The NPPF Consultation: delivery of the homes people want and need, including seniors housing

The Government issued a consultation in December 2022 about its proposed changes to the NPPF. These represent the first set of changes to the NPPF that the Government intends to make in order to reflect its levelling-up agenda, and will be followed by a wider review once it has implemented its proposals for wider changes to the planning system, including the Levelling-up and Regeneration Bill.

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What aspects of the NPPF does the review focus on?

The consultation sets out changes that the Government proposes in order to "build enough of the right homes in the right places with the right infrastructure, ensuring the environment is protected and giving local people a greater say on where and where not to place new, beautiful development."

What does this review mean for the senior living sector?

While the familiar mantra of building more homes, faster' continues to pervade the consultation, it does acknowledge the importance of new, diverse, housing which reflects a range of local needs and circumstances- it should not just be about the numbers.

In the context of establishing the minimum number of houses needed in a local area, the new draft NPPF would now require the local planning authority to assess and "reflect" in local planning policies the size, type and tenure of housing needed by older people including for retirement housing, housing-with-care and care homes (our emphasis), alongside the existing categories of those who require affordable housing, families with children, students, people with disabilities, service families, travellers, people who rent their homes and people wishing to commission or build their own homes.

There is no proposed change to the definition of 'Older People' who remain defined as people over or approaching retirement age, including the active, newly-retired through to the very frail elderly; and whose housing needs can encompass accessible, adaptable general needs housing through to the full range of retirement and specialised housing for those with support or care needs.

This is an encouraging step forward for the senior living sector, since the updated NPPF draft text specifically references all 3 sub-categories of seniors housing. This should help to set clearer expectations at a national level around planning for older peoples' housing. It stops short, however, of defining the sub-categories which could have helped to introduce some consistency of interpretation and expectation.

Importantly, while acknowledging the 2021 report by the international Longevity centre, which indicated that there will be a shortfall of 37% in specialist retirement housing by 2040, it does not propose the induction of a requirement that Local Plans include policies specifically addressing the provision of older peoples' housing. That feels like a missed opportunity, particularly given the pace of change required if the planning system is to adequately support (rather than hinder) the level of increased delivery required to meet future funds.

Is there anything else that it would be helpful for the NPPF to say in order to support the senior living sector?

Housing with care can be difficult to achieve in a scheme that provides for seniors of different financial means, because it is difficult to provide a gold service level to some and a bronze to others in the same scheme. It is great news for society as a whole that national planning policy may reflect the need for specialised accommodation for the elderly. However, there remain concerns that this will not filter down to a local level. Further, it would be helpful if those Local Plan policies that do emerge are sufficiently nuanced to reflect the range of financial circumstances of that local senior population. It would also be useful for the NPPF to support opportunities for senior living within the existing community as well as separate stand alone new communities and/or to recognise the opportunity for new standalone schemes to provide services to the wider (non-seniors) community, such as leisure and other community buildings - i.e. not seeing these as gated communities but one in which they are connected to the wider population.

More widely, it would also be useful to set out what would be appropriate in terms of planning obligations and conditions, including affordable housing requirements on the development of seniors accommodation. If the senior living scheme in question is providing social/outward services, how should this be taken into account in meeting those requirements?

Conclusion

The proposal to include reference to seniors housing in the calculation of a local housing need assessment is encouraging news for the sector, but, there remains much to be done to meet aspirations, particularly at a local level. It is therefore important to respond to the consultation before it closes on 2 March 2023, if only to agree with its inclusion via question 23.

Text from the consultation that relates to the senior living sector

This government is committed to further improving the diversity of housing options available to older people and boosting the supply of specialist elderly accommodation. The National Planning Policy Framework supports this ambition by asking local authorities to provide for a diverse range of housing needs, including for older people.

The Framework already makes clear that the size, type and tenure of housing needed for different groups in the community, including older people, should be assessed and reflected in planning policies. In 2019, we also published guidance to help local authorities implement the policies that can deliver on this expectation.

The population of the UK is ageing rapidly and around 1-in-4 will be aged 65 or over by 2041. We need to ensure that our housing market is prepared for this challenge and that older people are offered a better choice of accommodation to suit their changing needs, to help them to live independently and feel more connected to their communities. In 2021, a report by the International Longevity Centre indicates that there will be a shortfall of 37% in specialist retirement housing by 2040.

We have therefore been considering ways in which the Framework can further support the supply of older people’s housing. We propose to do this by adding an additional specific expectation that within ensuring that the needs of older people are met, particular regard is given to retirement housing, housing-with-care and care homes, which are important typologies of housing that can help support our ageing population.

Alongside this, we are also launching a taskforce on older people’s housing, which we announced in the Levelling Up White Paper. This taskforce will explore how we can improve the choice of and access to housing options for older people and will follow important work conducted recently by Professor Mayhew on meeting the challenges of our ageing population.

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