Proposed changes to the National Planning Policy Framework include some welcome ambitions but do not go far enough, writes Matt Mahony, policy and public affairs manager at the Construction Industry Council
CIC members play a vital role in regenerating towns and cities, delivering vital new skills and working in partnership with local authorities, businesses and housing providers to build and refurbish new homes.
We presented an overarching response to government on the new draft National Planning Policy Framework (NPPF) that reflected our members’ perspectives of what works best to provide much-needed housing that is well designed, well-constructed and safe, while building strong communities through excellence in place-making.
CIC’s view is that it is vital to boost housebuilding, including much-needed affordable housing, and we welcome the new government’s ambition.
To that end, we are supportive of many of the proposed amends to the NPPF in parallel with other measures that could bring about a boost to housebuilding, including the setting up of a New Towns task force, the Homes England Housing Accelerator scheme, the new emphasis on cross-boundary cooperation and plans to encourage mayors to play a major role in undertaking strategic planning.
CIC also welcomes the return to mandatory housing targets and a new focus on design codes in areas where greatest change will be seen.
NPPF cannot deliver on its own
Unfortunately, the NPPF as proposed will simply not be able to deliver on its own and there is a real risk that without other policy interventions around skills and social housing, government will fall well short of its ambitious housing targets.
Additional grant funding must be made available to support plans for developers to provide more affordable and social rented homes. The speculative model of housebuilding, based on build-out rates and profitability, will not be enough to meet the new targets on its own. To complement this, SME housebuilders and developers – particularly vulnerable to uncertainty – must be supported with knowledge transfer networks and a steady pipeline of work.
Upskilling to meet the targets is one of the most pressing concerns and at the heart of this is the fear that we will need to produce more with less. The uplift of hundreds of thousands of additional new dwellings proposed over the next five or so years contrasts with a growing skills shortage in construction that has been exacerbated by the age profile of our domestic workers – many of whom are near to retirement – and by a number of EU-born workers leaving.
This issue affects the professionally qualified as well, given the time needed to train new professionals and the need to negotiate immigration requirements. CIC supports a pragmatic, evidence-based approach to migrant workers that can be coupled with a comprehensive skills plan for our domestic built environment sector workers.
Government has pledged to work closely with the Migration Advisory Committee but, as it stands, putting arbitrary limits on skilled immigration on key roles before a plan for upskilling beds will stifle economic growth.
Built environment SMEs in key areas such as planning, architecture and the landscape industries may suffer as key roles risk being unfilled.
In the public sector, government’s proposal to hire 300 planning officers to “get Britain building again” will replace less than a tenth of the planners who have left public service and roughly equates to one planning officer per department.
Quality concerns
Even if the housing targets are met, there is a concern about compromising on quality. CIC has continued to underline the need for high quality development and to ensure that we strive for excellent sustainable placemaking.
Unfortunately, the NPPF does not address concerns regarding poor quality that can result through housing created under Permitted Development Rights (PDR). With such urgency to increase numbers there is a worry that new substandard homes could be created.
Government is bound by existing legal obligations under the Climate Change Act and the Labour manifesto pledge to move to a more circular economy.
Building to an ambitious new Future Homes Standards must be supported within the new NPPF from adoption together with further provisions to support climate resilience. This would include the adoption of blue-green infrastructure measures such as SuDS, which can help address the implications of a changing climate.
The previous version of the NPPF failed to adequately incentivise development which repurposes or reuses buildings and bolstering this part of the draft framework could be a vital tool to deliver more dwellings through retrofitting, improve design solutions and dramatically reduce waste and carbon emissions.
More support needed in tandem with NPPF changes
In summary, we are hugely supportive of government’s ambition to create 1.5m new homes and we back many of the changes that are being proposed across several fronts.
Notwithstanding that, we are concerned that too much heavy lifting relies on the private sector and market forces. We hope the upcoming Budget will allocate more funding for affordable housing.
There are many strands of housing policy yet to developed by the new government but speed in setting the new NPPF guidelines is essential now that the consultation has closed.
