Can Planning help to solve the social care crisis?

While life expectancy in the UK continues to increase, health expectancy has not kept pace, and the likelihood is that most of us will experience a number of years when we are not in full health and require a degree of care and support.  Age UK estimate that 1.5 million people aged 65+ do not currently receive the care and support they need with essential living activities.  With the number of people aged over 75 set to double in the next 30 years, it is easy to see why we are facing a crisis in Social Care.  In simple terms, we are not building enough of the right types of homes for older people and the gap between supply and demand is constantly widening.

Within the UK, we tend to want to stay in our family homes as we get older, and often wait for a trigger event such as a medical incident or bereavement, before considering moving to housing that better suits our needs.  As we age, our needs change – older people often need more help with maintenance and may require social care to help maintain their independence.  Social networks become ever more important in reducing loneliness, as we saw so starkly during the Covid lockdowns of 2020 and 2021.

Against this backdrop, it is clear that there is an increasingly important role for housing and care options that bridge the gap between care homes and people receiving care in homes that no longer suit their needs - from Retirement Villages and Sheltered Housing to Assisted Living and Extra-Care Housing.

But why is tailored accommodation so important?

Accommodation tailored to the support and care needs of the individual lessens the burden on the NHS by keeping older people out of hospital for longer.  When an older person moves into specialist housing, they typically move out of a larger house, and their transition into new accommodation releases family housing back into the market. The knock-on effect can consequently contribute towards fixing the wider the housing crisis too. 

However, there is a huge shortage of tailored accommodation and housing across the UK in both the private and social sectors.  We need to significantly increase the provision of accommodation that enables older people to live independently for as long as possible, with the option of accessing on-site care as and when this is required. 

The NPPF recognises this, requiring consideration to be given to the needs of different groups in the community, including older people, and the Planning Practice Guidance (PPG) describes the need to provide housing for older people as ‘critical’.  But while the PPG requires plan-making authorities to set clear policies to address the housing needs of groups with particular needs, such as older people, there is no requirement to provide details of the numbers of specialist housing units needed across the plan area, nor to identify suitable locations to meet this need.  Indeed, the Practice Guide says that it is up to the plan-making body to decide whether to allocate sites for specialist housing for older people.

Varying approaches of Local Authorities:

Within Norfolk, a county where the opportunities for coastal living attracts older people, and where consequently a quarter of the population are 65+ (compared to a national average of 18.5%), the emerging Greater Norwich Local Plan identifies a significant need for housing to meet the needs of older people - 3,857 specialist retirement units between 2020 and 2038. 

To address this, the plan includes 5 site allocations with an element of specialist housing in the policy, providing just 380 units – less than 10% of the need identified in the Plan period.  While the Plan does support and, indeed, encourage the provision of older people’s accommodation, it provides no requirement or incentive for a scheme to do so.  The strategy for meeting 90% of the identified need for older people’s specialist accommodation is consequently reliant on developers and providers pro-actively seeking to bring forward schemes, effectively hoping that the market will be sufficient to drive forward developments of this nature. 

To date, the evidence suggests that this is not happening, certainly not in sufficient quantity to plug the gap in provision.  Without a clear strategy for provision, there is a danger that the right accommodation will not be provided in the right places – often people are keen to stay local, within their communities where they have established social networks, and familiarity of surroundings is particularly important for people in the early stages of dementia.

A similar approach is found in Breckland Council’s Local Plan, which was Adopted at the end of 2019.  Breckland identified a need for 1,277 additional C2 bed spaces to be provided during the Plan period, and also recognised that there is a growing need for alternative models of older people’s housing, but only made one allocation for a 60-bed care home.  Beyond this, the approach is one of ‘support’ and ‘encouragement’ but no attempt to pro-actively plan to meet the demand for older people’s housing. 

By contrast, North Norfolk District’s emerging Local Plan takes a very different approach to provision of housing that meets the needs of its growing elderly population.  The First Draft Local Plan, published in 2019, includes a policy requiring all developments of over 150 dwellings to provide, as a minimum, 80 bed spaces of specialist elderly housing or care provision.  For developments of 301 or more dwellings, 120 bed spaces are required, with a further 40 bed spaces for each additional 150 dwellings thereafter. 

Whether this approach will remain unchanged in the imminent Regulation 19 publication remains to be seen, as criticism have been levelled at an alleged lack of evidence to underpin the strategy.  If it can be justified, this strategy certainly seems to offer a much greater likelihood of increasing the supply of Older People’s Housing in the District.  Perhaps this is a reflection of the fact that with the highest median age in the UK at 54.7, and the highest proportion of people aged 65 and over (33.2%), the needs of older people are higher up NNDC’s agenda.

What other difficulties are we facing?

Another obstacle that is frequently encountered when seeking planning consent for specialist Older People’s Housing, is the lack of consistency in how it is classified within the Use Classes.  While traditional Care Homes fall neatly into Class C2 (Residential Institutions), proposals that involve housing with support and care of varying degrees are not clearly defined, and there is a great deal of variation in how Local Planning Authorities classify such proposals.  The Practice Guide (para 014) attempted to provide further clarity on this topic, but failed miserably, simply stating that, “It is for a local planning authority to consider into which use class a particular development may fall” and “consideration could, for example, be given to the level of care and scale of communal facilities provided”.

This leaves Planning Authorities with little on which to base their judgements about how to deal with proposals for specialist housing that doesn’t fit squarely into the definition of a Residential Institution. 

We have experienced a wide divergence in approach between Local Authorities, and even between Officers within the same Local Authority, and the implications are potentially significant.  Often, policies requiring s106 contributions and affordable housing contributions, as well as CIL liability, do not apply to C2 development, whereas they do to C3.  This leads to uncertainty, and a disincentive to provide housing with care schemes that are deemed to be C3.  As a result, industry leaders, have called for the creation of a separate use class for housing with care, or alternatively for much clearer guidance on the circumstances that would render a housing with care scheme a C2 use.  Whilst some Local Authorities have begun to take this on board in our experience this is very much the exception rather than the rule.

Conclusion

Our Social Care system is deep in crisis, and whilst it is reassuring that the Government appear to be focussing their attention on addressing some of the complex issues responsible, the Planning System can certainly do more to play its part.

There is a very clear role for specialist Older People’s Housing that bridges the gap between care homes and people receiving care in homes that no longer suit their needs, but much more needs to be done to incentivise development of this type. 

More thought needs to be given to strategic planning for these forms of specialist housing – allocating sites and providing more than just ‘encouragement’.  Supply and demand need to be monitored and reported more closely going forward. More clarity is also needed around the classification of different formats of specialist accommodation, to remove uncertainty and provide a level playing field across the country.