NPPF & Social Housing Provisions

The updated National Planning Policy Framework (NPPF) is a step in the right direction for tackling the supply side of housing provision. However, planning reform alone will not solve the housing crisis nor address the supply side effectively.

Assuming, the targeted benefits of the NPPF can be realised and the planning process becomes more predictable (with all Local Authorities having workable Local Plans) and the application process speedier, there are other challenges on the supply side which need to be addressed still, including:

  • Affordable Housing Funding Model: Much more money is required than the central government has historically offered – and perhaps much more than the government can afford in the foreseeable future.

  • Affordable Housing delivery route: The over-reliance on the private sector to deliver affordable housing via the S106 planning agreement is (on its own) ineffective in dealing with the scale of the housing crisis. Local authorities will need to be enabled by central government to use their available land assets to deliver affordable housing – with particular emphasis on Social Housing. It is through the provision of Social Housing, at scale, that Local Authority burdens with temporary accommodation costs will be addressed.  This requires investment!

Whilst it may be convenient to hide behind the financial viability cloak with respect to having a clear and unambiguous target for Social Housing (which the NPPF is regrettably silent on), it is false economy.

In the latest Ministry of Housing, Communities and Local Government (MHCLG) figures, councils spent £2.29Bn on temporary accommodation from April 2023 to March 2024.  That was nearly £400M more than in the previous year and the expectation is that that bill can only increase into the future, except Social Housing provision at scale is addressed.

In 2023 there were nearly 108,000 households living in temporary accommodation, more than double the 2011 levels. And there are now over 1.1 million families on Social Housing waiting list!​

Beyond the significant expenditure on temporary accommodation, the poor social, economic and environmental outcomes for families who are forced to stay in B&Bs and other forms of temporary accommodation (which are usually of poor quality) should be a matter of serious concern.  We have all seen the stories.  

So, the demand side of Social Housing seems pretty clear, and the question is: How effective will the NPPF, Spring 2025 spending review and other government initiatives be in addressing this mammoth challenge? Sadly, this is where my current optimism ends as it is impossible to see a clear path in the government’s initiatives which leads us to turn the tide on the housing crisis – the core of which is the lack of social housing.   

My projections of Social homes that are likely to be delivered based on the government’s overall target of 1.5 million homes in this parliament, or circa 373,000 homes per annum tells the story of how much of our housing crisis would have been addressed at the end of this parliament.

It will take us over 20 years to turn the tide in addressing our housing crisis with the likely rate of social housing provision except massive investment is injected into social housing delivery and the most sensible way to do that currently is via Public-Private Partnership. We need to bring in ready, private sector investment, to deliver at scale and halt the ballooning temporary accommodation bill.

So, that is the crux of our challenge, but that is not diminishing the importance of the demand side of market housing (sale & rent). Unshackling this also should in fact be an integral part of the housing solution – especially given that housebuilders and developers will continue to contribute significantly to our overall housing delivery.

By addressing the demand side for market rent and market sale housing also, we will be unlocking the social housing provisions linked to these developments through the current s106 system (or its future alternative).

These are key considerations for addressing demand side:

  • Location and connectivity: We need to build where people want to live.

  • Infrastructure/facilities/amenities: Our housing strategy needs to be supplemented by the infrastructure bill due in Q1 2025. We need to create communities. It is good that the government’s New Towns initiative will also address this.

  • Affordability: We need to address high build costs driving up prices/rents. We also need to address how our mortgage system works.

  • Wages: We need to address the low wage syndrome and the poverty line this puts tens of thousands of families, making social housing their only viable option for affordable and decent housing

By having a joined-up approach, we can actually achieve lower demand for social housing – facilitating alternative options for some who would otherwise depend on Social Housing; increasing housebuilding volume and therefore overall affordable homes provision (and therefore social rent provision); supporting Local Authorities to build direct (filling in the gap on locations developers may not wish to build and providing additional social housing as a result).

The aspiration to build 373,000 homes per annum will mean very little if it does not address the social housing deficit costing Local Authorities £Billions annually. If we are unable to have a clear plan and path to finally solving this crisis within a decade (i.e. 2034), then we should be asking the question, why not? 

We all await the spending review coming up in spring 2025 and no doubt along with other policy statements.

In the meantime, speak to us about your viability, Joint Venture and buildability challenges. We are always at hand to assist.

’Kunle Awofeso

Director - Airey Miller

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