The new chapter to the NPPG helpfully states that LPAs:
- should set clear policies to address the housing needs of older people and ensure that their Plans provide for specialist housing for older people where a need exists;
- need to count housing provided for older people against their housing requirement;
- should take a positive approach to schemes that propose to address an identified unmet need for specialist housing.
However, it leaves a lot to the discretion of a LPA, including what use class this type of specialist housing falls into and whether affordable housing may be required alongside housing for the elderly, subject to viability.
Despite including a summary of four different types of specialist housing for older people, the guidance purposely shies away from answering the often contentious and critical question, because of policy wording, of whether a development for specialist housing for older people falls within C2 (Residential Institutions) or C3 (Dwellinghouse) of the Use Classes Order. Instead of stating that a LPA should look to current precedents for guidance, the new NPPG chapter acts to undermine it by stating that:
- the use class a particular development falls within may depend on the level of care and scale of communal facilities provided (at paragraph 14); and
- extra care housing usually has "a medium to high level of care available if required" (at paragraph 10).
Some other weaknesses in the guidance are that it says LPAs could (as opposed to should):
- provide indicative figures for the number of units of specialist housing needed for the plan period, but makes clear (paragraph 12) that Plans need to provide for specialist housing for older people where a need exists;
- monitor the provision of housing for older people;
- allocate sites for specialist housing for older people.
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