What should be in the Labour Government’s NPPF?

On 17 September, Labour Housing Group members and experts from across the housing sector met online to discuss what should be in the new Labour Government’s National Planning Policy Framework (NPPF).

Russell Curtis, founding director of RCKa Architects, provided a review of the NPPF

What is the NPPF?

The NPPF sets out the UK Government’s planning policy for England and how they should be applied. In theory, regional, local and neighbourhood plans should be aligned with the NPPF. As of June 2024, only 22% of planning authorities have an up-to-date local plan.

The new Labour government has published an updated version of the NPPF in July 2024, including updating the ‘presumption in favour’ of sustainable development, and bringing in changes to housing need, housing land supply, and updates to the Green Belt, and removing the idea of ‘beauty’ from the NPPF.

Housing need:

The new NPPF has a new “standard model” of housing targets, which significantly increased targets in many areas while decreasing them in a smaller number of areas, particularly inner urban boroughs. This is because of a change of focus to housing affordability and existing stock, rather than a focus on household projections which was how the previous NPPF calculated local targets.

Even with this adjustment, however, more urbanised areas have targets to achieve greater density than rural areas, and so fears that the new NPPF will ‘concrete over the countryside’ are unfounded.

The new NPPF also introduced a requirement for local authorities to have a 5-year land supply for housing, and reaffirms the government’s target of 1.5 million homes across five years.

Green belt:

The NPPF has aimed to increase housing delivery in green belt areas, which has produced some controversy. Russell downplayed these concerns, however, providing the example of Bassetlaw, which had a significant increase of its housing targets, but which would require a fraction of one percent of its total land to fulfil.

The NPPF includes a definition of ‘grey belt’ land, comprising of previously developed land in the green belt, or land which makes a limited contributed to the five Green Belt purposes. These five purposes are to:

1. To check the unrestricted sprawl of large built-up areas
2. To prevent neighbouring towns from merging into one another
3. To assist in safeguarding the countryside from encroachment
4. To preserve the setting and special character of historic towns
5. To assist in urban regeneration by encouraging the recycling of derelict and other urban land

Russell made it clear that, even providing 1.5 million homes would not make a significant impact on the countryside as it is. The consultation on the NPPF will close at 11:45pm on 24^th September.

Q&A for Russell:

How do we overcome the binary way of looking at planning to enable things to be built vs to stop things from being built?

People only interact with planning when it involves things being built around them. We need to encourage people to get more involved at the local plan-making stage. We need to make language around planning clearer so that is easier for people to get involved.

What should the NPPF say about empty homes, and how can planning help to produce homes which local people will be able to buy?

England has one of the lowest percentage of empty homes of comparable economies, and empty homes are necessary so that people can move around. While it is important to crack down on ‘deposit boxes in the sky’ the priority needs to be on housing delivery. This might not be a priority for the NPPF, but instead for local councils who can bring in policies which restrict empty homes.

How much can building on the grey belt help to meet the government’s housing targets?

One useful thing which the grey belt framing has done is to start to shift the conversation on the green belt, to make developing on less useful parts of it more possible. Research by Lichfields has shown that 15 – 20% of the green belt might meet Labour’s Grey Belt definition, this could be a significant area of land.

A lot of our eggs for housing delivery are in planning, what else is needed to hit 1.5 million homes in five years?

Planning has a lot to do with delivering new homes, as our existing planning system is too unpredictable. One reason that we have large volume housebuilders is that they can navigate the planning system, and it is harder for small developers. It will be very difficult to reach 1.5 million homes, and new towns in the countryside can only be part of that solution.

Roundtable discussion:

After Russell’s presentation, event attendees were able to contribute to the discussion in a roundtable discussion moderated by Alex Toal, Red Brick editor. A number of concerns were raised:

• Viability: Even with a move to deliver more affordable housing, developers would be able to reduce this by citing viability. Increased costs of building add further challenges here. Participants favoured moves to reduce the factors of viability, and to tighten Section 106 rules to ensure that developers had to deliver on what they had promised.
• Supporting the planning profession: Many people noted that local planning departments were suffering from particularly acute recruitment and retention issues, particularly after a decade of austerity. More needs to be done to ensure that planning officers are supported within local authorities and have more equivalent pay and conditions to their private sector counterparts.
• Density: There were concerns from participants that increasing density targets, particularly in areas with less need for more homes like the North East, could be detrimental to existing residents, particularly if there were compromises of quality on the way.
• Leaseholders and solar panels: One participant noted that freehold owners of blocks were allowed under permitted development rules to increase their blocks by two stories without planning permission. While this was no bad thing in itself, it did mean that leaseholders who might want to install solar panels on their roofs felt less able to do so, and that freeholders were less likely to allow this.

Panel discussion

After this roundtable, Labour Housing Group Vice-Chair Heather Johnson chaired a panel discussion with Rachael Williamson, Head of Policy & External Affairs at the Chartered Institute of Housing, Tom Chance, Chief Executive of the Community Land Trusts, and Cllr Shama Tatler, Cabinet Member for Planning, Regeneration and Growth at the London Borough of Brent.

Rachael Williamson began by noting that, while planning is not the only thing needed to solve the housing crisis, it is an important starting point. The moves in the NPPF are positive, but more is needed to increase capacity in local planning authorities and to invest in building the homes required. Therefore the budget on 30^th October and the following spending review will be crucial moments to deliver on housing.

Social housing needs to play a strong role being emphasised in housing policy, and affordable housing needs clearer definition tied with local income. With temporary accommodation on the rise, more needs to be done to factor this in to housing strategies more widely. The review of green belt land is welcome, and myth busting is needed. Widespread coverage of local plans is needed, and the government should also identify what land they have at their disposal to deliver housing.

Infrastructure is key to ensure that healthy places are created, with schools, healthcare and transport infrastructure in place from day one. Rachael concluded by noting that a positive vision for housing can be a key opportunity for the government to set some positive mood music, particularly as delivering change in the housing system will take some time.

Rachael is also looking ahead to the Planning and Infrastructure Bill to see what vision the government will set, in addition to how existing planning rules will be enforced to ensure that homes are delivered as promised.

Tom Chance followed with a suggestion of how the government can support SMEs in delivering a more diverse house building industry. Community Land Trusts, which Tom represents, primarily focus on community-led social housing, but along with other forms of self-commissioned housing they only deliver six to seven percent of homes in the UK, compared to 40% in comparable European countries. Similarly, SMEs only deliver ten percent of housing in the UK, down from 40% in the 1980s.

The planning system is primarily geared towards volume housebuilders, which means that homes in the UK are built slower, to lower quality and at less affordable rates. However, the cost and complexity of applying for planning permission has increased over the years, so that it can cost as much as £150,000 to navigate the planning system to deliver even ten homes. Costs per home for a small builder are two to three times larger than for a volume builder due to economies of scale.

It can take years to navigate the planning system, often because of rules such as those around nutrient neutrality, which adds further costs due to delays. Finally, uncertainty adds further burdens; even when builders work closely with local authorities to create a proposal which suits the local area well, they are still at the whims of individual planning officers.

One thing which is positive in the NPPF is a policy that at least ten percent of housing should be built on small sites and local planning authorities should allocate land in accordance with this. However, even larger sites can be divided off into smaller sub-sites, to forgo the resource burdens of local authorities having to identify a larger number of smaller sites for building.

The Community Land Trusts Network is pushing for an exceptions policy by which sites providing 100% affordable housing to address local need would be able to achieve planning permission when other non-affordable sites would not, and at a lower land price. This already exists on rural sites, but not yet in towns and cities. Therefore there is still work to go on the NPPF to prioritise certain types of development over others, and to champion a wider diversity of housebuilding.

Shama Tatler finished off the presentations in the panel debate with the example of Brent’s housing needs. Since Liz Truss’ mini budget, the number of households going into temporary accommodation has significantly increased, with 120 to 150 households per week presenting as homeless to the council. Brent’s council housing waiting list has increased to 30,000 and an additional £16m have had to be dedicated to temporary accommodation.

The changes proposed within the NPPF will affect boroughs like Brent, which are already delivering significant quantities of housing, less than others. But policies are needed to support good development, such as ensuring that public sector partners provide infrastructure according to promised timelines. The Housing Delivery Test also needs looking at, since it currently falls with local authorities, who are only responsible for approving new homes, rather than the full delivery. Shortening planning consents from their existing timeline of four years, for instance, would help to ensure accountability.

Shama followed up with calling for more to be done to pair up housing with infrastructure delivery, going as far as to suggest the creation of a unified Department for Housing and Infrastructure, to ensure that new homes are well-provisioned.

On quality, a move needs to be made on building safety to move away from independent assessments and back into local authorities where there is an increased quality and consistency of building regulations. Often, safety and quality issues arise because assessments are being done by a third party rather than by local authorities who are more accountable for the buildings in question, and so moving this in-house would help.

Local authorities also need further resources, particularly after a decade of austerity where councils saw cuts of 60% of more. This not only impacts planning departments, but housing management departments, with Housing Revenue Accounts in substantial debt as a result of funding cuts.

The NPPF is a moment of opportunity and to be optimistic about what can be achieved, to start a discussion on what barriers can be removed from the planning system which will not compromise on home quality. Community involvement is key, but it needs to be done earlier at the local plan stage. Shama finished by calling for planning to be viewed as something positive, rather than necessarily a more oppositional system.

Thank you to our panellists for presenting on this topic, and to our audience for attending the event.