Featured image: Bristol CLT
On 12th December 2024 the government published the revised National Planning Policy Framework. This follows from a period of consultation, where the CLT Network coordinated and submitted a network wide response to the 2023 revisions.
See the government’s full response to the consultation responses here and the 2024 revised NPPF here.
The National Planning Policy Framework (NPPF) sets out the government’s planning policies for England and how these are expected to be applied at the local level. This, therefore, is an important place for CLTs to campaign for changes that can make delivery of homes and community spaces easier, both as community-led organisations and also as small scale housing providers or developers.
The CLT Network’s 2024 response built on and refined the 2023 revisions, which saw CLTs and other types of community-led developments recognised and supported for the first time in national planning policy with:
- a definition of Community-led development
- requirements for local policies to be supportive of community-led development
- our long lobbied for community-led exception sites policy.
The key areas of our consultation response included small changes to the definition of community-led and affordable housing, expanding the terms around Community Led Exception Sites and changing requirements around being a Registered Provider of Social Housing. See our 2024 NPPF consultation response in full here.
In addition to this consultation response, CLT Network members have also been lobbying their MPs with our policy and funding proposals to significantly increase the contribution that CLTs can make to national housebuilding targets. See our policy proposal briefing for MPs in England here.
CLT Network Response
The CLT Network welcomes some of the recommendations that the revised NPPF makes, although sees space for further revisions to support CLTs to deliver more affordable homes more effectively.
CLT Network CEO, Tom Chance, commented:
“The new NPPF picks up many of the suggestions the CLT movement has been making in recent years. It tidies up and clarifies definitions of things like community-led development, and affordable housing, in ways that should help CLTs and other community led developers.
“One immediate opportunity is to ask planning authorities to introduce a local policy on community led exception sites. These could raise the size cap to enable more ambitious proposals, clarify whether land for non-housing uses (like open green space) count in the size cap, and clarify that these exception sites can be for mixed-use assets including homes, workspace, green space and more.
“However, the government has kicked the can down the road on the bigger reforms needed. It acknowledges that policies like ‘small sites’ are not working. But in its response, and in our discussions with officials, we are not convinced there is a recognition of why the risk, cost and delay in the planning system creates a barrier to community-led developers, self builders and SMEs.
“We’ll be continuing to talk to officials and lobby the minister for a more radical set of reforms to follow next year.”
In relation to the CLT Network’s specific asks, which you can see here, here is what the government has said and done.
The definition of Community-led – the changes are welcome and follow issues that we and others have raised since the 2023 definition was introduced, particularly broadening it out so it captures all forms of development (not just housing) and all kinds of community led organisation (not only those originally set up for housing).
Community-led exception sites – we hope local planning authorities will now use the flexibility to raise the size cap for these, but we’re disappointed there were no other changes to clarify the policy (e.g. how it relates to and differs from rural exception sites), nor to apply it to sites within settlements.
Small sites – it is very disappointing that the government has not made any changes to facilitate small sites, or create more opportunities for communities in large sites.
Social rent – it is very positive that the NPPF now clearly requires planning authorities to consider the need for this tenure separate to other affordable tenures, distinguishing it from ‘other affordable housing for rent’ which is often not affordable to those most in need.
Affordable rent definition – it is disappointing that the government has now consulted twice on whether to reverse or adjust the requirement – introduced in 2018 – for providers of low rent homes to be registered providers, and has again declined to make any changes. This policy excludes many small community-based providers, and ties the hands of planning authorities that have previously been willing to support this additional supply.
Tenure mix – it is welcome that the government has removed the overly prescriptive requirements for First Homes or other affordable home ownership tenures. The tenure mix for any particular site should follow local evidence of need, not a national formula.
Rural affordable housing – it’s frustrating that no significant changes were made, given years of underdelivery, but positive that they intend to return to this topic including with a potential National Development Management Policy.
Health – it’s positive that paragraph 96 now references the importance of social interaction and inequality in relation to health, but the examples illustrating how planning can address these again leave out any mention of Public Health England’s guidance on promoting community voice and agency, for example in the way developments are designed and stewarded.