Mission Critical - New planning guidance ramps up the importance of delivery of housing for older people

09 Jul 19

Mission Critical – New planning guidance ramps up the importance of delivery of housing for older people


Wednesday of last week saw National Planning Policy Guidance (NPPG) updated with a new housing for older and disabled people section. This guidance provides encouragement for developers of third age living schemes in the form of a change in rhetoric from the Government and is broadly welcomed, although it still falls short of the radical steps required in some areas.

Critical delivery

The Government considers the need to deliver housing for older people is now ‘critical’. That is the big headline from this guidance. No other specific form of development is referred to as ‘critical’ in either the NPPG or National Planning Policy Framework (NPPF) and while this does not automatically propel the delivery of this form of development above all others in terms of importance, it does significantly ratchet up the rhetoric.

The NPPF states that local plans should meet the specific identified needs of older people. The huge level of unmet need for this type of development across the country should have meant that ensuring delivery of sufficient Third Age Living accommodation is a key component of the Local Plan process, but this has often been deficient in practice. Too often it has been assumed that the market will step up with no intervention required, and the result has been levels of delivery that are a fraction of what is needed. Moreover, choice on a range of accommodation and care options also remains sadly lacking. This guidance is explicit about the importance attached to meeting this need going forward.

Exactly how a sufficient supply of sites is brought forward is left to local authorities. The guidance suggests allocations as one way of ensuring needs are met and this is a good first step. Our view is that allocations will frequently be required to ensure sufficient supply, given that the Third Age Living sector does not operate on a level playing field with general market housing providers when purchasing sites. The key will be to ensure that there is early engagement with landowners, promoters, planners and social care specialists in the Local Plan process, rather than trying to retrofit the policy at a later date. Specific allocations could have implications for landowners, and expectations may need to be controlled. Equally, Third Age Living can cover a multitude of accommodation types, from lifestyle based products to operational care. Too generic an allocation could result in the over provision of a particular type, to the detriment of meeting overall housing needs.

Ultimately the success of this in the Local Plan process will depend on developers and promoters scrutinising Local Plans to ensure that the sector is not overlooked and to proper engagement with local authorities and communities. The opportunistic nature of site finding for the sector and the fragmented market means this has not always been the case previously. We are hopeful that the growth of investment in the sector means that more developers will become positively involved in the process.

Planning applications

Of course a very large number of applications for Third Age Living development comes through speculative applications where no development plan allocation exists for the proposed use. The guidance instructs decision makers to take a positive approach to schemes that meet an unmet identified need; one would hope that local authorities were already taking such an approach, but having it clearly stated is helpful. The guidance is rather vague on what a need might actually constitute – for example, there is often a qualitative need to replace existing outdated or unsuitable accommodation, as well as a quantitative one. Our view is that both forms of need should be met, but the lack of an explicit sentence on this could cause issues during the decision making process.

Assessing Need

The guidance helpfully defines different types of specialist housing for ‘older people’, and this can now be used to provide a clear and consistent basis for assessing needs. However what the guidance says about how needs should be assessed is quite limited, and it would have been helpful to have more specific guidance in order to improve the quality and consistency of need studies. Existing tools can show a need which is influenced significantly by existing provision which can risk creating issues of circularity – where low existing supply of specialist housing – or particular types of specialist housing – influences what is needed in the future. We would advocate a more sophisticated approach – one which appraises and benchmarks existing supply, considers the relevant commissioning strategy for Third Age Living accommodation, as well as wider socio-economic characteristics to assess whether there is an existing supply/demand imbalance, and in appraising what prevalence rates should be applied in modelling future needs.

Use class and viability

The section on seeking to clarify the C2/C3 debate appears to be kicking the can down the road. Currently one of the biggest delays in the application process is over affordable housing provision. This is either in the form of debating which use class the development should be classified, or over the scale (if any) of an appropriate and viable off-site contribution. With more far reaching reforms within the use class order required to assist with the former issue, we would encourage local authorities to consider the starkly different viability characteristics of this sector to general market housing in their Local Plan evidence base. A separate carve out affordable housing policy for Third Age Living can then be considered, which would provide significantly higher levels of certainty for developers and landowners.


The guidance also contains some direction on design requirements for new developments for this group as well as accessibility objectives for places which is welcomed. The emphasis on dementia friendly design is helpful, as is the requirement for specific types of accommodation to meet their individual needs.

Overall, the guidance represents a step forward for the sector, but needs full engagement from developers, promoters and local authorities to succeed. The industry will be hopeful that it can be a springboard for more radical policy going forward.

To discuss Third Age Living, please contact;
Jamie Sullivan – jsullivan@iceniprojects.com – Sector lead – Third Age Living,
Nick Ireland – nireland@iceniprojects.com in relation to Needs Assessments and;
Olivia Holt – oholt@iceniprojects.com for Viability advice.