Proposed reforms to the National Planning Policy Framework and other changes to the planning system – Response from Habitat for Humanity Great Britain

1. Habitat for Humanity Great Britain is part of an international charity whose mission is to fight poverty and homelessness around the world. We believe that a decent home helps to permanently break the cycle of poverty and allows families to achieve strength, stability, and self-reliance. Our domestic work focuses on research and advocacy in support of more effective solutions to housing need, as well as the practical delivery of homes in partnership with local authorities and others.

2. We welcome the Government’s decision to focus on housing as a crucial strategic issue for health, wealth and prosperity in the long term. As we note below, reform to the planning system is only one string in the Government’s bow as it seeks to address the UK’s housing crisis, but it is an important one.

3. The consultation rightly identifies the importance of having a planning system that empowers a diversity of actors, beyond the major housebuilders and including smaller independent developers, community groups, self-builders, housing associations and local authorities themselves. While revising current proposals, and with future reforms, retaining this holistic understanding of the sector and the contributions different elements can make is key.

4. Setting high expectations for local authorities, and resourcing them appropriately to meet those expectations, is the right approach – but this must go beyond allocating more land for house-building and waving through developer proposals as quickly as possible. As the Government treats housing as a national strategic priority, it must enable local authorities to take a strategic approach to space and place, identifying local need and opportunity, while being realistic about what is possible.

Housing Targets and Viability

5. Setting clear targets that reflect national and local housing need, and enforcing those targets to ensure every local area has an informed and relevant local plan could be a positive step (Q1 and Q2). The Government is right to identify local plan development as a crucial process if we are to connect the national housing mission with local considerations and democratic engagement. Nationally mandated targets should not, however, be allowed to be too blunt an instrument.

6. It would be more positive to take a nuanced approach to targets, including specific targets for social and genuinely affordable housing, particularly on green belt land (Q34). Increasing the volume of social and affordable homes, both as a raw total and as a proportion of the overall housing stock, should be our number one goal. There is a risk, however that a local authority under pressure from the Government to deliver overall housing numbers feels it necessary to reduce expectations of social housing delivery.

7. Without specific targets for social housing in each area there could be a race to the bottom, with local areas forced to compete, attracting developers through their willingness to forgo social housing obligations. Housing waiting lists remain long in areas of both high and low land value. If there is concern that land value may reduce affordable and social housing viability in some areas, the solution is greater intervention from national and/or local government to unlock this, not a lowering of expectations (Q35). Efforts to reduce viability negotiation where land transacts above benchmark land values are welcome (Q39). Minimising the expectation of additional contributions for affordable housing beyond that set out in national policy is only appropriate if national policy makes clear the levels of social and genuinely affordable housing that are needed and that should be delivered (Q40).

Greenbelt Release and Densification

8. A “brownfield first” approach is right, but is only meaningful if steps are taken to ensure that brownfield sites actually are developed first. If not then the release of “grey belt” sites and encroachment into the greenbelt will leave difficult brownfield sites untouched, as developers give preference to more profitable alternatives.

9. Community engagement is critical for local and national support for the Government’s approach. If the Government and local authorities speak of a brownfield first approach, and raise expectations that this will be delivered, communities won’t understand when proposals are approved for development on valued green sites before brownfield.

10. Simplifying the planning process for brownfield development and previously developed land (PDL) is a sensible ambition, but the introduction of brownfield passports and relaxation of PDL restrictions will need to be carefully managed. Brownfield, and proposed “grey belt” land, takes many forms, and can often be an important source of biodiversity. Proposals that remove oversight of development must retain safeguards that ensure biodiversity is protected (Q20, Q22, Q23 and Q36).

11. Densification is important to create more vibrant and successful urban areas, better connect homes to transport, jobs and opportunities, and perhaps most importantly, enable development that is more environmentally sustainable for the long term (Q4 and Q5). Policies that favour densification must, however, be married to policies and resources that support the reuse of existing structures over destruction and rebuilding. It must be a priority that we look first and foremost at the opportunities presented by existing commercial and other non-residential structures for housing as vehicles for densification, before knocking down viable low-density housing.

12. It is important that densification policies are carefully worded to avoid the risk that already dense (urban) areas become ever denser, while rural developments are very low density by default. This would risk worsening established inequalities in productivity. Rural developments should aim for more efficient land use and design which takes steps to increase density and creates more sustainable communities for the long term (Q54).

Social and Affordable Housing Need

13. Traveller communities are often amongst our most marginalized, and experience many of the worst impacts of housing poverty. Taking steps through the NPPF to release land for traveller communities is therefore welcome. When assessing the appropriateness of sites, it will be important to prioritise places with adequate utilities infrastructure, council services and transport connections (Q32).
14. The decision to require local planning authorities to consider the particular needs of those who require social rent when undertaking needs assessments and setting affordable housing policies is a positive one, particularly while waiting lists for social housing remain high across the country (Q47). Care must be taken, however, to ensure that variation in requirements for different types of social and affordable housing across local plans do not cause perverse, counter-productive outcomes.

15. Habitat for Humanity GB has experience where a proposal for a property conversion which would have resulted in 100% genuinely affordable housing couldn’t be taken forward because the council’s local policy demanded management by specific registered providers. With the registered providers in question unable to take on the property, and after extended unsuccessful dialogue with planners, we were forced to sell the site commercially to ensure we secured a return that could be used for other programmes. Providing local authorities with the flexibility to shape policy in line with local need is important, but Government has a role to play in ensuring that proposals don’t act as blockers that stop smaller developers and housing charities from creating innovative, genuinely affordable homes (Q57).

16. We welcome the removal of preference given to affordable home ownership models over social and affordable rent (Q48 and Q49). Ownership, even discounted, isn’t an option for many people in housing need. It is, of course, important that efforts to shift the tenure mix towards social and affordable rent are combined with further steps to protect and strengthen the position of renters, including and beyond the proposals set out in the Renters’ Rights Bill.

17. We would also support policy that encourages mixed tenure developments and diverse communities that benefit social cohesion. It is important, however, that the design of developments is also promoted in a way that encourages organic mixing of neighbours. Too often, large schemes in the past that were ostensibly mixed tenure contained individual blocks of a single-tenure and questionable quality, resulting in segregation and inequality within an individual scheme. This approach should be discouraged and local planners encouraged to support proposals with well-designed community infrastructure (Q51).

18. We would support proposals to include specific reference to ‘looked after children’ within policy, in order to improve this provision (Q55). Having developed high quality, tailored solutions for children and young people, and seen the results in terms of wellbeing, education and life prospects, we recognize the importance of making specific provision for this kind of housing stock.

19. Community-led developments play an important role in place-making, particularly where a site is contentious or considered too complicated for commercial and large-scale house builders. Removing restrictions on the ability of communities to lead change in their neighbourhoods is a positive step, and should be married to effective local support to help groups through what remains an often difficult process to navigate (Q56).

Growing the Council Housing Stock

20. Encouraging greater volumes of council house building should be a priority concern for the Government.

21. Habitat for Humanity GB have demonstrated how councils can work with partners to deliver social rental homes through the conversion of empty retail sites. There is significant potential to do this at much larger scale, with councils leading the conversion of substantial empty commercial sites for social and affordable housing (Q52).

22. Driving development in this way will be imperative if the Government is to achieve its housing targets in a way that also reflects ongoing commitments to decarbonization and net zero. Analysts estimate that achieving the Government’s target of 300,000 homes through new builds alone would consume 104% of the UK’s total carbon budget by 2050. When factoring in the embedded carbon in existing buildings, it is estimated that conversion consumes between 50% and 70% less carbon than building anew. The Government could and should encourage councils to adopt similar policies to Westminster Council’s “retrofit first” planning approach, which requires large developments to demonstrate why retrofit is impossible if they are seeking permission to demolish.

23. Planning interventions to incentivize this kind of climate-friendly conversion could include setting mandatory targets for conversion at the local planning authority level, as a component of the overall housing target. (Q78). A more radical proposal for planning reform to address climate change could focus on removing the ability for developers to contest affordable housing requirements on the basis of viability, but open the opportunity to negotiate on the basis of carbon assessments (Q81).
    A standardised carbon calculating tool that could be used industry-wide would be beneficial, as currently individual business have bespoke calculating systems, or none. This would raise the benchmark by enabling all to undertake assessments and ensure parity across construction projects (Q79).

24. Alongside the climate impacts, the Empty Spaces to Homes approach has multiple other benefits: it helps revitalize ailing high streets and town centres; it means that social and affordable housing stock reflects the specific needs of local places and communities rather than meeting the budget of private developers; it is controlled by the authorities responsible for supporting residents; and it can be delivered at relatively high speed compared to often long-winded and contentious developments on greenbelt.
25. The most effective way to encourage this kind of development is not through regulation but by resourcing councils to enable them to operate more effectively and, in the long term, efficiently. Research we commissioned in 2021 found that local authorities and other public sector organisations own thousands of commercial and non-residential properties that have been sitting empty for more than a year, many of which could be repurposed as safe, secure, appropriate and affordable housing for vulnerable people. We’ve shown how it can be done in Barking, East London, by working with the local authority to transform a number of retail properties into homes tailored to the specific needs of care leavers.

26. The most significant restraints on councils doing this work at scale are resources in two senses. Unexpected additional cost burdens, as set out by the Chartered Institute of Housing, have limited space in housing revenue accounts for investment in new stock. Central government taking steps to empower local councils to invest in their housing stock again is crucial. Perhaps the bigger barrier, however, is the weakened capacity of local authorities to invest officer time in long-term solutions that require collaboration and financial certainty. Years of cuts to local government budgets make it increasingly difficult for officers to look beyond immediate emergency solutions to the most pressing needs of residents. Building capacity in planning departments will help smooth the planning process, but councils need additional resource in housing, adult and children’s services, in finance and in property management to create the space for the kind of joined up, strategic and transformational action that is needed. Lack of certainty regarding social rent returns and whether they will match cost changes over time also inhibits investment decisions. Habitat for Humanity GB are exploring how to support councils through the process on an individual basis, but to achieve change at scale will require meaningful government investment.

Conclusion

27. Many of the proposed reforms to the National Planning Policy Framework will be welcome by communities and those concerned with access to high-quality, affordable and secure housing. The Government must, however, guard against seeing planning reform as a silver bullet.

28. A holistic approach to housing is the right approach – one which connects planning and resource, and identifies opportunities to make better use of the spaces we already used before and as well as looking for opportunities to expand. Similarly, the forthcoming Budget cannot treat housing in isolation. Investing in effective housing solutions is vital to reducing long-term pressures on health, education and welfare budgets, and driving the economic growth at the heart of the Government’s mission.

29. With housing so critical to life chances, those in the most significant housing need should be our priority. This is Habitat for Humanity GB’s focus, and we will be increasing our domestic work over the coming months to put our international experience into practice.

For further information, please contact Guy Parker, UK Housing Advocacy Manager, at gparker@habitatforhumanity.org.uk