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Residential Aged Care Facilities – The VPP’s steps forward in 2018

Work is currently underway to reform the classification and assessment of Residential Aged Care Facilities (“RACFS”) within the Victorian Planning Provisions. In July 2016, the Managing Residential Development Advisory Committee – Residential Zones Review identified the need for residential zones to provide greater support and flexibility with notable recommendations, in addition to high level objectives, the Committee concluded 

• The maximum building height controls in the current suite of residential zones do not support State planning policy support for facilitating RACF development.
 • RACFs should be excluded from mandatory maximum building height requirements and some ResCode requirements

Synthesis of the above-mentioned has resulted in the exhibited Clause 52.X draft Residential Aged Care Facility. The proposed provisions have recently been exhibited with key refinements including; confining ResCode tests to internal/offsite amenity impacts, and built form siting, in addition to the ability to grant a permit to vary (under Clause  2.XX-4) the requirements of Clause 52.XX-3 (or the abovementioned). Small steps but steps nevertheless. 

I applaud the Ministers intent and the Departments move to reform but as with all bystanders I have the luxury to ask, “will this go far enough”. For comparison I turn to our NSW counterparts. Specifically, the differentiation between the differing types of seniors housing provision and subsequent methods of assessment under Chapter 2 and 3 of the State Environment Planning Policy (Housing for Seniors or people with a Disability) 2004. In terms of regulatory frameworks and specificity in detailing the differences in classifying seniors living models within the planning scheme, our NSW counterparts are “miles ahead”. 

Unlike NSW, within Victoria RACF’s, Retirement Living, Independent Living Units, high, low or transitional care facilities are not clearly distinguished within the VPP’s. Whilst Clause 74 provides broad land use definitions – certainty cannot be derived from clear definition and differentiation of senior living models. It follows that I believe the existing VPP’s (and reforms) do not go far enough to reflect the transition in the seniors living or lifestyle industry that are on foot or reflect the certainty required by service providers to compete within the land acquisition market place.  

Ageing is no longer about seeing out the twilight years in medium to high care facilities. My parents are baby boomers, healthier than any other generation of a similar age before them. They are cashed up (literally or figuratively with assets) and are approaching their later years of life with zest for activity, community and family. They have done their part in paying for their kid’s education, their taxes, and have been the first generation to have dual income households. We should acknowledge a) that they (and us) are ageing with differing expectations, and b) our existing ageing in place is little more than objective within a policy statement rather than a real, deliverable target.

How is this relevant to planning? Well, it starts from the top down and is two-fold. 

RACF’s is but one form of aged care. Within the current definitions of the VPPS, RACF’s does not account for the different types of aged care, whether it be independent living, low care with in home care, or lifestyle models (which require minimal care but access to care services such as basic GP, mental health, pharmaceuticals etc etc.) 

Aside from a differentiating and defining each of the models within a planning definition to land use, incentives need to be provided to service providers to create certainty – currently the assessment of built form for RACFs falls back to ResCode, with no exemptions, and importantly, no incentives for service provision. That is, the same market forces (“magic hand”) which are pushing first home buyers to the fringe, are also intervening in the service provision for much needed facilities, i.e. redevelopment sites potentially suitable for seniors living models are losing out to the apartment development/standard residential redevelopment market. We as an industry (and indeed a society) need to decide if we are going to introduce an artificial market force via public policy intervention to redirect or incentivise a much-needed adjustment. 
Incentive must be provided to seniors living/lifestyle providers in terms of built form, and land use exemptions. On this basis, certainty is given to service providers to compete within the “standard” residential (or indeed commercial market depending on location and land use mix) market place for land acquisition. The market will adjust. 

For example, a height exemption of X storey’s above the 13.5 max under a GRZ would arm providers (and indeed developers acting for service providers) to invest in well located, well serviced inner urban or middle ring sites where yield and model can be accurately and confidently forecasted, and as such, risks in acquisition can be balanced. 

We should aim to provide our seniors living – not on the fringe away from the communities that the residents have helped build, but in and amongst their networks, communities and families. If indeed the new model for seniors living is one of inclusion by good urban design and well considered urban planning then we as an industry have the responsibility to provide a regulatory framework which provides development incentive, and importantly, confidence for service providers to purchase desirable urban sites - let them “stretch their legs” and put to market vertical seniors living models, co-locate seniors living with childcare and medical facilities, or higher education or retail land use mixes – capture the imagination and preference of a post 2000’s ageing.  

I see this as a relatively simple fix. Being 65 in 2018 is different to being 65 in 1965. Expectations, disposable income and wealth, family commitments and preference are generations apart, figuratively and literally. I say bravo to the first step of reform however recommend we look further North for a case study of “better” practice. 


  1. There is strong planning policy support at a State level to facilitate RACF development and to enable ‘ageing in place’.  A working group, with representatives from industry, peak bodies, councils and state government, has been established to provide advice in developing new RACF planning controls to ensure their timely and cost-effective delivery.
  2. Try obtaining an approval for an intergenerational home in Metropolitan Melbourne and a proposal with more than one kitchen or separate entry point is treated by planning departments as a hideout for a dictator.

planning, melbourne, housing, aged care

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