"The NPPF should be encouraging, if not requiring, that through a local plan review an integral component of identifying minimum housing needs overall, is an objective identification of the later living needs across the new plan’s period"
We frequently read about the problems experienced by first-time buyers. But the problems at the other end of the age spectrum are just as acute. As a consequence of the recently proposed changes to the NPPF, it seems inevitable that our current shortcomings are on a path to exacerbating rather than abating.
The proposed revised NPPF includes some positive commentary on later living: introducing that, ‘particular regard is given to retirement housing, housing-with-care and care homes’. But while this overarching recognition is encouraging, it is hard to see how sufficient supply will be facilitated to materialise through our embattled planning system.
An alarming set of changes have been proposed: for example that local plans no longer need to be justified; enhanced rhetoric on ‘brownfield first’, and the explicit proposal that Green Belt boundaries need not be reviewed and altered if this is the only means of meeting minimum objectively assessed housing needs.
Not all older people’s accommodation is suited to delivery within existing urban areas and on brownfield sites. For example, integrated retirement communities can include larger amounts of on-site amenity space and care facilities which consequently require larger sites delivering at lower densities compared to general housing developments.
In certain areas, this frequently requires identification and delivery of existing non-urban and Green Belt designated sites. But under the proposed amendments such sites will become much, much harder to deliver.
The NPPF should be encouraging, if not requiring, that through a local plan review an integral component of identifying minimum housing needs overall, is an objective identification of the later living needs across the new plan’s period. Importantly this should specifically include establishing an understanding of the types of care needed.
Local plans should also be expected to proactively allocate a sufficient number and type of sites – in the right locations – to meet the communities’ later living needs.
Finally, all local plans should include at least one policy-supporting provision across all typologies.
It’s important the system remains plan-led, but not plan-absolute. Local plans currently cover a minimum of 15 years. Changes in economic, social and demographic circumstances rarely have regard for aligning durations.
