Today the Government finally published the detail of its new National Planning Policy Framework. It is a welcome recognition by the government that we need more homes, and building more homes is good for the economy.
During the messy row over the draft version, Shelter called for the framework to bring about the delivery of homes in the right places, of the right type and at the right price to alleviate housing need. So will it deliver genuinely affordable housing where it is most needed?
First, what is affordable housing? The Government has rejected the recommendation of the CLG Select Committee to retain the current definition of affordability, replacing it with one that is far too weak, and will push the cost of affordable homes further and further away from the reality of local incomes, rents and house prices.
Second, will local planning authorities be required to say how much they will build? On this, like so many other important matters, the framework is ultimately vague. There is a clear requirement on authorities to assess the need for market and affordable homes in the area and identify sites on which they can be built. But rather than setting local targets in their local plans, authorities are only required to ‘illustrate the expected rate of housing delivery through a housing trajectory’. Will this be enough to allow an army of armchair auditors to hold their council to account for delivery of affordable homes?
Third, will affordable housing actually get built? The framework is ambiguous in its attempt to balance viability against sustainability. The definition of sustainable development includes a social role for planning to support a community’s ‘health, social and cultural well-being’: affordable housing could certainly fall under this definition. But the NPPF goes on to say that, to ensure viability, developments should provide ‘competitive returns to a willing landowner and willing developer’ and that the costs of including affordable housing should take this into account. In other words, if including affordable homes in a development wouldn’t provide ‘competitive returns’, then developers won’t have to build them.
This is very worrying. Around half of affordable housing is currently delivered through section 106 planning gain agreements, negotiated by planners with a developer. Letting developers off these requirements if they can claim the returns are not competitive could seriously threaten the supply of new affordable homes. The CLG Select Committee supported us on this, concluding that it could cause ‘an unnecessary war of attrition between developers and authorities’. They recommended that ‘the NPPF make it clear that calculations of viability presuppose requirements to provide infrastructure and other measures necessary to the development, not simply returns deemed acceptable by the developer’.
The framework is therefore disappointing. It’s now down to local planners to get moving and make sure that the need for affordable housing has been objectively assessed and included in their local plan. The authorities who already have a local plan have 12 months to ensure it is consistent with the framework. For the remainder without a local plan, the ‘presumption in favour of sustainable development’ starts from today (although emerging plans will count for something). Without robust local plans, the NPPF’s failure to directly link sustainable development with affordable homes means the millions waiting for a decent place they can afford may have to wait a very long time.