Care Home Management

The Care Home Decision Makers’ Magazine

Insight & Analysis

Planning for older age

Significant changes in planning are needed to turnaround the drastic undersupply of purpose-built housing for the elderly and care homes.
By Ben Pope, associate director, planning and development company Boyer

With so much unmet need, current planning system is unable to supply the requisite number of care homes and retirement living schemes.

The National Planning Policy Framework (NPPF), the policy document which forms the basis of our planning system, was revised in December 2023. This included several changes in relation to housing need and housing delivery.

These appear to recognise that the planning system is partially responsible for the current undersupply of care homes. In Chapter 5: ‘Delivering a sufficient supply of homes’, a new specific reference to housing with care and care homes states: “The need, the size, type and tenure of housing needed for different
groups in the community should be assessed and reflected in planning policies.”

This amendment seems well meant and may result in a local plan (the document which determines strategic planning at a local level) that pays better attention to the care needs of older people.
However, the change in policy followed November’s rebellion by anti-development backbench Tory MPs who were opposed to top-down housing targets and development on greenfield land.

This has resulted in guidance that significantly reduces the amount of land released for development. This will impact significantly on the future development of new housing as well as for specialist older people’s housing and care homes.

Mind the gap: the local policy vacuum

A central problem is that most local authorities do not have a specific policy which recognises the need for care homes.

Many local authorities address the issue in an annual monitoring report but this generally lacks sufficient depth. This leaves the private sector to carry out a need assessment – but typically, only in relation to their specific development. Thus, need is not recognised holistically, and without due or up-to-date recognition of local demographics.

In an ideal world, the NPPF would be amended to include a clear direction that, through local plan review, local planning authorities should undertake an objective and robust review of current and forecast needs across the new plan’s period (typically 15 years), drilling down into the type of care needed (both general and specialist).

Local plans would then be able to allocate sufficient numbers of sites, and types of housing for older people in the right locations, according to the local need.

It’s important the planning system remains plan-led but it must not become blind to changing economic, social and demographic circumstances. Typically, local plans cover periods of a minimum of 15 years so good planning policy should be open to speculative applications when need is demonstrated.

Brown or green?

The revised NPPF reiterates the importance of ‘brownfield first’ and removes the need for local authorities to review Green Belt if this is the only means by which to meet minimum housing needs. There is also a new emphasis on ‘gentle density’, to be achieved through building upwards (loft conversions, etc).

Policy which disincentivises Green Belt release, particularly in authorities with very little brownfield sites, will result in strong competition for the available sites.

This is particularly concerning for care home developers, where the most suitable sites for care homes and retirement villages tend to be on the edge of settlements, and typically, on former agricultural land and or undeveloped sites.

Many sites can lie within the actual Green Belt – indeed, care homes are better suited to quieter, semi-rural sites, with greater potential for open spaces and attractive views in place of amenities.
The danger is that in the absence of a specific allocation, new care home developers are left only with ‘windfall’ (left over) sites for development, which can tend to be in unsuitable (urban) locations for a care home. It’s a possibility that, despite the intention to increase older people’s accommodation, the revised NPPF will encourage the opposite to happen.

Making a case for greenfield development

Gaining planning consent for a development on greenfield land is dependent on the benefits that the scheme brings. Aside from the obvious social benefits of addressing need and providing suitable facilities, solid environmental credentials are crucial: greater energy efficiency through use of ground or air source heat pumps, and biodiversity net gain. 

As per the Environment Act 2022, from February 2024, all new developments will be required to provide at least 10 per cent higher levels of biodiversity than existed on the site prior to development. While seemingly challenging for a scheme built on greenfield land, this can be achieved through many means, not solely gardens and green spaces but also green roofs, green walls and window boxes.

Build to Rent

An alternative route to planning success is to build a care home within a larger, mixed-use scheme. Build to Rent suburban communities – developments of family homes, located outside urban areas – have seen unprecedented and continued success over the past few years, due to the ability of such schemes to attract a diverse demographic.

BTR suburban communities grew out of an opportunity to provide homes for maturing millennials as they embarked on family life outside London. However, typically, they now accommodate multi-generational living – a ‘cradle to grave’ approach – that appeals to baby-boomers who wish to release equity in their own homes by moving into a rented property to support children and grandchildren into home ownership.

There are numerous successful later living schemes in Europe and the US which combine both retirement housing and care.
The House of Generations intergenerational living housing project, in Aarhus, Denmark, combines retirement homes, with domiciliary care as required, nursing home places, as well as family homes and youth flats. The good news is that investors and developers
are ready and waiting for the UK market to catch up with this concept: Knight Frank’s Seniors Housing Annual Review 2022/23 states that 67 per cent residential investors plan to enter this market within the next five years, compared to the current 31 per cent.


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