With thanks to Ben Pope, Associate Director, and Zoe Curran (pictured), Planner, Boyer (part of Leaders Romans Group), for sharing their insight with Care Sector Hub…
The need for more care homes
We are all only too aware of the desperate need for more care homes: the fact that 2.6 million older people in England unable to get the support they need and that record NHS waiting lists are partly attributable to the 13,000 people in hospital simply because they are waiting for social care.
What is needed
The desperate need for purpose-built facilities, in suitable locations, set in suitably landscaped, tranquil surrounding and with high quality facilities including accessible layouts and wet rooms is not being met, and the conversions of other buildings which are being provided to fill the gap, fail to meet the required quality standards.
This is largely due to the inability of the planning system to supply the requisite number of both care homes and retirement living schemes.
National planning policy: good intentions but difficulties in implementation
There should be some hope: the National Planning Policy Framework (NPPF), the policy document which forms the basis of our planning system, has been revised and, following a stakeholder consultation, the extent to which these revisions will take effect is expected to be announced in the autumn.
The proposed changes appear to recognise that the planning system is partially responsible for the current under-supply of care homes. In Chapter 5: ‘Delivering a sufficient supply of homes’, it adds to existing guidance (that, ‘the need, the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies,’): ‘including for retirement housing, housing-with-care and care homes’.
This amendment seems well meant and may result in Local Plans (the documents which determine strategic planning at a local level) being better informed of 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. As a consequence, if the proposed revisions to the NPPF are adopted, it could result in a significant reduction in the release of land for development and this will impact significantly on the future development of specialist older people’s housing and care homes.
A policy vacuum at a local level
A central problem is that the majority of local authorities do not have a policy which recognises the need for care homes. Many local authorities address the issue in an annual monitoring report but not in sufficient depth. So more commonly, thorough need assessments are being carried out by the private sector in relation to specific developments rather than need having been identified and allocations made accordingly. Thus most local authorities’ consideration of need fails to take demographics into account and consequently is out of date.
We would like to see the NPPF amended to include a clear direction that through local plan review, planning authorities are required to undertake an objective and robust identification and understanding 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 should then allocate sufficient numbers of sites, in the right locations, based on their specific assessment of need. Presently where local plans do include allocations for a care home or specialist housing, it is usually within a much larger strategic site allocation. Local plans should also allocate sites specifically for later living / care which meet the locational needs of the occupants, not solely as an add-on to an existing new development.
Furthermore, local plans should continue to include at least one policy supporting the delivery of new older persons’ homes – across all typologies. It’s important the planning system remains plan-led. But it must not become plan-absolute led. Local plans cover periods of a minimum 15-years. Changing economic, social and demographic circumstances rarely have regard for the duration of plan-making, plan lifespan and review cycles. It is important that planning policy, national and local, provides for speculative application secured developments – when the needs are demonstrated.
The prioritisation of sustainable and brownfield sites
One of the major changes in the revised NPPF is removal of the requirement to review Green Belt if this is the only means by which to meet minimum housing needs. Instead, the revised version – compounded by recent policy announcements – reiterates the importance of ‘brownfield first’.
There are many local planning authorities with very little available brownfield land and substantial areas of Green Belt. In these circumstances the policy changes will have a considerable and negative impact on the delivery of later living homes and care facilities.
There is also a new emphasis on ‘gentle density’, to be achieved through building upwards. But while loft conversions and the addition of mansard window may work for many homeowners, the policy of higher densities will place a further barrier to promoters and developers of older people’s homes. Competition for limited land opportunities on greenfield will invariably increase.
Furthermore, the absence of relevant policies in the Local Plan, or specific allocations in local plans often results in development only being possible through ‘windfall’ (ie, left-over) sites – which, again, tend to be in unsuitable urban locations.
Clearly not all older people’s accommodation is suited to delivery within existing urban areas. To meet amounts required, planning must re revised. For example, integrated retirement communities typically include high levels of open spaces and on-site amenity space. Consequently densities are lower than a typical housing development and profit margins are lower. This means that operators and promoters of such schemes often find themselves taking marginal sites which are less attractive to the volume housebuilders.
The most suitable sites for care homes and retirement villages tend to be on the edge of settlements. This includes former agricultural land and or undeveloped sites. But many lie within the Green Belt – and increasingly policies, which disincentivise Green Belt release result in these sites evaporating.
The need for quieter, greener locations
And the fact is that few care homes need to be located in urban areas. For retirement homes targeted at those as young as 55, there are benefits to being located in the heart of a community – close to shops and other amenities, and with good access to public transport. But care homes do not generally require a central location: most are better suited to quieter, semi-rural sites, with greater potential for open spaces and attractive views in place of amenities.
The revised NPPF states and intention to increase the supply of care homes. But the unfortunate consequence of the proposals could be that delivery of older people’s accommodation and homes will be hindered, rather than ‘significantly increased’ as a result of the revisions.
Making a case for greenfield development
In practice, we find that 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, the case in favour of a care home always benefits from solid environmental credentials – for example, achieving greater energy efficiency through use of ground or air source heat pumps, and providing over the requisite requirement of biodiversity net gain. Following the Environment Act 2022, from November 2023, all new developments will be required to provide at least 10% 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. Biodiversity need not be determined by the square footage of green land, so much as the ability for various species to flourish there. While most local authorities currently look set to require a minimum 10% biodiversity net gain, if a planning application can demonstrate the ability to deliver 20% or 30%, its potential for success will increase.
There is also an increased likelihood of a scheme gaining local authority support if is non-speculative: if a care home operator is ready and waiting to the scheme, planning consent is more likely.
The potential of Build to Rent (BTR) schemes to deliver care homes
An alternative route to success is the potential amalgamation of a care home into a larger, mixed use scheme. BTR suburban communities, developments of family homes, located outside urban areas, have seen unprecedented and unrelenting success over the last few years. This is undoubtedly (in part at least) due to the ability of such schemes to attract a diverse demographic. BTR suburban communities grew out of an opportunity to meet the changing needs of BTR’s original target market: providing homes for maturing Millennials as they embarked on family life outside London, but has extended beyond that, providing homes for those at all stages of life.
A typical BTR suburban community creates the ideal opportunity for multi-generational living: accommodating several generations of a family and thereby a diverse community, benefitting both the community itself and the scheme’s profitability. Of course this is not a new phenomenon, as the history of any village will show. But the benefits of creating new communities with this in mind, literally providing for ‘cradle to grave’ are increasingly being recognised, and favoured in planning policy.
BTR suburban communities have the potential to provide both retirement homes and care homes. Renting is all too often viewed as the default option for those unable to get a foot on the property ladder. But it is increasing becoming popular with those stepping off the property ladder. House price inflation has been generous to the baby boomers and, acknowledging this, increasing numbers now choose to release equity to support children and grandchildren into home ownership. Divesting equity and moving into a rented property with a BTR suburban community not only enables parents and grandparents to pass on property profits and reduce inheritance tax, but to live in a suitable home with the flexibility to move to assisted living within the same scheme should their needs change.
There are numerous successful later living schemes in European and the US which combine both retirement housing and care. A mixed use development of rental properties in Aarhus, Denmark, has addressed the problem very successfully: the House of Generations is an innovative intergenerational living housing project that demonstrates that there is a solution to the crisis in social care while also boosting the supply of affordable housing and delivering high quality pre-school education. The scheme 
has 100 retirement homes, where residents have daily visits from a care worker; 100 nursing home places, which come with more intensive medical support; 40 family homes, 40 youth flats and 24 apartments for disabled people. A ‘pepper-potting’ approach ensures a demographic mix and the scheme has many shared facilities including gardens, a nursery, a craft room, a carpentry workshop, a music studio and a gym. The scheme shows that intergenerational living has benefits all-round: to residents, managers, investors, and society at large.
Conclusion
The are a number of issues with the planning system which act as a brake on the delivery of both retirement housing and care homes.
We welcome the revised focus within the NPPF of improving the diversity and supply of homes and facilities for older people. But as explained above, there are substantial issues which will first need to be addressed.
The reality is that the collective changes being proposed are set to hinder the delivery of older people’s accommodation. There are many gaps which the updated guidance fails to address, such as a general lack of promotion of the delivery of specialist accommodation.
It is anticipated that the number of the population aged over 65 will account for almost a quarter of the population by 2043. Significant changes will be needed to turnaround the drastic undersupply of purpose-built housing and care homes.
The care home sector needs to speak out on these issues and encourage politicians to review existing planning legislation to the benefit of the sector.
There is some good news – investors and developers are ready and waiting: Knight Frank’s Seniors Housing Annual Review 2022/23 states that 67% residential investors plan to enter this market within the next five years, compared to 31% currently. Now, with the Levelling Up and Regeneration Bill going through Parliament and the NPPF awaiting further revisions, is the ideal time to influence planning policy and resolve this increasing concerning social problem.
