Shortly before Christmas the Government issued a consultation on its proposed approach to reforming national planning policies, to complement the Levelling Up and Regeneration Bill which is currently making its way through Parliament. They also published a draft of what the revised National Planning Policy Framework (NPPF) might look like. The consultation is open until 2 March 2023.
The current NPPF, which informs how local planning policies approach their plan-making duties and is a material consideration in the determination of planning applications, makes little more than a passing reference to housing for older people. It requires the context, type and tenure of housing needed for various groups, of which older people are one, to be assessed and reflected in policies. It is good news, therefore, that the introductory text in the relevant section of the consultation paper boldly states that “The government is committed to creating a planning system that focuses not simply on housing numbers, but on delivering the types of homes that communities want and need. That means a diverse range of homes, more genuinely affordable housing and specific provision for older people”. The consultation paper goes on to reference ensuring 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. It confirms that the government has been considering ways in which the Framework can further support the supply of older people’s housing. It specifically references the recently published and ARCO funded Mayhew Review on Future-Proofing Retirement Living.
If we turn to the indicative draft of what the revised NPPF may look like, however, it is easy to be disappointed that the update appears limited to adding into the existing requirement to assess the needs of various groups a simple reference to “including for retirement housing, housing-with-care and care homes”. There is no further explanation or definition as to what these types of housing entail, no reference to integrated retirement communities, and no specific policy actively requiring local plans to actually include a policy relating to housing for older people (which could seemingly easily slot into paragraph 20). It is widely recognised that as things stand many local planning authorities have no policies at all dealing with housing for older people, and the planning system is routinely blamed as one of the top barriers to the provision of more retirement housing.
Does this current consultation present a missed opportunity? The Plan-Making chapter contains a potential amendment to state that plans should provide a framework for “meeting” housing needs, rather than the somewhat more vague ‘addressing’ housing needs as is currently the case, so there is perhaps a stronger expectation that if a need is assessed then it needs to be provided for. When read against other proposed updates, however, such as the strengthening of the green belt and the proposed ability to take into account previous over-supply in considering housing figures, it does feel like considerably more could be made of this opportunity to make retirement living a central part of planning policy. Whilst NPPF amendments alone won’t present a quick fix to the planning barrier, now is the time to have your say!
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