The population of the UK is aging and the need to provide appropriate and accessible housing for older people is coming into sharp focus. Between 2016 and 2041, the number of people living in the UK aged 85 and over is expected to double to 3.2 million, giving rise to a potentially huge shortfall in accessible senior living accommodation. This shortfall is exacerbated by what is referred to as a postcode lottery. A Forecast for Accessible Homes, a study by Habinteg, found that by 2030, there will be 1 accessible home for every 270 people in the West Midlands, 1 for every 52 people in the East of England and 1 for every 24 people in London.

In recognition of this crisis, the Ministry of Housing, Communities and Local Government has published a timely piece of guidance on housing for older and disabled people.

National policy defines older people as those "people over or approaching retirement age, including the active, newly-retired through to the very frail elderly; and whose housing needs can encompass accessible, adaptable general needs housing through to the full range of retirement and specialised housing for those with support or care needs." Similarly, it defines people with disabilities as those "who have a physical or mental impairment, and that impairment has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities. These persons include, but are not limited to, people with ambulatory difficulties, blindness, learning difficulties, autism and mental health needs." Clearly, the scope of these definitions is very wide and encompasses an already large percentage of the population, so the importance of this guidance cannot be understated.

While the guidance largely serves as a refresher of existing policy, the consolidation of previously fragmented guidance on senior and assisted living is to be welcomed by developers and operators in this increasingly important space; particularly as it requires relevant bodies to plan positively for sufficient and relevant provision in development plans, and this need is a material consideration in the grant of planning permission.

The guidance encourages plan-making authorities to create policies which:

  • set out how proposals will be considered for different types of housing requirement;
  • determine whether to allocate sites for specialist housing for older people where an identified need exists;
  • identify the role that general housing can play to alleviate senior housing need where adaptations aren't required, such as bungalows;
  • set out the contributions expected from other types of development towards senior or assisted living;
  • set out the levels and types of affordable housing provision required – specific to senior or assisted living; and
  • consider the location and viability of a development when assessing planning applications for specialist housing.

Perhaps of most interest to developers is the specific acknowledgement in policy terms that local planning authorities should count housing provided for older people against their overall housing requirements. It is not clear whether general housing policies in emerging local plans will, in time, be drafted so as to apply to senior living accommodation – though such a move could be beneficial in ensuring that an appropriate mix of housing is generated. The timing of this guidance will please the likes of Sir Oliver Letwin who, appointed by the government to look at increasing building numbers, champions the idea of greater housing diversity to increase absorption rates of housing into the market.

While the emergence of consolidated guidance is welcome news, the guidance itself lacks detail on viability issues, affordable housing provision for senior or assisted living and it gives no detail on the types of developer contributions that might be expected. It also gives a very limited range of examples of the types of innovative housing models that might be acceptable in policy terms. It also offers little guidance on the quandary that is how to determine the appropriate land-use class for senior living – developers and local authorities will still need to decide whether the level of care provided requires consent under C2 (residential institutions) rather than C3 (dwellinghouse).

It is highly likely that we will see more policy and guidance on senior living in the months and years to come, given the importance of this subject in the context of an aging population. Planning policy, both current and emerging, needs to reflect the growing demand for senior living accommodation and encourage innovative solutions to new and diverse housing models.

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