Government guidance on Planning for Older People can’t come soon enough

The challenges of meeting the needs of an ageing population have been around for quite some time (eg the RTPI Practice Guidance Note 8 was published in 2007); and yet there are still wide discrepancies as to how receptive local areas are to the provision of housing for older people. 

Ten years on and the Government issued a consultation last week, ‘Planning for the right homes in the right places’ (opens new window), which set out their proposals to reform the planning system to increase the supply of new homes and increase local authority capacity to manage growth.

The Government is committed to delivering the best outcomes for older people as stated in the Housing White Paper, ‘Fixing the broken housing market’ (opens new window). Crucially, the Neighbourhood Planning Act 2017 compels the Secretary of State to issue guidance on older people in local plans:

“The Secretary of State must issue guidance for local planning authorities on how their local development documents (taken as a whole) should address housing needs that result from old age or disability.”

National Planning Guidance already stresses the critical importance of Planning for Older People (para 2a-021-20160401 (opens new window)), so what else should Communities Secretary Sajid Javid, say and what else could be done? Interestingly, the current consultation paper states that Government is reviewing whether there is a need to amend the definition of older people for planning purposes.  However, at the same time, says:

“We consider that the current definition is still fit-for-purpose but would welcome views.“ (para 93)

Standardised Approach to Need

This month, the Government issued its standardised methodology for calculating Objectively Assessed Housing Need (opens new window). So far, the detail has only focussed on adjustments to address affordability to the totality of housing need. This new standard approach needs to explicitly address the complex needs of housing for older people. Hopefully, this will be borne out in the Government’s proposal that total housing need should be disaggregated into different types of homes when preparing  new plans.

Specify contribution to housing supply

Local planning authorities are driven by the need to keep up their housing land supply in order that the policies in Local Plans can be given full weight. And yet, there are significant differences as to how they count care homes in relation to housing land supply. Some consider that extra bed spaces offer nothing towards housing land supply, whereas others consider that a proportion does as it frees up homes elsewhere. It is possible that this drives behaviour and how receptive different authorities are to developments. And the Planning Inspectorate deals with it on a case by case, authority by authority basis, as illustrated in another recent Housing LIN guest blog. Providing clear guidance would be help address the current postcode lottery.

The need should be a given

A recent article in Property Week (opens new window) highlighted how many Local Plans do not have specific policies or allocations addressing the needs of older people. However, looking at the detail of some specific policies in Local Plans, it suggests there is still not a level playing field and unnecessary hoops to jump through. In one local plan proposals for Older People housing will only be allowed if evidence of need can be demonstrated. The need should be a given – there is no such requirement to demonstrate this for general housing.

Update Use Class Order

As has already been highlighted in an earlier Housing LIN guest blog, the current Use Class Order is not fit for purpose. For instance, the Extra Care model does not easily fit into either C2 or C3. This is something that local councils (and applicants) have to grapple with (opens new window) in each and every case. Two options could be considered – redefining the descriptions or the creation of a new use class specifically for housing older people.

Change the NPPF

It is mooted that the National Planning Policy Framework will be updated within the next year; there is an opportunity to shape this now. The Framework currently suggests local authorities should plan for housing based on needs of different groups including older people, but it should go further. Perhaps a statement should be inserted along the lines of:

“Significant weight should be given to the provision of housing for older people in both plan making and decision taking”

The above suggestions are just some of the things that the Secretary of State should consider, we are sure there are plenty of others. And these changes should assist planners both when preparing plans and determining applications. Then in future we may not be faced with situations like we recently experienced where the Planning Officer did not see the provision of housing for older people as important as other considerations and recommended refusal. Thankfully, the elected members of the Council’s Planning Committee agreed with us that this was an issue of critical importance and granted permission.  But, it shouldn’t have to be like this, everyone should be singing from the same hymn sheet, clearly changes to the planning system can’t come soon enough.

Lastly, if you found this of interest, the DCLG public consultation on further measures set out in the housing white paper to boost housing supply in England, including reference to housing for older people, closes at 11.45pm on 9 November 2017. Respond online at: https://www.surveymonkey.co.uk/r/planningforhomes (opens new window)