Planning
characteristics of extra care schemes within each Use Class, similar to how the Greater London Authority (GLA) has handled affordable housing in the London Plan. This would acknowledge the considerable variation across extra care developments and provide a framework for distinguishing between schemes that fall under Use Class C2 or C3, rather than attempting to offer a blanket model.
Rethinking Reform
Classification complications are just one piece of the puzzle. Clearly gaps remain in planning policy, but how should these be addressed?
The Older People’s Housing Taskforce
advocates for stronger planning policies at both national and local levels to boost the supply of LLH. It urges LPAs to be equipped with ‘the right levers to address the under- supply of later living housing, including ensuring sufficient land is made available to support the volumes of new supply needed, raising the profile and priority given to later living housing in local plans’. Managing the ‘social reluctance to plan for old age’ is key, and these priorities must be reflected in updated National Planning Policy Guidance. The NPPF should also be amended
to provide clearer direction for LPAs to conduct a thorough, evidence-based review of both current and projected LLH needs. This assessment should provide a broad evaluation of older persons’ facilities, and distinguish between general and specialist care requirements, identifying where provision is most critically demanded across the LPA.
There is no ‘one-size-fits-all’ remedy.
LPAs must facilitate a diverse range of housing options to meet varying needs- based supply (meeting, at least, the minimum level of demand) and different typologies. Equally important is the identification of suitable locations, ideally in town centres or areas with existing and planned access to services, transport and amenities.
While national policy updates would help to provide a clear direction for LPAs to respond to the growing need for LLH, it is noted that any such progress would be constrained by the timescales required for LPAs to undertake evidence-based testing and prepare updated local plans. As such, there is currently no short-term solution to meeting this growing crisis of under- delivery.
Local plans need to allocate a sufficient 30
number of well-located sites for LLH, or include specific provision for LLH within site allocation policies. Currently, allocations are typically confined to care homes within larger strategic developments. Instead, local plans should emphasise on plots in villages and town centres or on outskirts, where they best meet public needs. Furthermore, they must continue to include at least one policy supporting the delivery of LLH across all typologies. While a plan-led system is essential, it must not be rigid. Local plans span a minimum of 15 years, yet economic, social and demographic shifts do not adhere to planning cycles. To ensure flexibility, national and local policies must accommodate speculative applications where housing needs are evidently unmet.
Time for Action As our world ages, the inadequacy of senior living accommodation is becoming ever more pressing. The need for further planning reform is undeniable, but for it to be truly effective, obstacles must first be addressed. While the transition of government presents a fresh opportunity which is welcomed by the property industry, future updates to national planning policy should encourage local authorities to plan for the delivery of LLH The NPPF revisions should go further in bridging critical gaps in policy, including the lack of solid backing for specialist accommodation and continuing uncertainty over whether extra care developments should contribute to affordable housing and CIL.
Additionally, there is more to be done to prioritise LLH within planning policy.
For example, implementing key OPHT recommendations, such as establishing a presumption in favour of older people’s housing, conducting targeted assessments of future needs, and addressing the viability challenges that hinder development. It remains uncertain whether the imminent Planning and Infrastructure Bill or forthcoming updates to National Policy Guidance will take the bold and necessary action to confront these challenges. However, what is indisputable is that immediate action is required to secure a sustainable future for later living.
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Zoe Curran
Zoe is a senior planner based in Boyer’s London office, working on a variety of projects across London and the South East, including residential and commercial developments and mixed- use schemes. Prior to joining Boyer, Zoe graduated from the University of York with a BA (Hons) in History and the University of Manchester with a Master’s degree in Planning.
www.thecarehomeenvironment.com September 2025
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