NaCSBA welcomes the latest version of the NPPF, as part of Labour’s ambition to deliver 1.5m new homes. In particular we welcome the new section aimed at increasing the mix and choice available on sites. However there is an urgent and recognized need to do more to support small sites in particular.
NaCSBA’s policy objectives are focused on three main areas:
- Ensuring that the Right to Build legislation operates as parliament intended.
- Reversing the trend away from fewer planning permissions for small sites.
- Ensuring that a proportion of plots are set aside for custom and self build on large sites
Planning has for some time been the greatest barrier to the growth of the sector and to housing delivery more widely. The need for reform was highlighted in the recent Competition and Market Authority Market Study into Housebuilding.
The review of the NPPF is welcome, although it does not directly address the work needed to ensure that the Right to Build operates as intended.
We have therefore analysed the changes announced, and their impact on the sector into three areas:
- Overall
- In relation to small sites
- In relation to large sites
At the heart of the NPPF changes is the reintroduction of housing targets. Furthermore these targets have been reallocated and are higher. This means that not only must more homes be developed but more Authorities will find themselves without a sufficient planned housing supply – increasing the chance that new plans will
be approved. This should benefit all forms of housing delivery, although as we already know it is the larger developments that are generally the winners in the current planning system.
Small sites
The NPPF consultation recognized the challenge with regards small sites and the Bacon Review highlighted that the proportion of homes built on small sites had halved in the past 10 years. However, whilst the issue had been recognized the NPPF consultation did not propose solutions it only asked what could be done. NaCSBA made proposals including exception sites and making it easier for infills and to build in gardens, but as expected there was little in this update to make a difference. Furthermore, the updated NPPF appears to have reined back on proposals to strengthen the position of small sites, in part it seems due to concern over stretched local authority resources. This is the wrong response to a recognized issue. The solution is to make it easier for small developments to proceed, not least through the Right to Build.
The Government has at least recognized that there is a problem. They say in their papers:
“However, the government recognises the strength of feeling from the consultation that small site policy generally is not working for both local planning authorities and small to medium sized developers. Supporting small to medium sized housebuilders to grow is a crucial part of the government’s strategy, and we are strengthening the wording in the National Planning Policy Framework to make the importance of allocating small sites to small to medium sized housebuilders clear. We intend to give further consideration to how policy can better support small site development as part of our work to produce a set of national policies for decision making in 2025.”
The wording changes that are referenced are meaningless spin, but the recognition of the need for action (and soon) is important – and NaCSBA will continue to push for the needed action in this area.
Large sites
Positive changes have been made to the approach to large sites and specifically to increase the diversity of build on those sites. This need was highlighted in the 2018 Letwin Review, which in effect
concluded that the best way to build more houses more quickly was to increase choice (and competition) on large sites.
The NPPF introduces a new section to support this diversity and this makes specific reference to custom and self build. It states:
- Mixed tenure sites can provide a range of benefits, including creating diverse communities and supporting timely build out rates, and local planning authorities should support their development through their policies and decisions (although this should not preclude schemes that are mainly, or entirely, for Social Rent or other affordable housing tenures from being supported). Mixed tenure sites can include a mixture of ownership and rental tenures, including Social Rent, other rented affordable housing and build to rent, as well as housing designed for specific groups such as older people’s housing and student accommodation, and plots sold for custom or self-build.
They have also stated in the associated papers:
We intend to reinforce this with further measures in the new year, including setting a site size threshold above which sites must deliver a mix of tenures.
We are keen to see a minimum percentage of plots for custom and self build on all larger sites with stronger support to ensure that these plots are appropriately positioned, serviced and marketed.
Overall, this is great news, and long awaited. We await further details as to how the Government intends this new section to be applied. The wording introduced is effectively as consulted on. In our response we noted that the wording was not strong enough to ensure the changes come about. We hope therefore that this concern will be addressed by the ongoing work in this area.
In conclusion
The updated NPPF makes important strides forward with regards the overall delivery of new homes and to improving the mix on large sites. All this is welcomed. However, and as recognized, there is more to do to address the issues with regards to smaller sites. Whilst it is understandable that this has not been addressed at this stage it is important, if the ambitious housing targets are to be met, that this area is addressed in 2025.
We were not fully convinced from the Government’s work to date that as to the seriousness of this issue and the need for early action. We will look to work with our partners who together deliver housing diversity and through our own engagement with ministers and officials to make the case for further change.
If you have any further comments to make or if you require more information as to our position on specific areas of policy, then please get in touch. We will provide further details in our next member update on 17 December.
