Comment

Planning for the Future of Housing: Labour’s progress at the 100-day mark

Following Labour’s election win in July we released ‘From Scarcity to Stability: Planning for the Future of Housing’, a paper calling on the Government to prioritise solving the housing crisis. As we race over the 100-day line, we asked experts from across our services how it’s going so far.

In ‘From Scarcity to Stability: Planning for the Future of housing’, we set out our plan for the new Labour Government, outlining recommendations to help significantly boost the supply of housing, remove the barriers to development that have marred the housebuilding sector in recent years and provide certainty for an industry that is crucial to our economic growth. Looking at what we said Labour should do, what they’ve done, and how it’s going, co-owners from our Planning, Economics, Business Cases and Funding, Strategic Communications, Design and Heritage, Townscape & Landscape teams give their views on Labour’s first 100 days in housing and planning policy.

A positive new approach to assessing housing need

We reiterated our earlier call for a new standard method of assessing housing need shortly after the election, so were glad to see this feature amongst the reforms proposed only weeks later. We were particularly heartened to see the Government embrace the stock-based approach that we have long advocated, due to its simplicity and inherent fairness. Removing the ability to argue for lower levels of need should lead to more ambitious housing targets in many parts of the country, especially where the draft NPPF still positively allows for the setting of higher housing requirements to reflect economic growth ambitions with their impact on housing need therefore still having to be considered as Local Plans are developed.

Positive changes but more clarity needed

Whilst Labour’s proposed amends do set out a positive change, there are a few areas where we need further clarity in order to really start delivering the new homes that we need. This includes:  

• Transitional arrangements – clarification around how these arrangements apply to two-part plans outside of London is needed, as there are currently different interpretations of this. Clear guidance is necessary to ensure that the impacts of the new NPPF are considered in the plan-making process as early as possible.  
• Approach to Benchmark Land Value – there is concern across the industry that the proposed interventions outlined in Annex 4 of the revised draft NPPF will further delay development, rather than accelerate it. An alternative approach should be considered by the Government, and we welcome their close attention to this, as outlined at the Labour Party Conference.  

We need transparent criteria for identifying new town locations

The long-term vision for New Towns presents a significant opportunity to drive strategic economic growth and housing delivery beyond this Parliament for communities of "at least 10,000 new homes each, with many significantly larger". While it is understood that the recently formed New Towns taskforce will develop a shortlist of 12 locations within the next 12 months, the identification criteria remain unclear. This lack of clarity often leads to speculative efforts and considerations among private investors and strategic landholders. A transparent methodology and criteria for identifying these locations will help both the public and private sectors focus resources where there is a genuine need with best outcomes and impacts, drawing on the previous experiences of the “Alternative Development Patterns: New Settlements” (1992) report and the Lyons Housing Review (2014), and other initiatives since the 1946 New Towns Act, such as EcoTowns (2007). 

Brownfield first presents an invaluable opportunity but clarity is needed

The Labour Party's commitment to "brownfield first" presents an invaluable opportunity to tackle challenging sites and remediate land for housing. However, this process relies on public sector forward funding to catalyse private sector investments. Currently, access to public funding sources remains unclear, although new Brownfield round funding has been announced this week. There is a need for clarity around brownfield development support that is available to instil confidence within the private sector to reinvest and bring forward these challenging sites. The New Homes Accelerator Programme and call for sites offer a potential opportunity to unlock viable largescale housing developments facing delivery challenges. The objective of this programme is to support stalled projects which are viable. However, the criteria for site prioritisation and the exact nature of support remain unclear at this point. Given the complexity of delivering large-scale housing and region-specific challenges, prioritising only viable sites may not yield the best outcomes in terms of unlocking sites where it is needed the most.

Planning reform is an important litmus test

Politically, all has not been smooth sailing for the new Government in its first 100 days. However, in many departments, including Housing, Communities and Local Government, reform is already well underway. The consultation on the proposed changes to the NPPF has received over 10,000 responses and legislation will be brought to the house later this year. As perhaps the most politically challenging and controversial manifesto commitment made to the electorate, planning reform will be an important litmus test for the Government’s appetite to deliver on its manifesto commitments at a time when its mandate is strongest.

Numbers are important but so is good design

Within the specific design guidance contained in the draft NPPF, one of the most talked about has been the update to Chapter 12 and the removal of the subjective concept of 'beauty' in favour of ‘well-designed places and buildings’. Authority wide Design Codes no longer feature, but the imperative for high quality design remains. Although much of the focus has been on housing numbers, it will be important to ensure that moving forwards the Government is clear on expectations regarding good design and give local planning authorities the tools and resources to deliver on the ground.

We need definitions on the Green and grey belt

The potential for the development of Green Belt land has become a significant talking point during Labour’s first 100 days in office. The proposed slight adjustment to para 154(g) is a subtle change that has the potential to open the way for more brownfield development that had previously struggled to meet the high bar of openness tests. Landholdings are being reviewed against the draft NPPF definition for ‘grey belt’ and supporting criteria provided in the NPPF consultation document. As a concept this has the potential to deliver transformational change. This feels like a significant step in terms of unlocking Green Belt land that is no longer serving its intended purpose. However, what is missing in the draft NPPF, is clarity around this definition and how to interpret it. Whereas talk before the election focused on poor quality areas of Green Belt, the quality or condition of the landscape is not part of the current definition. Further clarity is needed to allow Green Belt land to be consistently assessed, and ‘grey belt’ land identified for appropriate development in the most sustainable locations, whilst preserving areas of important landscape.

Concluding thoughts

The Government had intended to have a new NPPF in place by the end of October 2024; however, due to the number of responses received to the consultation, this is unlikely. Matthew Pennycook has outlined that the Government are working their way through the consultation responses to “ensure we get these vital reforms in place before the end of the year”. However, at the Labour Party Conference it was suggested that it may be delayed until the new year. Watch this space.  

Whilst this may not be as quick as we’d like, it is important to get it right, and it’s clear that we are moving in the right direction with planning being front and centre of the new Government’s agenda to support the growth imperative, with, we expect, more details to follow in the imminent Budget.

For more information, please contact Tim Burden or a member of the team.

17 October 2024