Consenting a supported living or move-on accommodation scheme

Supported living planning permission turns almost entirely on one question: is the scheme a residential institution in Class C2 or dwellings in Class C3? The answer decides whether space standards apply, whether affordable housing policy is engaged, what levy rate attaches, what parking standard is used and what the conditions look like. Get the classification argued properly at submission and the rest of the application follows.

The Use Classes Order does not use the phrase "supported living", which is why the question is contested so often. What it does is define care, and then split accommodation by the level of care provided and whether the residents live as a single household.

Where supported living sits between Class C2 and Class C3

Class C2 covers use for the provision of residential accommodation and care to people in need of care, other than a use within Class C3, together with hospitals, nursing homes, residential schools and training centres.

Class C3 covers dwellinghouses, and it has three limbs. A single person or a family. Not more than six residents living together as a single household where care is provided to them. And not more than six residents living together as a single household where no care is provided.

So a six-bedroom house with personal care for residents who live as one household falls in C3, not C2. Seven residents, or residents who do not live as a single household, takes it out of C3. A scheme of self-contained flats with floating support usually reads as C3 dwellings, because each flat is a separate household and the support is delivered to it rather than within an institution.

Move-on accommodation sits awkwardly. Where units are self-contained and occupiers hold their own tenancies, C3 is the likely answer. Where rooms are shared with communal facilities and a staff presence, the scheme may be C2 or, on some facts, sui generis.

Level of care and how it is evidenced

"Care" is defined in the Use Classes Order as personal care for people in need of it by reason of old age, disablement, past or present dependence on alcohol or drugs, or past or present mental disorder. That definition is narrower than everyday usage, and it excludes practical help with housing, budgeting or employment.

Evidence the level of care rather than asserting it. The documents that work are the operator's model of care, the staffing rota with hours of cover, the referral and allocation policy, any registration with the relevant regulator, and the support plan template used for residents.

An application that describes "supported accommodation" without saying who provides what, for how many hours, to how many residents, invites the council to pick the classification that produces the higher obligations.

Space standards and whether they apply

Where a council has adopted the Nationally Described Space Standard as a local plan policy, it applies to new dwellings. A C2 institution is not a dwelling, so the standard does not bite in the same way, and bedroom sizes are driven by the care model and by accessibility requirements instead.

That is a real difference in scheme design. A C3 scheme of self-contained units has to meet the adopted internal area and bedroom width figures, plus whatever accessible and adaptable dwellings policy applies. A C2 scheme has more latitude on unit sizes and less on communal provision.

Do not design to one classification and argue for the other. Where the classification is uncertain, design the units to the stricter standard so that the scheme works either way.

Staffing, management and on-site presence

Describe the staffing honestly in the Planning Statement: daytime hours, evening cover, sleep-in or waking night staff, visiting professionals, and the number of staff on site at peak. Officers use those numbers for parking, for traffic generation and for the intensity of use assessment.

Where there is a sleep-in room, say so and show it on the plans. Where staff change shifts at a time that generates vehicle movements, say when. Attempting to minimise the staffing description to dampen objections usually produces a condition that the operator then cannot comply with.

A management plan secured by condition is normal and useful. It should cover staffing levels, referral criteria, the response to incidents, visitor arrangements and a named contact for neighbours.

Parking and travel demand of residents and staff

Resident car ownership in supported schemes is often well below the general residential standard, and staff demand is often above it. Both points need evidence rather than assertion.

The evidence that works is the operator's own records for comparable schemes it runs, set out as a table with the scheme, the number of units, the number of resident vehicles and the staffing. Where the operator has no comparable scheme, a reduced provision has to be supported by accessibility: distances to bus stops with service frequencies, distance to a railway station, and a travel plan.

Visitor and drop-off provision is the detail that gets missed. Schemes with regular visiting professionals and family visits need a short-stay space near the entrance, and the Design and Access Statement should show it.

Affordable housing and levy implications of the classification

This is where the money is. Affordable housing policies are usually drafted around dwellings, so a C2 classification may take the scheme outside the requirement, though some plans now require contributions from institutional uses as well. Read the policy text rather than relying on the general position.

Community Infrastructure Levy liability depends on the council's charging schedule and the rate it sets for the relevant use. Residential rates are commonly expressed for dwellings, so an institutional use may be charged differently or not at all. Check the adopted charging schedule for the authority before assuming a figure, and remember the schedule is indexed.

Where the scheme is C3 and affordable housing policy applies, the Affordable Housing Statement has to explain how the supported units are counted and against which tenure, because supported housing does not map neatly onto standard tenure definitions.

Community concerns and how they are properly weighed

Objections to supported housing frequently focus on the prospective occupiers rather than on the development. The characteristics of future occupiers are not a material planning consideration, and a council has a public sector equality duty under the Equality Act 2010 which bears directly on how it handles such objections.

What is material is the physical and operational effect: intensity of use, parking, noise from comings and goings, bin storage, and the suitability of the building. Address each of those with evidence, and let the officer deal with the rest.

A short, factual community engagement exercise before submission helps. Not a consultation about whether the scheme should exist, but an explanation of the staffing, the management arrangements and the named contact. Where the health case is part of the justification, a Health Impact Assessment gives the officer something substantive to weigh.

Conditions securing care provision and management

Expect a condition restricting occupation to the use class applied for, and often a tighter one restricting occupation to persons in need of care as defined in the Use Classes Order. Expect a management plan condition. Expect a condition on staffing levels where parking was assessed on that basis.

Two drafting points. A condition that ties the scheme to a named operator is a personal permission and should be resisted, because it devalues the asset and fails the tests for conditions. And a condition restricting occupancy numbers should state the basis of the count, because "no more than six residents" and "no more than six persons" mean different things once staff are in the building.

Enter your postcode on PlanScope to see which reports a supported living scheme is likely to need.

This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it.

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