Reforming Site Thresholds – An Opportunity to Boost Supported and Older Persons Housing Delivery

The changing of ‘thresholds’ has been a bit of a buzzword in proposed revisions to Planning Policy and the process. Two specific threshold changes stand out: the introduction of a new ‘medium’ planning application category and clearer tenure expectations within Local Plans. Together, these may aid the delivery of greater numbers of older persons and supported housing.

‘Medium’ Sites

In May 2025, the Government published a ‘Reforming Site Thresholds’ working paper, seeking views on a more proportionate planning system. A key proposal is the introduction of a new ‘medium’ development category covering schemes of 10–49 homes. This is particularly relevant for older persons’ and supported housing, where many schemes naturally fall within this range.

There are several compelling benefits, with my top three covered here:

1. Simplification of BNG requirements – this will result in a simplified method for delivery of BNG, increasing the certainty of delivery, which is good if more specialist and supported housing is to be delivered.
2. Application of the ‘Permission in Principle’ - I have not seen this widely used to date and it is relatively unknown in Local Authority Planning Departments, but it offers an opportunity for early, low-cost confirmation of planning acceptability. This is especially valuable for the constrained brownfield sites that frequently accommodate specialist housing schemes.
3. Proportional submission of information for planning applications – depending on the exact detail, this should reduce costs for submissions which are becoming prohibitively expensive for SMEs, which covers many developers and operators of specialist and supported housing. Any reduction in unnecessary reporting and procedural burden directly supports delivery.

Local Plan – Tenure Expectations

Historically, Local Plans have struggled to adequately plan for older persons’ and specialist housing. Proposed changes to the National Planning Policy Framework (NPPF) represent a step forward by requiring firmer tenure expectations on sites of over 150 homes, based on local housing need.

The introduction of a 40% minimum requirement for M4(2) accessible housing is welcome, but it remains a compromise. With most of the existing housing stock failing to meet accessibility standards, this threshold alone will not address the structural imbalance. A stronger baseline for new development would better future-proof communities.

Overall, setting clearer tenure expectations is a positive shift. However, real impact would come from embedding these expectations across all identified Local Plan sites, not just large allocations. Aligning tenure requirements consistently with local need is essential if specialist and older persons’ housing is to be delivered at scale, and in the locations where it is most needed.

Summary

Proposed changes to planning thresholds offer a real opportunity to unlock further delivery of older persons’ and supported housing by reducing the complexity and cost of planning applications. However, to achieve meaningful impact, clearer tenure and accessibility expectations must be embedded consistently across Local Plans and aligned with local needs.

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WWA are proud to sponsor Housing LIN’s online planning portal, Planning Homes and Communities for Older People, where you can find a range of useful resources on national guidance, strategies and tools and examples of local planning practice for an ageing population.