Sarah Roe (Associate Director with a specialism in Later Living) discusses how the Updated National Planning Policy Framework (NPPF) fails to proactively plan for delivering more, and a better quality and choice of, housing for older people and how current political uncertainty may provide another opportunity for the sector to achieve the planning policy reform that is so desperately required.

The updated NPPF was released in December 2023 after much speculation.  Many had hoped it would include an increased emphasis on meeting the housing needs of older people compared with the previous NPPF, in particular requiring local planning authorities to clearly identify the amount of housing needed for older people.  Speaking at a conference last year, the (then) Housing Minister Rachel MacLean advised that both were early recommendations of the Housing for Older People Taskforce due to be reported to Ministers in late 2023.

However, like so many other aspects of the updated NPPF, the changes in respect of housing for older people lack any real substance with many of the ‘changes’ simply re-worded versions of statements included in the previous NPPF.  Crucially, the updated NPPF fails to make the most obvious and simplest of change, which is to reiterate the “critical” need for more housing for older people set out in the National Planning Practice Guidance: Housing for Older and Disabled People.  This change alone would have brought the pressing need for more housing for older people ‘front and centre’, which taking into account the status of the NPPF as the principal planning document in the country and the fundamental shift in the country’s demographics, we consider it should.  Other types of housing such as affordable housing are given due prominence in the Updated NPPF, so why not housing for older people (mentioned just twice)?

Paragraph 60 includes a new statement advising the overall aim for local planning authorities “should be to meet as much of an area’s identified housing need as possible” including accommodation for older people, which on first impressions seems positive.  However, it is a suggestion rather than a requirement and outlines no strategy for how this might be achieved.  Indeed, if the Government are truly serious about delivering a greater quantity and choice of housing for older people, it is considered a more proactive approach might have been to require site allocations and/or a range of units to be delivered in an area as suggested (but again not required) in the NPPG.  Some have suggested certain sites should be required to deliver a specific percentage of housing for older people.  Although given retirement and care schemes must be of a certain size to be financially viable, this is only likely to be applicable to large sites and in our view will prove challenging to deliver in practice when taking into account other site-specific requirements such as affordable housing and overall viability.

Perhaps the Government anticipated that, through a purported increase in housing more generally brought about as a consequence of other changes to the NPPF, an increased quantum of housing for older people would in turn be delivered.  However, from the numerous articles released on the topic, it is evident that many in the industry are sceptical that this will be the case.  See Nexus’ thoughts on this outlined in our blog “National Planning Policy Framework December 2023 – Some (Potential!) Implications” released earlier this year.

Paragraph 63 of the updated NPPF also sets out different types of housing for older people – namely “retirement housing, housing-with-care and care homes”.  However, whilst further clarity over the different types of accommodation may have a slight impact in terms of raising awareness of the different forms of accommodation available, definitions are already set out in the NPPG with neither document using the most up-to-date terminology in any event.  The inclusion of these terms within the NPPF also does nothing to proactively address the “critical” need for more, and better quality and choice, of accommodation.

Overall, the updated NPPF is considered a missed opportunity for the sector.  However, the planning system is currently in uncertain times with a stream of planning policy and legislative updates (including the updated NPPF) having been recently released and a general election expected later in the year.  If the current polls are to be believed, we are likely to see a new Labour Government in place by the end of 2024.  They recently pledged to take “decisive and early action” to reverse the changes set out in the Updated NPPF, which given the changes relating to housing for older people lack any real substance is likely to have limited impact on the sector.  However, it provides a valuable opportunity for the sector to lobby for changes that could form part of any future NPPF updates and/or new planning policy or legislation.  It will therefore be interesting to see the recommendations of the Housing for Older Person’s Taskforce to the Department for Levelling Up Housing and Communities due later this year.

If you would like to discuss any of the above in more detail and/or explore how Nexus Planning may be able to assist you with your retirement or care project, please do get in touch

 

Authored by

Sarah Roe, Associate Director