Can Labour’s Changes to Planning Policy Help Resolve the Later Living Crisis?

The housing crisis is impacting on all demographics. We frequently read about the problems experienced by first time buyers in getting a foot on the property ladder, but the problems at the other end of the age spectrum are just as acute. Furthermore, as a consequence of the currently proposed changes to national planning policy and further proposed planning reforms, sadly it seems inevitable the existing shortcomings are more likely to exacerbate rather than abate the crisis.  

In July, the then new Labour government published revisions to the National Planning Policy Framework (NPPF). Consultation on the revisions led to the final publication version, which was released in December. 

The reforms to planning policy have been received positively by the wider development industry, as a means to tackle the housing crisis.  But how will the changes impact on specialist housing, specifically the later living sector? 

The Grey Belt 

The proposed introduction of a ‘Grey Belt’ designation is likely to be the primary source of delivering this additional and specialist housing. 

One of the Government’s ‘Golden Rules’ for development in the Green Belt is ensure that maximum public gain is obtained from new development in these areas – specifically that 50% of any new development is affordable housing.   

However, these ‘Golden Rules’ do not include provision for affordable later living accommodation.  

As set out within the recently released report from the Older People's Housing Taskforce (OPHT), there is currently an insufficient supply of later living housing (across both the mainstream and specialist accommodation). Furthermore, research by the OPHTA highlights that current private leasehold older person’s housing options are unaffordable for the majority of English households aged 75 years and over. This is a significant challenge which the proposed reforms to the NPPF do not currently address.  

Brownfield development 

In addition to supporting more development on the Green Belt, the government has placed a renewed focus on brownfield sites. Brownfield sites should be a priority to address the housing crisis and provide opportunities to maximise previously development land that is often well-served by public transport and infrastructure.  

However, the further emphasis given to maximising brownfield land and building at higher densities will place a further barrier to promoters and developers of older people’s homes. Competition for limited land opportunities in such locations which are more suitable for older people’s homes will increase. 

It is important to acknowledge that not all older people’s accommodation is suited to delivery within the confines of existing urban area defined. For example, integrated retirement communities (IRC) include a provision of high levels of on-site amenity space and both recreational and care facilities and so densities can be lower than comparable (in terms of unit size) general housing developments. Operators and promoters of IRCs often find themselves taking marginal sites which are less attractive to the volume housebuilders. Many of these sites are on edge of settlements, former agricultural land and or undeveloped sites within the Green Belt. 

What amendments could/should be brought forward?  

The OPHT calls for stronger planning policies at a national and local level, in order to help boost the supply of later living housing. The OPHT recommends that local authorities be given, ‘the right levers to address the under-supply of later living housing, including ensuring sufficient land is made available to support the volumes of new supply needed, raising the profile and priority given to later living housing in local plans,’ which will hopefully bring confidence to providers and help overcome the “social reluctance to plan for old age.  This message should be conveyed to local authorities through updated National Planning Policy Guidance.  

I believe that the NPPF should be amended to include a clear direction that through local plan review, local planning authorities (LPAs) are required to undertake an objective and robust identification and understanding of current and forecast needs across the new plan’s period. The assessment must not be just for overall older persons’ accommodation. It needs to drill down into the type of care needed (general and specialist) and at least attempt to grapple with where the accommodation is most needed across the LPA. 

Secondly, there is no ‘one size fits all’ solution to older persons’ housing. LPAs should be facilitating  a range of options to provide needs-based supply (meeting at least the minimum level of need) as well as the different typologies of older people’s housing needs. And of equal importance, identifying the right locations and areas for delivery of new older people’s homes and accommodation – in most cases, town centres and locations where services, transport and facilities are already and are planned to be readily available.    

Furthermore local plans should allocate sufficient number of sites, in the right locations for the delivery of older people’s homes. Presently where local plans do include an allocation, it is usually for a care home within a much larger strategic site allocation. Local plans should be looking to allocate sites in existing town and village centres, and on edges of settlements where such locations meet the locational needs of the type of accommodation needed by the community.   

Finally, local plans should continue to include at least one policy supporting the delivery of new older persons’ homes – across all typologies. It’s important the planning system remains plan-led. But it must not become plan-absolute led. Local plans cover periods of a minimum 15-years. Changing economic, social and demographic circumstances rarely have regard for the duration of plan-making, plan lifespan and review cycles. It is important that planning policy, national and local, provides for speculative application secured developments – when the needs are demonstrated.  

Conclusion 

The change of government creates a new opportunity. However, it seems that in a rush to publish the new NPPF, the new government has failed to address this problem.  

The revisions to the NPPF have not done enough to remove the gaps within current policy guidance, such as a general lack of promotion of the delivery of specialist accommodation and uncertainty around whether extra care development should be required to make contributions towards affordable housing and CIL. And there is so much more that could be done to promote and support later living accommodation through planning policy, such as implementing the recommendations made within the OPHT report including establishing a planning presumption in favour of new developments for older people; new assessments of housing need for older people; and measures to address the viability restraints on the development of later living accommodation. We can only hope that the imminent Planning and Infrastructure Bill or subsequent updated National Policy Guidance does more to address this issue.