Housing and the NPPF: does it really need to be ‘this or that’?

by Emma Cooke, External Affairs Manager, and Vicky Payne, Strategy, Research and Engagement Lead

Housing crisis? What housing crisis? That’s the question you might find yourself asking when reading the Government’s proposals on refreshing the National Planning Policy Framework (NPPF).

Like many other organisations with an interest in housing and planning, last week we responded to the Department for Levelling Up, Housing and Communities’ consultation.

Risky revisions

Our take on it was that many of the proposed revisions risk making it easier for local authorities to turn their backs on delivering the homes the country so desperately needs.

This is because many of the proposals create ways for local planning authorities to avoid planning for their identified housing need or to turn down applications.

The consultation proposes that there should be no need to review Green Belt when making plans locally, and that applications could be turned down on the grounds of ‘sustainability’, but with no definition of what that means. It also suggests that building at densities significantly out of character with an existing area may be considered in assessing whether housing need can be met.

We worry that, when taken individually and in the round as a policy direction, these proposals create routes for local planning authorities to avoid planning for the homes that their communities really need.

Are polarised debates really necessary?

We know that debates about land use, housing supply, and what needs prioritising can be really polarising. But we don’t think they need to be.

We don’t need to choose between building enough new homes and building homes that are well designed, built in the right places and that include all the ingredients that contribute to people having a good quality of life.

We don’t need to choose between this or that.

In terms of land use, the housing crisis means that we really do need an anything and everything approach.

It’s too easy to cite empty homes, retrofit, brownfield land use, and intensification or densification as reasons why we don’t need homes on other land.

And it’s true, all of those things do need to happen.

But they don’t need to happen at the expense of finding ways to build high quality, medium density sustainable development on strategic land allocations large enough to provide for the infrastructure and amenities needed.

Such an approach is preferable to the impacts of cumulative smaller applications around the edge of settlements, that do not join up, and by themselves may not support required infrastructure. Large strategic sites may need to be on carefully chosen, appropriate green field or Green Belt land.

All the tools in the toolbox

At times, that may mean the mindful and well-informed renegotiation of Green Belt boundaries is necessary, where this is required to meet housing need and to achieve sustainable patterns of development.

It may also mean using good design to provide housing at really quite high densities, which may subjectively be defined as ‘out of character with the surrounding area’. Good design makes it possible to do this in ways that fit with many different contexts from the urban to the rural.

And, as we know, such patterns can be inherently sustainable and create the critical mass needed to support public transport, shops, services and communities. This, then, should be encouraged as a route to meeting housing need.

This or that?

So, it is not a question of this or that.

It is not a question of densification, filling empty homes and using brownfield sites or of making strategic use of other types of land.

It is not a question of meeting housing need or of developing homes in a way that is sustainable and sensitive.

Having a decent, affordable home in a safe, well-designed neighbourhood is the foundation of a happy, healthy life. And at the moment, we do not have a sufficient supply of these homes.

So national planning policy should not be encouraging local planning authorities to choose between this or that.

It should be encouraging those authorities to truly understand the needs in their local area and to explore the many different avenues through which those needs could be met.