Planning
(Delivering a Sufficient Supply of Homes) remains largely unchanged in its approach to housing for senior members of society. Meanwhile, the government’s broader intent on accelerating housebuilding has led to a noteworthy modification: intentions to release land, particularly sustainable Green Belt sites on the inner edge of towns and cities.
While these modifications are welcomed, national planning policy should also aim to require local planning authorities (LPAs) to make provision for the delivery of LLH within Development Plans, which should be informed by relevant and up-to-date evidence specifically relating to older persons’ housing need.
The answer lies partly in brownfield sites Along with a need to increase development on the Green Belt, the government is also paying attention to brownfield sites – both greenfield and brownfield are necessary to meet the ambitious housing targets and address need. The updated NPPF strengthens the presumption in favour of sustainable development on brownfield sites through amendments to paragraph 125(c), which gives substantial weight to the value of suitable brownfield land within settlements for homes (along with other identified needs) and sets out that proposals for this type of development should be approved unless substantial harm would be caused. Maximising the potential of formerly developed plots, which are often well-connected by public transport and established infrastructure, should be a preference in tackling the housing crisis. However, the push for higher densities
on brownfield land offers additional hurdles for later living developers. Competition for these restricted sites, many of which are well-suited to specialist housing, will only intensify, making it even harder to secure appropriate locations.
The need for further planning reform is undeniable
It is also important to note that not all LLH fits within high-density urban spaces. Integrated Retirement Communities (IRCs), for instance, require significant onsite amenities, recreational areas and care facilities. In most cases, this results in lower housing densities than standard residential developments. Consequently, IRC operators frequently turn to marginal sites that mainstream housebuilders overlook, including settlement edges, former agricultural land and undeveloped Green Belt zones.
Presumption in favour of sustainable development The revised NPPF places greater emphasis on approving development where local plans are outdated, while reinforcing policies that uphold quality and sustainability. This shift could form a clearer pathway for presenting well- positioned, high-quality LLH in regions facing housing shortages. Specifically, the potential for
development on the Green Belt is increased. Recent modifications permit limited infill or redevelopment of previously developed land under specific conditions. This has the potential to open the door for LLH in underutilised urban-fringe spots while safeguarding the Green Belt’s ‘openness’.
The introduction of the Grey Belt The provisions of paragraph 155 of the updated NPPF allow for housing development in the Green Belt where it would utilise the newly defined ‘grey belt’ land and would not fundamentally undermine the purposes of the remaining
Green Belt across the local plan area; where there is a demonstrable unmet need for the type of development proposed; the development would be in a sustainable location, and where the proposals would meet the ‘Golden Rules’ for development. These ‘Golden Rules’ also require the
provision of affordable housing 15 per cent above local policy levels, the provision of necessary improvements to local or national infrastructure, as well as the provision of new – or improvements to existing – green spaces that are accessible to the public. These updates could significantly increase the opportunities for later living development on grey belt land. However, in reference to the barriers currently being faced by the later living sector in delivering LLH, the Older Person’s Taskforce noted that there are currently very few sites allocated for LLH, and appropriate sites can be hard for providers to identify. Applications are being pursued in the Green Belt or unallocated greenfield land and constrained brownfield land, which involve higher development costs for developers. The Older Person’s Taskforce stresses the importance of assessing and evidencing the need for LLH, and that LPAs need to do more to assess the local housing needs of senior citizens across a diversity of type and tenures. On this basis, relying on national planning policy alone will not be sufficient to address the growing later living crisis.
Bringing order to Use Class chaos Beyond land allocations, another major challenge lies in planning classifications. The ambiguity surrounding Use Class designations continues to generate unnecessary delays and financial barriers, limiting the sector’s ability to respond to demand.
Planning policy must resolve this problem for extra care schemes in particular. At present, an absence of concise advice leads LPAs to adopt inconsistent approaches when classifying Later Living projects. This scarcity of clarity directly impacts the application of affordable housing and CIL. Under Use Class C3, developers must offer affordable housing and CIL contributions, whereas Use Class C2 does not always carry the same obligations. As a result, inconsistencies create confusion, delay decision-making and drive-up costs – ultimately hindering the build of much-needed LLH. One method would be to issue clearer information defining the particular
September 2025
www.thecarehomeenvironment.com 29
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