balance between ownership, rented
and affordable provision may be a
consideration in the mix of tenures provided
on new development sites.
Socially rented housing currently makes up
approximately one tenth of the overall
tenure profile in the NA, and shared
ownership homes make up less than 1%.
Both proportional shares are smaller than
the district average.
As such there is an opportunity to improve
the supply of Affordable Housing to bring the
tenure profile more in line with the district
average.
I. Views of registered providers:
It is not within the scope of this HNA to
investigate whether it would be viable for
housing associations (registered providers)
to deliver and manage affordable rented
homes in the NA. The funding arrangements
available to housing associations will
determine rent levels.
J. Wider policy objectives: The East Bergholt Neighbourhood Plan
Group may wish to take account of broader
policy objectives for East Bergholt and/or
the wider district. These could include, but
are not restricted to, policies to attract
younger households, families or working
East Bergholt Neighbourhood Plan Housing Needs Assessment
72
age people to the NA. These wider
considerations may influence the mix of
Affordable Housing provided.
East Bergholt Neighbourhood Plan Housing Needs Assessment
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Appendix E : Specialist housing for
older people
Background data tables
Table E-1: Tenure and mobility limitations of those aged 65+ in East Bergholt,
2011 (65+ is the closest proxy for 75+ in this data)
Tenure
Day-to-day
activities
limited a lot
Day-to-day
activities
limited a little
Day-to-day
activities not
limited
All categories 86 14.9% 146 25.3% 346 59.9%
Owned Total 77 14.4% 135 25.3% 322 60.3%
Owned outright 9 20.5% 11 25.0% 24 54.5%
Owned (mortgage) or
shared ownership
21 21.2% 33 33.3% 45 45.5%
Rented Total 16 28.1% 17 29.8% 24 42.1%
Social rented 5 11.9% 16 38.1% 21 50.0%
Private rented or living
rent free
86 14.9% 146 25.3% 346 59.9%
Source: DC3408EW Health status
HLIN calculations
Table E-2: Recommended provision of specialist housing for older people from
the HLIN SHOP toolkit
Source: Housing LIN SHOP Toolkit
East Bergholt Neighbourhood Plan Housing Needs Assessment
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E.1 As Table 6-4 in the main report shows, East Bergholt is forecast to see an
increase of 238 individuals aged 75+ by the end of the Plan period. According
to the HLIN tool, this translates into need as follows:
• Conventional sheltered housing to rent = 60 x .238 = 14
• Leasehold sheltered housing = 120 x .238 = 29
• Enhanced sheltered housing (divided 50:50 between that for rent and that
for sale) = 20 x .238 = 5
• Extra care housing for rent = 15 x .238 = 4
• Extra care housing for sale = 30 x .238 = 7
• Housing based provision for dementia = 6 x .238 = 1
East Bergholt Neighbourhood Plan Housing Needs Assessment
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Appendix F : Housing Needs
Assessment Glossary
Adoption
This refers to the final confirmation of a local plan by a local planning authority.
Affordability
The terms ‘affordability’ and ‘affordable housing’ have different meanings. ‘Affordability’
is a measure of whether housing may be afforded by certain groups of households.
‘Affordable housing’ refers to particular products outside the main housing market.
Affordability Ratio
Assessing affordability involves comparing housing costs against the ability to pay.
The ratio between lower quartile house prices and the lower quartile income or
earnings can be used to assess the relative affordability of housing. The Ministry for
Housing, Community and Local Governments publishes quarterly the ratio of lower
quartile house price to lower quartile earnings by local authority (LQAR) as well as
median house price to median earnings by local authority (MAR) e.g. income =
£25,000, house price = £200,000. House price: income ratio = £200,000/£25,000 =
8, (the house price is 8 times income).
Affordable Housing (NPPF Definition)
Housing for sale or rent, for those whose needs are not met by the market (including
housing that provides a subsidised route to home ownership and/or is for essential
local workers); and which complies with one or more of the following definitions:
a) Affordable housing for rent: meets all of the following conditions: (a) the rent is set
in accordance with the Government’s rent policy for Social Rent or Affordable Rent, or
is at least 20% below local market rents (including service charges where applicable);
(b) the landlord is a registered provider, except where it is included as part of a Build
to Rent scheme (in which case the landlord need not be a registered provider); and
(c) it includes provisions to remain at an affordable price for future eligible households,
or for the subsidy to be recycled for alternative affordable housing provision. For Build
to Rent schemes affordable housing for rent is expected to be the normal form of
affordable housing provision (and, in this context, is known as Affordable Private Rent).
b) Discounted market sales housing: is that sold at a discount of at least 20% below
local market value. Eligibility is determined with regard to local incomes and local
house prices. Provisions should be in place to ensure housing remains at a discount
for future eligible households.
c) Other affordable routes to home ownership: is housing provided for sale that
provides a route to ownership for those who could not achieve home ownership
through the market. It includes shared ownership, relevant equity loans, other low-cost
homes for sale (at a price equivalent to at least 20% below local market value) and
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76
Rent to Buy (which includes a period of intermediate rent). Where public grant funding
is provided, there should be provisions for the homes to remain at an affordable price
for future eligible households, or for any receipts to be recycled for alternative
affordable housing provision, or refunded to Government or the relevant authority
specified in the funding agreement.
Affordable rented housing
Rented housing let by registered providers of social housing to households who are
eligible for social rented housing. Affordable Rent is not subject to the national rent
regime but is subject to other rent controls that require a rent of no more than 80% of
the local market rent (including service charges, where applicable). The national rent
regime is the regime under which the social rents of tenants of social housing are set,
with particular reference to the Guide to Social Rent Reforms (March 2001) and the
Rent Influencing Regime Guidance (October 2001). Local market rents are calculated
using the Royal Institution for Chartered Surveyors (RICS) approved valuation
methods
16
.
Age-Restricted General Market Housing
A type of housing which is generally for people aged 55 and over and active older
people. It may include some shared amenities such as communal gardens but does
not include support or care services.
Annual Monitoring Report
A report submitted to the Government by local planning authorities assessing progress
with and the effectiveness of a Local Development Framework.
Basic Conditions
The Basic Conditions are the legal tests that are considered at the examination stage
of neighbourhood development plans. They need to be met before a plan can progress
to referendum.
Backlog need
The backlog need constitutes those households who are eligible for Affordable
Housing, on account of homelessness, over-crowding, concealment or affordability,
but who are yet to be offered a home suited to their needs.
Bedroom Standard
17
The bedroom standard is a measure of occupancy (whether a property is overcrowded
or under‐occupied, based on the number of bedrooms in a property and the type of
household in residence). The Census overcrowding data is based on occupancy rating
(overcrowding by number of rooms not including bathrooms and hallways). This tends
to produce higher levels of overcrowding/ under occupation. A detailed definition of the
standard is given in the Glossary of the EHS Household Report.
16
The Tenant Services Authority has issued an explanatory note on these methods at
http://www.communities.gov.uk/documents/planningandbuilding/pdf/1918430.pdf
17
See https://www.gov.uk/government/statistics/english-housing-survey-2011-to-2012-household-report
East Bergholt Neighbourhood Plan Housing Needs Assessment
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Co-living
Co-living denotes people who do not have family ties sharing either a self-contained
dwelling (i.e., a ‘house share’) or new development akin to student housing in which
people have a bedroom and bathroom to themselves, but share living and kitchen
space with others. In co-living schemes each individual represents a separate
‘household’.
Community-led developments (NPPF definition)
A development instigated and taken forward by a not-for-profit organisation set up and
run primarily for the purpose of meeting the housing needs of its members and the
wider local community, rather than being a primarily commercial enterprise. The
organisation is created, managed, and democratically controlled by its members. It
may take any one of the various legal forms including a community land trust, housing
co-operative, and community benefit society. Membership of the organisation is open
to all beneficiaries and prospective beneficiaries of that organisation. The organisation
should own, manage, or steward the homes in a manner consistent with its purpose,
for example through a mutually supported arrangement with a Registered Provider of
Social Housing. The benefits of the development to the specified community should
be clearly defined and consideration given to how these benefits can be protected over
time, including in the event of the organisation being wound up.
Community Right to Build Order
18
A community right to build order is a special kind of neighbourhood development order,
granting planning permission for small community development schemes, such as
housing or new community facilities. Local community organisations that meet certain
requirements or parish/town councils are able to prepare community right to build
orders.
Concealed Families (Census definition)
19
The 2011 Census defined a concealed family as one with young adults living with a
partner and/or child/children in the same household as their parents, older couples
living with an adult child and their family or unrelated families sharing a household. A
single person cannot be a concealed family; therefore one older parent living with their
adult child and family or an adult child returning to the parental home is not a concealed
family; the latter are reported in an ONS analysis on increasing numbers of young
adults living with parents.
Equity Loans/Shared Equity
An equity loan which acts as a second charge on a property. For example, a household
buys a £200,000 property with a 10% equity loan (£20,000). They pay a small amount
for the loan and when the property is sold e.g. for £250,000 the lender receives 10%
of the sale cost (£25,000). Some equity loans were available for the purchase of
existing stock. The current scheme is to assist people to buy new build.
18
See https://www.gov.uk/guidance/national-planning-policy-framework/annex-2-glossary
19
See http://webarchive.nationalarchives.gov.uk/20160107160832/http://www.ons.gov.uk/ons/dcp171776_350282.pdf
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Extra Care Housing or Housing-With-Care
Housing which usually consists of purpose-built or adapted flats or bungalows with a
medium to high level of care available if required, through an onsite care agency
registered through the Care Quality Commission (CQC). Residents are able to live
independently with 24 hour access to support services and staff, and meals are also
available. There are often extensive communal areas, such as space to socialise or a
wellbeing centre. In some cases, these developments are included in retirement
communities or villages – the intention is for residents to benefit from varying levels of
care as time progresses.
Fair Share
‘Fair share’ is an approach to determining housing need within a given geographical
area based on a proportional split according to the size of the area, the number of
homes in it, or its population.
First Homes
First Homes is another form of discounted market housing which will provide a
discount of at least 30% on the price of new homes, introduced in 2021. These homes
are available to first time buyers as a priority but other households will be eligible
depending on agreed criteria. New developments will be required to provide 25% of
Affordable Housing as First Homes. A more detailed explanation of First Homes and
its implications is provided in the main body of the HNA.
Habitable Rooms
The number of habitable rooms in a home is the total number of rooms, excluding
bathrooms, toilets and halls.
Household Reference Person (HRP)
The concept of a Household Reference Person (HRP) was introduced in the 2001
Census (in common with other government surveys in 2001/2) to replace the
traditional concept of the head of the household. HRPs provide an individual person
within a household to act as a reference point for producing further derived statistics
and for characterising a whole household according to characteristics of the chosen
reference person.
Housing Market Area
A housing market area is a geographical area defined by household demand and
preferences for all types of housing, reflecting the key functional linkages between
places where people live and work. It might be the case that housing market areas
overlap.
The extent of the housing market areas identified will vary, and many will in practice
cut across various local planning authority administrative boundaries. Local planning
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authorities should work with all the other constituent authorities under the duty to
cooperate.
Housing Needs
There is no official definition of housing need in either the National Planning Policy
Framework or the National Planning Practice Guidance. Clearly, individuals have their
own housing needs. The process of understanding housing needs at a population
scale is undertaken via the preparation of a Strategic Housing Market Assessment
(see below).
Housing Needs Assessment
A Housing Needs Assessment (HNA) is an assessment of housing needs at the
Neighbourhood Area level.
Housing Products
Housing products simply refers to different types of housing as they are produced by
developers of various kinds (including councils and housing associations). Housing
products usually refers to specific tenures and types of new build housing.
Housing Size (Census Definition)
Housing size can be referred to either in terms of the number of bedrooms in a home
(a bedroom is defined as any room that was intended to be used as a bedroom when
the property was built, any rooms permanently converted for use as bedrooms); or in
terms of the number of rooms, excluding bathrooms, toilets halls or landings, or rooms
that can only be used for storage. All other rooms, for example, kitchens, living rooms,
bedrooms, utility rooms, studies and conservatories are counted. If two rooms have
been converted into one they are counted as one room. Rooms shared between more
than one household, for example a shared kitchen, are not counted.
Housing Type (Census Definition)
This refers to the type of accommodation used or available for use by an individual
household (i.e. detached, semi-detached, terraced including end of terraced, and
flats). Flats are broken down into those in a purpose-built block of flats, in parts of a
converted or shared house, or in a commercial building.
Housing Tenure (Census Definition)
Tenure provides information about whether a household rents or owns the
accommodation that it occupies and, if rented, combines this with information about
the type of landlord who owns or manages the accommodation.
Income Threshold
Income thresholds are derived as a result of the annualisation of the monthly rental
cost and then asserting this cost should not exceed 35% of annual household income.
Intercensal Period
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This means the period between the last two Censuses, i.e. between years 2001 and
2011.
Intermediate Housing
Intermediate housing is homes for sale and rent provided at a cost above social rent,
but below market levels subject to the criteria in the Affordable Housing definition
above. These can include shared equity (shared ownership and equity loans), other
low-cost homes for sale and intermediate rent, but not affordable rented housing.
Homes that do not meet the above definition of affordable housing, such as ‘low-cost
market’ housing, may not be considered as affordable housing for planning purposes.
Life Stage modelling
Life Stage modelling is forecasting need for dwellings of different sizes by the end of
the Plan period on the basis of changes in the distribution of household types and key
age brackets (life stages) within the NA. Given the shared behavioural patterns
associated with these metrics, they provide a helpful way of understanding and
predicting future community need. This data is not available at neighbourhood level so
LPA level data is employed on the basis of the NA falling within its defined Housing
Market Area.
Life-time Homes
Dwellings constructed to make them more flexible, convenient adaptable and
accessible than most ‘normal’ houses, usually according to the Lifetime Homes
Standard, 16 design criteria that can be applied to new homes at minimal cost:
http://www.lifetimehomes.org.uk/.
Life-time Neighbourhoods
Lifetime neighbourhoods extend the principles of Lifetime Homes into the wider
neighbourhood to ensure the public realm is designed in such a way to be as inclusive
as possible and designed to address the needs of older people, for example providing
more greenery and more walkable, better connected places.
Local Development Order
An Order made by a local planning authority (under the Town and Country Planning
Act 1990) that grants planning permission for a specific development proposal or
classes of development.
Local Enterprise Partnership
A body, designated by the Secretary of State for Communities and Local Government,
established for the purpose of creating or improving the conditions for economic
growth in an area.
Local housing need (NPPF definition)
The number of homes identified as being needed through the application of the
standard method set out in national planning guidance (or, in the context of preparing
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strategic policies only, this may be calculated using a justified alternative approach as
provided for in paragraph 60 of this Framework).
Local Planning Authority
The public authority whose duty it is to carry out specific planning functions for a
particular area. All references to local planning authority apply to the District Council,
London Borough Council, County Council, Broads Authority, National Park Authority
or the Greater London Authority, to the extent appropriate to their responsibilities.
Local Plan
This is the plan for the future development of the local area, drawn up by the local
planning authority in consultation with the community. In law this is described as the
development plan documents adopted under the Planning and Compulsory Purchase
Act 2004. Current core strategies or other planning policies form part of the Local Plan
and are known as ‘Development Plan Documents’ (DPDs).
Lower Quartile
The bottom 25% value, i.e. of all the properties sold, 25% were cheaper than this value
and 75% were more expensive. The lower quartile price is used as an entry level price
and is the recommended level used to evaluate affordability; for example for first time
buyers.
Lower Quartile Affordability Ratio
The Lower Quartile Affordability Ratio reflects the relationship between Lower Quartile
Household Incomes and Lower Quartile House Prices, and is a key indicator of
affordability of market housing for people on relatively low incomes.
Market Housing
Market housing is housing which is built by developers (which may be private
companies or housing associations, or Private Registered Providers), for the purposes
of sale (or rent) on the open market.
Mean (Average)
The mean or the average is, mathematically, the sum of all values divided by the total
number of values. This is the more commonly used “average” measure as it includes
all values, unlike the median.
Median
The middle value, i.e. of all the properties sold, half were cheaper and half were more
expensive. This is sometimes used instead of the mean average as it is not subject to
skew by very large or very small statistical outliers.
Median Affordability Ratio
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The Lower Quartile Affordability Ratio reflects the relationship between Median
Household Incomes and Median House Prices and is a key indicator of affordability of
market housing for people on middle-range incomes.
Mortgage Ratio
The mortgage ratio is the ratio of mortgage value to income which is typically deemed
acceptable by banks. Approximately 75% of all mortgage lending ratios fell below 4 in
recent years
20
, i.e. the total value of the mortgage was less than 4 times the annual
income of the person who was granted the mortgage.
Neighbourhood Development Order (NDO)
An NDO will grant planning permission for a particular type of development in a
particular area. This could be either a particular development, or a particular class of
development (for example retail or housing). A number of types of development will be
excluded from NDOs, however. These are minerals and waste development, types of
development that, regardless of scale, always need Environmental Impact
Assessment, and Nationally Significant Infrastructure Projects.
Neighbourhood plan
A plan prepared by a Parish or Town Council or Neighbourhood Forum for a particular
neighbourhood area (made under the Planning and Compulsory Purchase Act 2004).
Older People
People over retirement age, including the active, newly-retired through to very frail
older people, whose housing needs can encompass accessible, adaptable general
needs housing for those looking to downsize from family housing and the full range of
retirement and specialised housing for those with support or care needs.
Output Area/Lower Super Output Area/Middle Super Output Area
An output area is the lowest level of geography for publishing statistics, and is the core
geography from which statistics for other geographies are built. Output areas were
created for England and Wales from the 2001 Census data, by grouping a number of
households and populations together so that each output area’s population is roughly
the same. 175,434 output areas were created from the 2001 Census data, each
containing a minimum of 100 persons with an average of 300 persons. Lower Super
Output Areas consist of higher geographies of between 1,000-1,500 persons (made
up of a number of individual Output Areas) and Middle Super Output Areas are higher
than this, containing between 5,000 and 7,200 people, and made up of individual
Lower Layer Super Output Areas. Some statistics are only available down to Middle
Layer Super Output Area level, meaning that they are not available for individual
Output Areas or parishes.
20
See https://www.which.co.uk/news/2017/08/how-your-income-affects-your-mortgage-chances/
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Overcrowding
There is no single agreed definition of overcrowding, however, utilising the
Government’s bedroom standard, overcrowding is deemed to be in households where
there is more than one person in the household per room (excluding kitchens,
bathrooms, halls and storage areas). As such, a home with one bedroom and one
living room and one kitchen would be deemed overcrowded if three adults were living
there.
Planning Condition
A condition imposed on a grant of planning permission (in accordance with the Town
and Country Planning Act 1990) or a condition included in a Local Development Order
or Neighbourhood Development Order.
Planning Obligation
A legally enforceable obligation entered into under section 106 of the Town and
Country Planning Act 1990 to mitigate the impacts of a development proposal.
Purchase Threshold
Purchase thresholds are calculated by netting 10% off the entry house price to reflect
purchase deposit. The resulting cost is divided by 4 to reflect the standard household
income requirement to access mortgage products.
Proportionate and Robust Evidence
Proportionate and robust evidence is evidence which is deemed appropriate in scale,
scope and depth for the purposes of neighbourhood planning, sufficient so as to meet
the Basic Conditions, as well as robust enough to withstand legal challenge. It is
referred to a number of times in the PPG and its definition and interpretation relies on
the judgement of professionals such as Neighbourhood Plan Examiners.
Private Rented
The Census tenure private rented includes a range of different living situations in
practice, such as private rented/ other including households living “rent free”. Around
20% of the private rented sector are in this category, which will have included some
benefit claimants whose housing benefit at the time was paid directly to their landlord.
This could mean people whose rent is paid by their employer, including some people
in the armed forces. Some housing association tenants may also have been counted
as living in the private rented sector because of confusion about what a housing
association is.
Retirement Living or Sheltered Housing
Housing for older people which usually consists of purpose-built flats or bungalows
with limited communal facilities such as a lounge, laundry room and guest room. It
does not generally provide care services, but provides some support to enable
residents to live independently. This can include 24 hour on-site assistance (alarm)
and a warden or house manager.
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Residential Care Homes and Nursing Homes
Housing for older people comprising of individual rooms within a residential building
and provide a high level of care meeting all activities of daily living. They do not usually
include support services for independent living. This type of housing can also include
dementia care homes.
Rightsizing
Households who wish to move into a property that is a more appropriate size for their
needs can be said to be rightsizing. This is often used to refer to older households who
may be living in large family homes but whose children have left, and who intend to
rightsize to a smaller dwelling. The popularity of this trend is debatable as ties to
existing communities and the home itself may outweigh issues of space. Other factors,
including wealth, health, status and family circumstance also need to be taken into
consideration, and it should not be assumed that all older households in large
dwellings wish to rightsize.
Rural Exception Sites
Small sites used for affordable housing in perpetuity where sites would not normally
be used for housing. Rural exception sites seek to address the needs of the local
community by accommodating households who are either current residents or have
an existing family or employment connection. Small numbers of market homes may
be allowed at the local authority’s discretion, for example where essential to enable
the delivery of affordable dwellings without grant funding.
Shared Ownership
Housing where a purchaser part buys and part rents from a housing association or
local authority. Typical purchase share is between 25% and 75% (though this was
lowered in 2021 to a minimum of 10%), and buyers are encouraged to buy the largest
share they can afford. Generally applies to new build properties, but re‐sales
occasionally become available. There may be an opportunity to rent at intermediate
rent level before purchasing a share in order to save/increase the deposit level
Sheltered Housing
21
Sheltered housing (also known as retirement housing) means having your own flat or
bungalow in a block, or on a small estate, where all the other residents are older people
(usually over 55). With a few exceptions, all developments (or ‘schemes’) provide
independent, self-contained homes with their own front doors. There are many
different types of scheme, both to rent and to buy. They usually contain between 15
and 40 properties, and range in size from studio flats (or ‘bedsits’) through to 2 and 3
bedroomed. Properties in most schemes are designed to make life a little easier for
older people – with features like raised electric sockets, lowered worktops, walk-in
showers, and so on. Some will usually be designed to accommodate wheelchair users.
And they are usually linked to an emergency alarm service (sometimes called
‘community alarm service’) to call help if needed. Many schemes also have their own
21
See http://www.housingcare.org/jargon-sheltered-housing.aspx
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‘manager’ or ‘warden’, either living on-site or nearby, whose job is to manage the
scheme and help arrange any services residents need. Managed schemes will also
usually have some shared or communal facilities such as a lounge for residents to
meet, a laundry, a guest flat and a garden.
Strategic Housing Land Availability Assessment
A Strategic Housing Land Availability Assessment (SHLAA) is a document prepared
by one or more local planning authorities to establish realistic assumptions about the
availability, suitability and the likely economic viability of land to meet the identified
need for housing over the Plan period. SHLAAs are sometimes also called LAAs
(Land Availability Assessments) or HELAAs (Housing and Economic Land Availability
Assessments) so as to integrate the need to balance assessed housing and economic
needs as described below.
Strategic Housing Market Assessment (NPPF Definition)
A Strategic Housing Market Assessment (SHMA) is a document prepared by one or
more local planning authorities to assess their housing needs under the 2012 version
of the NPPF, usually across administrative boundaries to encompass the whole
housing market area. The NPPF makes clear that SHMAs should identify the scale
and mix of housing and the range of tenures the local population is likely to need over
the Plan period. Sometimes SHMAs are combined with Economic Development
Needs Assessments to create documents known as HEDNAs (Housing and Economic
Development Needs Assessments).
Specialist Housing for Older People
Specialist housing for Older People, sometimes known as specialist accommodation
for older people, encompasses a wide range of housing types specifically aimed at
older people, which may often be restricted to those in certain older age groups
(usually 55+ or 65+). This could include residential institutions, sometimes known as
care homes, sheltered housing, extra care housing, retirement housing and a range
of other potential types of housing which has been designed and built to serve the
needs of older people, including often providing care or other additional services. This
housing can be provided in a range of tenures (often on a rented or leasehold basis).
Social Rented Housing
Social rented housing is owned by local authorities and private registered providers
(as defined in Section 80 of the Housing and Regeneration Act 2008.). Guideline target
rents for this tenure are determined through the national rent regime. It may also be
owned by other persons and provided under equivalent rental arrangements to the
above, as agreed with the local authority or with Homes England.
22
22
See http://www.communities.gov.uk/documents/planningandbuilding/doc/1980960.doc#Housing
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