The impact of change in planning in the care sector
The National Planning Policy Framework (NPPF), the policy document which forms the basis of our planning system, has been revised. Following a stakeholder consultation, the extent to which these revisions will take effect is awaited.
The proposed changes appear to recognise that the planning system is partially responsible for the current under-supply of care homes. In Chapter 5: ‘Delivering a sufficient supply of homes’, it adds to existing guidance (that, ‘the need, the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies,’): ‘including for retirement housing, housing-with-care and care homes’.
This amendment seems well meant and may result in Local Plans (the documents which determine strategic planning at a local level) being better informed of the care needs of older people.
However, the change in policy followed November’s rebellion by anti-development backbench Tory MPs who were opposed to top-down housing targets and development on greenfield land. As a consequence, if the proposed revisions are adopted it could result in a significant reduction in the release of land for development and the supply of homes, and this will impact significantly on the future development of specialist older people’s housing and care homes.
One of the main changes in planning guidance is the prioritisation of brownfield over greenfield site and renewed protection of the Green Belt.
The emphasis on maximising brownfield land and building at higher densities will also place a further challenge to developers of care facilities, because such facilities are generally better suited to tranquil rural edge-of-settlement locations than more urban sites. Furthermore, the high levels of on-site recreational and amenity space and care facilities required by integrated retirement communities means that densities are generally lower than general housing developments, which can become unviable in the case of more costly urban sites. Accordingly, competition for limited land opportunities in preferred locations will increase.
So, unfortunately, the consequence of the proposals could be that delivery of older people’s accommodation and homes will be hindered, rather than ‘significantly increased’ as the revised NPPF promises.
We would like to see the NPPF amended to include a clear direction that through local plan review, local planning authorities are required to undertake an objective and robust identification and understanding of current and forecast needs across the new plan’s period (typically 15 years), drilling down into the type of care needed (both general and specialist).
Furthermore local plans should then allocate sufficient numbers of sites, in the right locations, based on their specific assessment of need. Presently where local plans do include for a care home or specialist housing, it is usually within a much larger strategic site allocation. Local plans should also allocate sites specifically for later living / care which meet the locational needs of the occupants, not solely as an add-on to an existing new development.
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 of 15-years, during which time economic, social and demographic circumstances can change significantly. It is important that planning policy, national and local, provides for both strategically planned and also speculative applications where the need exists.
The revisions to the NPPF proposing to improve the diversity and supply of housing options available to older people are welcomed, especially at a time when our population is ageing and there is a documented under-supply of senior living housing units. However, in order to ensure that the delivery of older person’s accommodation can be delivered effectively, there are substantial issues which will need to be addressed first.