Case study: the revised NPPF and its impact in Bottisham
The decision on Rowan Close, Bottisham, is one of the first released since the revised National Planning Policy Framework (NPPF) was published in December 2023.
The impact of the revisions can be clearly seen in the Inspectorate’s approach. The Inspector took into consideration:
- How the need for specialist housing for the elderly should be addressed
- The viability profile of Integrated Retirement Communities (IRCs)
- The benefits of the sector.
Key findings
“32. Planning Practice Guidance (PPG) states that the need to provide housing for older people is critical, whilst recognising that there are a variety of specialist housing types to meet the needs of this group. The type of accommodation proposed would comprise extra care housing for older people (also known as housing-with-care) in the form of an integrated retirement community facility (IRC). Whilst it falls within the C2 use class, extra care housing is distinctly different from other forms of older people’s accommodation such as care homes and retirement housing.
36. In summary, it is clear that when considering the short, medium, or long-term net need for extra care housing for those aged 75 or over, this is likely to far exceed supply. Whilst the figures have been updated by the appellant, they do not markedly alter the appellant’s evidence as it was considered by the previous appeal Inspector. I also find that the need is acute.
37. Interested parties refer to other vacant units at existing facilities in Bottisham. Be that as it may, the existing facilities comprise different forms of housing for older people and not the extra care housing sought by this appeal. Furthermore, the Council does not dispute that there is a need for older people’s extra care housing in the District.
38. The evidence supports the appellant’s assertion that retirement housing schemes are generally less viable than general needs housing due to a range of factors, such as higher build costs. This is not contested by the Council and appears to me to be a major factor influencing past delivery, which has been abject at best. Indeed, the Local Plan acknowledges that the District faces a major challenge in increasing the provision of housing for the potentially vulnerable and elderly.
39. Paragraph 63 of the Framework emphasises the importance of planning policies in ensuring that housing needs for different groups, including housing-with-care for older people, are addressed. However, no sites are allocated specifically for C2 use in the Local Plan. That the predicted supply of extra care housing falls significantly below the identified need, and is anticipated to do so in the future, is partly a result of a distinct lack of robust local planning policies and site allocations to support this form of housing. Furthermore, the Council’s robust housing land supply position is not predicated on the future delivery of extra care housing, which reinforces the inadequacy of the Local Plan in supporting the delivery of this type of housing for older people.”
In relation to the wider benefits of the scheme, the Inspector held:
“Release of general market housing
57. The provision of up to 170 extra care units would be anticipated to release 113 existing housing units into the market. This would be due to future occupants of the extra care accommodation vacating existing properties (which are often under-occupied) and larger family houses. These knock-on benefits attract significant weight in favour.”
“83. In respect of benefits, as well as deficient local policy support, there are significant market constraints affecting delivery potential and no alternative sites have been identified. This leads me to conclude that the identified acute extra care housing needs are unlikely to be realised over the plan period. This proposal would make a significant and meaningful contribution to addressing the need for older people’s extra care housing; a matter which attracts very substantial weight in favour.”
"Whilst our research shows that progress with local planning policies has largely stalled over the last two years, the same can’t be said of the national policy position that applies to seniors housing.
“The December 2023 revisions to the NPPF are already providing greater support for retirement housing applications that are decided at appeal. The national policy environment for the sector is likely to improve in the medium term, following the publication of findings of the Older Persons Housing Task force later this year; and the provisions in LURA taking effect, which will place the Secretary of State under a legal duty to provide detailed guidance on how local authorities should meet the needs of the elderly population
“As such, the Bottisham appeal decision should be viewed in the context of an increasingly supportive national policy environment. It is an encouraging sign of the difference that national policy can make, when local policies are absent or insufficient."
Nicola Gooch
Partner & Planning Specialist, Irwin Mitchell