-Age Concern

Age Concern London response to Consultation on the draft replacement London Plan

Age Concern London (ACL) is the regional body of Age Concern in London.  ACL works with borough Age Concerns (who are its members) to promote the interests of older people and campaign on strategic issues of ageing and demographic change in the capital, and works to support the organisational development of Age Concerns and partners.  At borough level and more locally, Age Concerns provide services for older people and work in partnership with colleagues in all sectors to promote issues important to older people.

ACL welcomes this opportunity to comment on the draft replacement London Plan. We also cooperated with Care and Repair, the GLA, London Older People’s Strategies Group (LOPSG) and the Greater London Forum of Older People to hold a discussion event on the London Plan at City Hall in  December 2009. A specific submission is being made on behalf of the older people who attended that event and we commend that submission to your attention.

In general we find that the draft London Plan recognizes the importance of planning for London’s growing number of older people. However there is a limitation in that the draft looks at older people’s needs for appropriate housing and services, but does not seem to consider older people’s contribution to London as workers, volunteers, grandparents, carers and in many other roles. This is particularly apparent in the section on economic opportunity.

Comments on Sections and Policies:

1.            Context and Strategy

ACL welcomes the recognition of the need to plan for a changing population including greater numbers of older people. (paras. 1.11 to 1.13). We urge that the implications should be fully thought through in areas including the economy and employment as well as health and social care, housing and neighbourhood planning.

2.            London’s Places

While of course all areas of London need full attention to their social, environmental and economic development, ACL can welcome strengthened policies for Outer London from a demographic point of view. In Outer London boroughs the proportions of older people in the population are higher than in Inner London and closer to the national average, and this has a range of implications.

We welcome the stress on quality of life and the recognition that quality of life must include “high quality “lifetime” neighbourhoods with sufficient, good quality social infrastructure provision” (see below for our more specific comments on housing and neighbourhood planning). Good quality of life, lifetime neighbourhoods and sufficient good quality social infrastructure should also be the aim for Inner London.

People aged 50+ who are employed or would like to be employed, are often looking for employment close to where they live: this is particularly worth bearing in mind when considering development in Outer London with its considerable older population.

Chapter 3 – London’s People


ACL can generally welcome the Plan’s intention of meeting the housing needs of people of all ages. We have made detailed comments in responses to the draft London Housing Strategy and London Housing Design Guide. Some of these also apply to the London Plan and there are some areas in which we feel the proposals need to be strengthened.

Policy 3.8 – Housing Choice

ACL considers the requirement that “all new housing is built to Lifetime Homes standards” an extremely welcome and important feature which absolutely needs to be retained in the final Plan.

ACL considers that the requirement on wheelchair accessibility needs to be strengthened: in other words all new housing should be easily adaptable for wheelchair users, with for example minimum door width standard increased to 900 mm in all new build housing. At least 10% of all new housing should provide wheelchair specific facilities such as ramps, wider doors, lower fittings and fixtures etc.

If only 10% of new housing is to be either wheelchair accessible or easily adaptable, this would imply that 90% will be inaccessible and not easily adaptable.

At the consultative event ACL co-organised with Care and Repair and other partners in December 2009, participants made similar points on wheelchair access and defined other features that should be ensured in homes:

  • “Space: is particularly important. There was a view that bedsits should be phased out and one bedroomed homes are still too small for many people. Sufficient storage space is also important.
  • Access: easy access front and rear.
  • Ground level: some felt an ideal home should be on one level. Others recommended toilets on all floors with washing and laundry facilities on the ground floor. Lifts to be included as a mandatory requirement in blocks of flats and homes suitable for a stair lift to be fitted if necessary.
  • Security: especially for ground floor flats and good external lighting for blocks of flats
  • Sound: adequate sound proofing, especially between floors.
  • Heating: suitable low cost heating with easy controls
  • Bathing: step free walk in shower”

ACL also welcomes the stated policy to take account of  the varied needs of older Londoners including for supported and affordable accommodation. (While we think that the published research on needs in London for supported housing for older people and other groups underestimates the scale of need).

The mention of “supported and affordable housing” and paragraph 3.43  extend principles of the policies on affordable housing (presumably including intermediate housing) to cover housing which caters specifically for older people. This appears a welcome step which ACL has called for in the past. The whole content of paragraph 3.43 on borough  assessment of needs for supported housing is very welcome.

Supported housing provision needs to take account of diversity among older people. For example there is a grave lack of provision suited to the needs of older people from different BAME groups. Older LGBT people report experiencing homophobia from staff and other residents in supported housing and residential or care homes, and many therefore feel that existing provision excludes them.

Policy 3.17 – Protection and enhancement of social infrastructure

ACL welcomes the inclusion of this policy and its spirit and would like to suggest some additions. In paragraph 3.79, social infrastructure should include health and social care provision (not only health). Social care, which is normally funded by local authorities, is very important to many vulnerable older people and other vulnerable people and would not automatically be included in “health provision” which may indicate only NHS services. Community meeting facilities such as community halls are also an important part of social infrastructure. Informal recreation facilities should also include recreation facilities of interest to people of all ages.

In para. 3.84 there is a welcome acknowledgement of the difficulty in finding suitable premises for voluntary and community organizations, who are recognized elsewhere in the Plan as making a key social contribution. In our view voluntary and community organizations should include Community Transport provision.

However we would urge the Mayor to go further than calling for “unused or underused facilities” to be brought into use: planning should ensure provision of social infrastructure and this should include premises suitable for voluntary and community organizations.

Policy 3.18 – Healthcare facilities

ACL welcomes this policy but urges that it should be amended to cover “health and social care facilities” for the reasons outlined under policy 3.17.

Chapter 4 – London’s Economy

Policies in this section should also include support to the voluntary and community sector, which employs 7% of London’s workforce and makes a strong economic as well as social contribution to London’s success.

Policy 4.12 – Improving opportunities for all

This Policy is important but it is very disappointing that it includes no mention of the contribution of London’s older people to the economy through paid employment, volunteering and childcare and recognition of the issues facing older people (50+ with no upper limit) in the labour market. There is evidence that very many older Londoners work in paid employment, and very many others would like to:

This has been recognized by the London Assembly in its report “UB50?”, and by the 2006 Mayor’s Older People’s Strategy “Valuing Older People” which identified that over 10% of Londoners of State pension age have paid employment, while older people also make a huge contribution as volunteers.

Some of the evidence has been developed by ACL working together with the LDA. The research report “Making Age Work for London” identifying a broad range of labour market issues for older people was part-funded by the LDA and included on the LDA website. More recently, the LDA commissioned ACL to carry out research into employment support services for people aged 50+ in London. The report “Locating the Unknown” was completed for the LDA in 2008: it has not yet been published. At the end of 2008 ACL published a report “A Wealth of Experience” (attached). One if its findings was that based on the Labour Force Survey, some 108,000 Londoners aged 50+ were either looking for work or wanted to work, while only 22,000 were in groups identified as Jobcentre Plus clients. The difference suggests that a considerable number of older people wanting work are not being reached by employment programmes.

Of these 108,000 older Londoners wanting work, at least 10,000 were aged over 65. (The Labour Force Survey does not ask people aged 70 or more if they want to work). This research was carried out immediately before the economic downturn in autumn 2008, suggesting that the equivalent figures might be higher today.

Chapter 6 – Transport

Transport and in particular, transport accessibility are a central concern for many of London’s older people. Many discussions around older people’s contribution to London and older people’s social involvement and access to services involve the question “how do we get there?”

Therefore work on transport has been a high priority for ACL recently. In 2009 we published jointly with partner organisations, a statement entitled “Breaking Barriers” setting out our view of current transport services for older people and disabled people in London and how we would like to see them evolve in future (attached for information). We also commissioned jointly with Transport for London a research report “Understanding older people’s travel barriers and their impacts” which looks at how inaccessible transport affects older people’s lives, and the implications for transport services.

Policy 6.4 – Enhancing London’s transport connectivity


Policy 6.5. – Funding Crossrail and other strategically important transport infrastructure

While welcoming many of the proposals to improve transport accessibility in the Mayor’s Transport Strategy which is currently under consultation, ACL has been disappointed by the downscaling and delay to plans to improve step free access to the Underground network.

We therefore urge the Mayor to include and identify the cost of faster and more substantial improvements to step free access to the Underground within these London Plan policies.

Chapter 7 – London’s Living Places and Spaces

ACL strongly supports the aims of  Policies 7.1 to 7.5 on neighbourhood planning, an inclusive environment, “Secured by design” and the public realm. While the policies aim for the objective of “Lifetime Neighbourhoods” we would appreciate a reference to the national older people’s  housing strategy “Lifetime Homes, Lifetime Neighbourhoods”[1].

Older people at the jointly-organised consultation event on the London Plan in December 2009 identified the following as features of a suitable neighbourhood for older people to live in:

“Neighbourhoods: in the neighbourhood, transport continues to be a major issue. Facilities are also very important-not only that they exist, but are well signposted, suitable and accessible. Leisure, learning and social opportunities are also important. The scope to be more challenging (and less “dumbed down” or “patronising”) should be recognised in activities tailored for older people. It was questioned whether we can deliver ideal communities at a time of service cuts.

Transport: for many people transport continues to be the most important factor in creating a lifetime neighbourhood. Community transport or hail and ride facilities on some bus routes were proposed. There was also a request for improved access to bus services for disabled people. People strongly back Policy 6.2 and wanted to see increased investment in public transport.

Design: ensuring suitable walkways also featured strongly in people’s comments. Safe, well maintained and wider pavements with dropped curbs for wheelchairs are important to neighbourhoods.  People also wanted to see pedestrian crossings geared less in favour of traffic. Good pedestrianised areas are also supported with well controlled restrictions on bicycles.

Facilities: a wide range of facilities were suggested for an ideal lifetime neighbourhood. Those particularly highlighted include (1) toilets (2) local shops (3) Post office (4) health related services:

  • Toilets: people felt that this should receive London wide attention and is vital to enable people to access local centres. While there were borough’s identified as having good provision, others were poor.
  • Local shops: there was strong backing for the new policy 4.9, supporting small shops. People rated having at least a small number of local shops very highly.
  • Post Office: people continue to highly value a local Post office service.
  • Health related services: medical treatment close to home is an important feature of any lifetime neighbourhood. Apart from a health centre other related services include: chiropody, dentistry, opticians, physiotherapy, other therapies and a  pharmacy.
  • Leisure, entertainment & learning: including a community centre, sports centre, swimming pool, library, cafe’s, pubs and restaurants.
  • Other retail outlets: including a bank and newsagent.
  • Green and open spaces: accessible and safe green spaces. More greenery.
  • Other facilities: there was support for the proposal to include drinking water fountains were appropriate in new development (Page 174 policy 7.5). Other important public realm features include litter bins, seats and shelters and recycling facilities.”

(Quoted from draft response on behalf of the event participants)

Age Concern London, January 2010

[1] http://www.communities.gov.uk/publications/housing/lifetimehomesneighbourhoods


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