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Priced Out have been leading the fight for housing affordability since 2006. As a volunteer run campaign, we aim to represent the victims of the housing crisis, and campaign for policies delivering better outcomes to all.

The National Planning Policy Framework (NPPF) plays an intrinsic role in modern planning law. This is because it constitutes the primary expression of Government policy against which the soundness of a draft local plan is considered. Moreover, in the decision making process it is also important, since a development plan that is contrary to the NPPF is presumed to be out of date, and therefore given less weight in the planning balance.

It is thus essential that the NPPF provides a realistic path to meeting Government house building targets . The 300,000 homes per year target that PricedOut campaign for is not just a mere expression of our desire; it is a manifesto promise that has been expressed in multiple Queen’s speeches. However, this target in the long run remains insufficient. Professor Glen Bramley has estimated that 340,000 new homes built every year till 2031 are needed to end the housing backlog over a 15 year period. However, this is based on data only running to 2015/16, meaning that it does not account for the 7 years of not building 340,000 homes per year since then. Indeed, the Centre for Cities has estimated that it would take at least 50 years to fill the current shortage if we built 300,000 homes a year from now onwards. To end this shortage in the next 25 years would take 442,000 homes a year to be built every year. For context, in 2020 the United Kingdom built just 243,000 homes

This provides the context within which the NPPF needs to be examined. National policy that fails to meet the need for sustainable development necessarily fails. The following consultation response shall address specifically how the draft changes to the NPPF, considered as a whole, would turn a dysfunctional system into a failed system.

This is shown most clearly in the changes to the status of housing need calculations. Currently, local planning authorities (LPA) must follow the standard method when creating Local Plans unless exceptional circumstances apply. This is calculated by assessing household growth projections, adjusting this upwards where the ratio of house price to earnings ratios is high, and capping the level of increase that any LPA can face. In some urban areas this is then increased further recognising the scale of the affordability crises in these areas. If development plans are out of date, then the application will be approved unless it is in a protected area or the harms significantly outweigh its benefits. This, therefore, provides an incentive for local planning authorities to keep an up to date plan that meets their housing needs in that area.

The problem with the proposed amendments is that it would change the way mandatory housing need targets operate. This is done by making the standard formula for measuring housing need a mere advisory starting point. As well as this the housing need figures will completely lose any status where this can only met by building at densities out of the character of the area. This is a subjective test, and inevitably will prompt more litigation to the detriment of already underfunded local authorities, as well as allowing more authorities to get away with failing to meet the needs of their residents. Moreover, if greenbelt release is necessary to achieve these targets, then the target will also lose its limited effect, despite the greenbelt already making up 12.6% of England. 

We have already seen the effects of this with multiple authorities delaying their local plans in an attempt to present ones that, in line with the draft framework, will require councils to permit significantly less housebuilding. For example, Mole Valley councillors have asked their inspector to remove all green belt sites from the draft plan; this modification would see 1476 fewer homes built in the area. 

Unfortunately there is not enough brownfield land alone to meet housing need in any region. Outside of the South East the bulk of brownfield capacity is in the least viable areas, and 48% of sites on brownfield registers are to come forward for flats, which is a type of accommodation sought by just 17% of households. Whilst this is a positive move for inner cities where we submit that development should be focussed it cannot by itself meet the housebuilding that we need. 

However, it is possible to focus planning around already built transport hubs like train stations and bus stops. Professor Paul Cheshire and Boyana Buyuklieva have estimated that if Green Belt land within 800 metres of a train station that is less than 45 minutes commutes of a major city, then this would provide enough land to build 1.1 million new houses. This calculation excludes all national parks, AONBs and public recreation areas, and would only require releasing 1.8% of the existing green belt. Elsewhere Russell Curtis has estimated that you could build 1.26 million new homes around England’s rural stations and lose less than 1% of the current greenbelt. By providing further discretion over Green Belt release to local authorities it is inevitable that completely appropriate developments will not occur, and thus overall developments will fall. 

Given that 2022 already saw a significant slowdown in the number of plans being published, with Planning Magazine reporting that it was the lowest in a decade, these changes have the potential to worsen an already dire situation. Indeed, Lichfields have reported that it is precisely the issues of Green Belts and Housing Need that has been causing delays even before the publication of the draft changes to the NPPF. This report was in April 2022 where they described some 70,000 permissions being delayed – since then a further 74,000 homes have been delayed due to similar uncertainties over national policy. This means that simply due to policy uncertainty over 140,000 homes on net have not been planned for, and therefore most likely will not be built anytime soon. Based on this logic the leading Barrister, Chris Young KC, has estimated that across the country 100,000-200,000 less homes every year would be built if the draft plan was to be adopted. Slightly more conservatively the Home Builders Federation have put this figure at 77,000. Regardless of the specifics, the decline in annual building is extremely alarming. 

Further discretion is incorrectly proposed to be given to local authorities that are “oversupplied”. Frankly, over-supply does not exist in England. According to data from the OECD as a percentage of the total stock, the United Kingdom has the lowest amount of vacant housing stock in the developed world. The mere fact that a local authority has provided permissions greater than 115% of their housing need is therefore not sufficient to switch off the presumption in favour of sustainable development. This is because there are many good reasons why a planned house is never delivered, such as where developers need to re-plan an approved permission or where pre-commencement conditions take longer than anticipated to discharge. By switching off this presumption, then local authorities will have an incentive to permit the developments least likely to happen to game the system allowing them to benefit from the switching off of the presumption. Indeed, Lichfields have suggested that up to 20% of permissions do not materialise into a start on site at all, and a further 15-20% must be re-engineered with another permission sought.

300,000 homes a year is the minimum the Government should plan for in the NPPF, focussing on unaffordable cities in metropolises and the South East to ease the shortage of housing across the country. If adopted it would be impossible to meet the Manifesto promise of building those homes, and local authorities would be able to fail to meet the needs of their residents without consequence. As laid out in the highly influential ‘Housing Theory of Everything’ article, the effects of not building enough range from direct harm like increased housing and commuting costs to downwind effects like it becoming harder for people to have families and reducing productivity overall. Indeed, Professors Enrico Moretti and Chang-Tai Hsieh have estimated that had just 3 American Cities built suitable housing between 1964 and 2009, then its GDP would be 36% higher. We can expect similar results to apply in the United Kingdom. If the NPPF does provide more discretion to local authorities in England to not bear the burden of the house building that we need, then we will be missing the growth that the Government is pursuing to our detriment, as well as continuing to miss out on another opportunity to increase outcomes for the people of this country.

This is not to say there is no merit in some of the proposals. By strengthening the roles of placemaking and beauty in design, there will be a lessening of objections to building that genuinely enhances the aesthetics of an area. However, this has to be combined with clear design codes made at the local level that will provide certainty to developers of what constitutes acceptable design. If these are left to discretion, then it will increase costs of development worsening the effects of the crisis.

Moreover, by encouraging upwards extensions in the form of Mansard roofs housing, as suggested in question 36, supply will be allowed to grow in a sustainable way that allows supply to grow in line with a neighbourhood’s character. Mansard roof extensions are a proven method to support gentle density and deliver new space within our towns and cities. Mansard roofs have been common for centuries in British architecture and are an attractive and traditional way to adapt existing buildings. Modern schemes, like Fitzroy Road in Primrose Hill, show the benefits that could be unlocked if more of Britain’s 4.7 million pre-1918 homes could be sensitively extended upwards.

Currently, the planning system often makes it difficult or impossible to get permission for mansard roof extensions. The language proposed would be helpful in ensuring more favourable treatment for proposed well-designed mansards. The proposed language is especially helpful in discouraging requirements that all such extensions be done simultaneously. It is unreasonable to require such coordination amongst large groups of neighbours, all with different needs, and many residents are defeated by such requirements.

However, these positive reforms do not suffice to overwhelm the harm the changes to the standard method will do. At PricedOut we strongly implore that the Government re-evaluate these decisions, and think again about the harm the housing crisis already exhibits on all people across the country. This move would inevitably take the country further away from delivering sufficient growths in the housing supply making house prices, rents and mortgage payments more, lessening everyone’s disposable incomes and reducing growth overall.