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Planning trends: Extra Care Development

Better use of Strategic Housing Market Assessments by local authorities to establish the needs of older people in their area will make speculative planning applications for C2 residential institutional development increasingly challenging, says Alder King planning partner Matthew Halstead.


The number of people aged over 65 in the UK is forecast to rise over the next decade from 11.7 million people to 14.3 million, a 22% increase. This means that one in five of the total population will be over 65 in 10 years’ time, which will become one in four by 2050.

In the UK the vast majority of over 65s live in mainstream housing.  Only 0.6% of over 65s live in housing with some form of care provision. The suitability of housing stock is of critical importance to the health of individuals and also impacts on the demand for public spending, particularly social care and the NHS.

There is an increasing trend of retirees seeking to ‘rightsize’, in order to live in residential accommodation that meets their needs in later life, and which provides some form of care. However, there is a chronic shortage of high quality and affordable accommodation to meet this growing need, in particular that which provides extra care in the C2: Residential Institution use class (C2 development).

It is well engrained in planning policy that a mix of development should be provided that meets the needs of all sectors of society. The National Planning Policy Framework (NPPF) requires local planning authorities (LPAs) to undertake Strategic Housing Market Assessments (SHMAs) to establish the full housing requirements for their area, with this assessment having to take account of the needs of ‘older people’.

In our experience, when discharging this requirement of the NPPF, LPAs have sought to address the needs of older people through retirement accommodation only, as a component of mainstream housing supply. However, further to the publication of the National Planning Practice Guidance, LPAs are now also required to set out the level of need for C2: Residential Institutions.

To date, many LPAs have failed to grapple with the need to plan for C2 development. This has paved the way for applications for extra care development to be successfully negotiated through the planning system, structured upon independent assessments of C2 development need. Given the growing demographic of older people, LPAs have found it difficult to resist such evidence, with speculative applications being granted permission on the basis of the development plan being silent on how it will meet the need for C2 development.

However, some LPAs are now addressing C2 development need, with SHMAs identifying residential institutions as a separate component of supply. Given the on-going pressure to meet C2 development need, it is expected that LPA’s evidence on this issue will become far more robust.

The direction of travel is moving towards target driven policies to satisfy the growing need for C2 development. Further, it is anticipated that when formulating such policies, greater attention will be placed on viability testing of C2 development. The likely outcome of this would be the requirement for C2 development to provide an element of affordable accommodation, a policy objective that has traditionally been directed at mainstream open market housing only.

With the development needs of an ageing population being cast in sharper relief, it is envisaged that speculative applications for C2 development will become more challenging to progress. It will therefore be vital for applicants to ensure that their proposals are supported by a wide gamut of up to date evidence.

In addition to traditional evidence of C2 development need based upon ONS data, it will become increasingly important to engage with key stakeholders such as the NHS, charities and extra care providers to help explain the issue of need. Further, sequential assessments of site availability should also be undertaken of the target area. The combined outcome of these activities is to demonstrate that the level of C2 need is greater than that envisaged by the LPA, and in turn that there is a shortfall of deliverable sites to meet the additional requirements. The case can then be presented that the application site would help address the identified deficit.

Matthew Halstead acts for a wide range of commercial and residential clients. He recently secured planning permission for an 86 bed extra care scheme on an unallocated green field site in Fareham. The scheme is now being built out.

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