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The Journal of the London Planning & Development Forum Issue 136 January-March 2026.

LEADERS page 5 MALLETT page 7 FINCH page 12 ¡PILLO! page 41 PLANNING PERFORMANCE p42 ROGERS page 48 LP&DF page 46

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Celebrating over 20 years of Hellman’s cover cartoons see page 8; BRIEFING: The Planning and Infrastructure Act, analysis and opinions page 28; New NPPF, Rachel Clements & Matthew Spry of Lichfields page 29; New NPPF analysis and opinions page 32; Can we create a bedroom bonanza? Nicholas Boys Smith page 58; Shaping the World: Imagination in place-making, Farrell’s Peter Barbalov page 73; Helping first time buyers, Adrian Plant page 62

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CONTENTS

PiL136 CONTENTS PAGE 5 LEADERS Planning enables, it doesn’t deliver; Measures that ensure nothing will change soon 7 LEE MALLETT New kinds of suburbia

Tribute to Louis Hellman page 7

8 TRIBUTE TO LOUIS HELLMAN King of cartoonists to retire 11 Murray for Mayor 12 PAUL FINCH More haste, less speed

Pragmatic approach to the housing crisis | Olivia Harris p 20

OPINIONS 13 Speed up the speeding up of planning | Jason Lowes 14 Predictions 1 | Tim Foreman 15 Predictions 2 | Lawrence Turner 18 London housing emergency measures | Simon Ricketts 20 Pragmatic approach to the housing crisis | Olivia Harris 21 The use of AI in environmental assessments | Alistair Walker 22 Gateway 2 delays | Sarah Rock 24 The latest on viability | Andrew Golland 26 Green belt release and affordable housing | Chris Hemmings 27 Take-up and implementation of BNG | Richard Holliday 28 BRIEFING The Planning and Infrastructure Act | Analysis and opinions 29 New NPPF | Rachel Clements & Matthew Spry of Lichfields 32 New NPPF | Analysis and Opinions 34 LETTERS from Professor Michael Edwards, Bartlett School, UCL; Professor Paul Cheshire LSE & Professor Ian Gordon, LSE

ANDREW ROGERS Planning quiz for 2026 page 48

39 CLIPBOARD: Consultation on changes to VAT treatment of social housing sites welcomed; New land policy changes in the UK; £360m job at Euston; Government launches consultation Continues into statutory consultee process; AI-nimbyism next page >>>

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pil136 January-March 2026

CONTENTS CONTINUED

41 ¡PILLO! Where is ‘The Environment’? When will the ONS data debacle end? Pedestrianising the public realm; Third runway: government backs Heathrow; Not the epitome of global cool; A bit of self-indulgence

>>>

Tottenham Court Road

42 PLANNING PERFORMANCE The number of applications made and decided continues to slide from the same quarter last year 46 LONDON PLANNING & DEVELOPMENT FORUM 47 Placemaking not Plotting, 48 Jumpstarting house building and SME delivery in London, 52 Camden High Street upgrade, 54 Update from the parliamentary select committee 48 ANDREW ROGERS Planning quiz for 2026 FEATURES 58 Nicholas Boys Smith | Can we create a bedroom bonanza?

“Now Keir also has his own ‘jungle’ to rival that in Calais”. ¡Pillo! page 41

62 Adrian Plant | Helping first time buyers 65 BOOK The Manifesto House | Owen Hopkins 69 PLANNING AND ENVIRONMENT REFERENCE GUIDE 72 SUBSCRIPTION ORDER FORM 73 Shaping the World: Imagination in place-making | Peter Barbalov 77 ADVICE

Publishing Editors: Brian Waters, Paul Finch and Lee Mallett editor@planninginlondon.com, planninginlondon@mac.com ISSN 1366-9672 (PRINT) ISSN 2053-4124 (DIGITAL) ISSUE 136 JANUARY-MARCH 2026 www.planninginlondon.com

The London Planning and Development Forum (LP&DF) The LP&DF was formed in 1980 following an all-party inquiry into the development control system. It selects topics to debate at its quarterly meetings and these views are reported to constituent bodies and published in Planning in London. It is a sounding board for the development of planning policy in the capital, used by both the public and private sectors. Agendas and minutes are at www.planninginlondon.com To attend please email EDITOR@PLANNINGINLONDON.COM

Planning in London

Editorial, subscriptions and advertising: Tel: 07957871477 Email: planninginlondon@mac.com Contents ©Land Research Unit Ltd or as stated

Chairman: Brian Waters MA DipArch (Cantab)DipTP RIBA MRTPI ACArch ppACA FRSA Principal: The Boisot Waters Cohen Partnership – brian@bwcp.co.uk Vice-Chairmen: Riette Oosthuizen HTA Design: riette.oosthuizen@hta.co.uk and Brian Whiteley Brian.Whiteley@planningaid.rtpi.org.uk

Member bodies Association of Consultant Architects Planning Officers’ Society/Association of London Borough Planning Officers London Councils British Property Federation Design Council CABE City o London Law Society

The Manifesto House | Owen Hopkins page 65

Available only on subscription: £99 pa Provides a licence for five copies by email See subscription form or buy online at www.planninginlondon.com. Planning in London is published quarterly in association with The London Planning & Development Forum by Land Research Unit Ltd, Studio Petersham, Gorshott, 181 Petersham Road TW10 7AW

Contributors write in a personal capacity. Their views are not necessarily those of The London Development & Planning Forum or of their organisations. Correspondence and contributions are invited for consideration. The editors reserve the right to edit material and letters supplied.

Confederation for British Industry DLUHC Design for London/ Urban Design London Historic England Environment Agency Greater London Authority Home Builders Federation Landscape Architecture SE London Chambers of Commerce & Industry London Forum of Amenity Societies London Housing Federation National Planning Forum ICE, RIBA, RICS, RTPI, UDAL, TCPA Transport for London London University (The Bartlett, UCL) University of Westminster

Affiliated members: Planning Aid for London London Metropolitan University

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LEADERS

Planning enables; it doesn’t deliver Historians will ponder what turned a country that liked housebuilding into one that seemed opposed to it

Planning in London has been published and edited by Brian Waters, Lee Mallett and Paul Finch since 1992

Endless changes to the National Planning Policy Framework since it was created, itself intended to cut out systemic delays in the planning system as a whole, have by definition not worked. Or at least if the measure of success is the number of dwellings being delivered. Unfortunately, the latest changes look like the result of displacement activity on the part of politicians who seem incapable of answering a simple question: who exactly will deliver 1.5 million net additional homes by the end of this government’s first (and possibly only) term? Will it be local authorities, many of which seem incapable of producing Local Plans, let alone delivering housing? Will it be the house-building sector, with its proven track- record of market failure on an epic scale? Will it be City of London financiers, with their siren call for more build-to-let, where you pay rent for 25 or 30 years but end up with no real property asset? In London, will it be the Greater London Authority, which has built zero homes – a disgraceful history which insults the huge programmes administered by its predecessors, the London County Council and the Greater London Council? Will it be Homes England, which appears constitutionally incapable of actually building anything as a direct client, instead acting as a form of sewerage system for billions of pounds flushed from Whitehall for redistribution, to no great effect? The current government, like its predecessor, seems to have little idea of how to proceed, other than pretending that it is the ‘planning system’ which is responsible for housing supply shortage. Neither has offered any explanation as to why this system enabled the construction of millions of homes in every decade since the last four. That is because politicians will never admit that the political class is responsible for anything other than success. Historians will ponder what turned a country that liked house-building into one that seemed opposed to it, with the concomitant and inevitable inflation of house prices, rents, and shortages made even worse by decades of more or less uncontrolled inward migration. By contrast, our transport planners have done an excellent job, especially in London. Perhaps that is because trains and buses are easier for politicians to understand than the world of property. Incidentally, all that useful transport was enabled by exactly the same planning system that is supposedly unfit for purpose. >>>

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pil136 January-March 2026

LEADERS

Measures that ensure nothing will change soon >>> The NPPF

continues to ignore the basic error of expecting the private sector to pay for affordable provision

Planning in London

A singularly depressing discussion took place at December’s London Planning and Development Forum looking at ‘Measures to kick-start house-building in London’ which the latest revisions to the NPPF seem unlikely to relieve. We are now down to less than 5,000 annual starts in 24-25, down from 20,000 only two years ago. And we’ve all read about local authority budgets eviscerated by temporary housing costs. There is an inverse relationship between housing starts and housing targets. London’s target of 90,000 a year from 2028 onwards is currently an incredible fantasy. Populism thrives on such gruel. Politicians must expect trouble, which their ignoring of reality has contributed to. While the ‘default yes’ for station-orientated developments mentioned in the changes to the NPPF will help, they do not address the fundamental lack of viability which has almost stopped delivery and killed off SME developers. Other levers pulled recently to encourage delivery, changes to the threshold approach, temporary CIL relief, increased Mayoral powers, changes to design guidance and adjustments to cycle parking requirements, are likely to prove ineffectual, according to planning consultant Boyer (see our Forum report from page 46), in encouraging more delivery over the next three years. Stories abound of developers renegotiating S106 deals, and of housing associations, in the same financial boat as developers, refusing to acquire those affordable units that have been built. Especially where inefficient numbers have been provided. The consequences have been looming for five decades. The 1970s and 80s were in hindsight a golden period for small and medium sized developers who proliferated. Some like Berkeley, Redrow and Persimmon originating then have grown into today’s giants. But our national delivery of homes peaked when the number of SME builders was at its highest. Land was cheaper, finance was available, and planning was simpler. Today SMEs account for a mere 10% of the UK’s housing, perhaps less in London. As Pocket Living’s communications director put it to the Forum, from the 1990s on ‘policy makers treated housebuilding like a shopping trolley they could keep adding to’. A tsunami of legislation and taxes has wiped out SMEs’ interest in delivering homes. Recently there has been a £1m drop in returns from a typical ninehome scheme, eliminating what was a £700,000 (21%) profit four years ago, replacing it with a £340,000 loss today, Pocket estimates. No wonder little development is happening. But a trans-party consensus may be emerging about the solution. Colin Wilson, Southwark’s head of regeneration for Old Kent Road, was crystal clear in his message to the Forum which is that all layers of Government by pursuing affordable housing policies that tax development are effectively saying the shortage of affordable housing is ‘not our problem’. The disregard for the realities and abnegation of social responsibility for provision of a key element of national infrastructure is no longer tenable and the NPPF continues to ignore the basic error of expecting the private sector to pay for affordable provision. They won’t because they can’t. The state’s underfunding of social housing has become a national scandal, and if you don’t know the cause you mistakenly blame planning or developers. Wilson summarised what half a century of being let down by politicians on housing policy, especially in London, means: ‘It has become a threat to the world we enjoy living in.’ n

OPINION: NEW KINDS OF SUBURBIA | LEE MALLETT

MALLETT

New kinds of suburbia Visions are driven by design, not just the need to build houses, but to build denser communities and make better use of our wasteful suburbs, says Lee Mallett People negotiating planning in the capital seem doubtful recent measures to ease tax and complexity burdens on builders and developers will deliver any noticeable change to annual housebuilding numbers anytime soon. Longer term thinking is also needed. Increased density being the nub of most opposition. Take Islington’s density for example, one of London’s most densely populated boroughs. It saw a 14% increase in its population from 180,000 in 2001 to 206,000 in 2011. This equated to an increase in density from 120 people per hectare (PPH) to 139 PPH within the borough’s 15 sq kilometres. In the 2021 Census this increased by a much lower 5.1% to 216,000 – which could reflect decreased opportunity, difficulties in getting permission, decline in viability, unfavourable policies. Or all of these. Waltham Forest is much less densely populated as you might expect. But it has become increasingly popular, with affluent immigrants, many funded by the West London Bank of Mum and Dad. It’s population in 2011 was 258,000 – a whopping increase of 60% over the Census of 2001, but equating to a density of only 67pph, within a borough of 39 square kilometres - more than twice as big as Islington. In the 2021 Census the population had risen by a mere 7.8% to 278,000, a drastic reduction from that 60% increase seen between 2001 and 2011. We could still reasonably conclude without too much research, however, that Waltham Forest probably has a lot more remaining opportunities to increase its capacity for new homes than Islington, and it has the advantage of bordering the Lea Valley on its western edge. London is not a dense city. It could accommodate much more housing in its slightly shabby suburbs and ease pressure on the Green Belt. The wasteful ‘plotting’ of housebuilders which squanders land on car parking and underused private amenity (big parking aprons, underused rear gardens) at the expense of what could be more resilient and sustainable shared amenity has been pointed out, as has the need to ameliorate the car’s baleful tyranny.

www.planninginlondon.com

But if there are two things certain to ignite vocal local opposition, it is any threat to increase housing density, or reduce on-street parking. We need persuasive visions of how to do this which are widely publicised. Architects HTA have form here. In 2015 the practice ran an appealing campaign attempting to persuade local authorities to consider ‘Supurbia’ – a denser form of suburban blocks of terraced housing liberated by a more relaxed planning regime encouraging back garden and rooftop extensions within a given neighbourhood block. A worthy idea, because it might incentivise owners to sell and realise gains, and small developers to pile in for similar reasons. But it won little traction. HTA’s Ben Derbyshire PPRIBA and former Government Head of Architecture Andy von Bradsky have re-entered the lists with a report to MCHLG, Placemaking Not Plotting, which argues for a new generation of sustainable suburbs that eschew the housebuilder’s wasteful and uninspired approach to the quality of urban and architectural design. The report suggests new approaches to densification can be driven by design codes that make places, not simply deliver plots. An increase in density helps pay for better design and more amenity, encouraging better places. It is an approach that has been pursued in greater detail by Clerkenwellbased architects Metropolitan Workshop – which was joint winner of the RIBA Wates Build to Rent competition in 2012. Metwork was inspired to develop, research and implement a ‘Homestead’ concept now featuring in several of the practice’s surburban schemes. The Homestead is a framework for a neighbourhood block that can be flexed for density, tenure and home type. It offers greater shared amenity and fosters greater social opportunities.

These are the visions that will eventually deliver the housing London needs by renewing and reinventing suburban neighbourhood blocks – possibly overcoming local opposition. They are driven by design, not just the need to build houses, but the need to build denser communities and make better use of our wasteful suburbs and to build what Metwork call A New Kind of Suburbia. We need a campaign to explore these ideas with a strong visual campaign to win hearts and minds. You can read about these two sets of ideas here: Placemaking Not Plotting: https://www.hta.co.uk/ publications-post/placemaking-not-plottingtowards-a-new-generation-of-sustainable-suburbs/ A New Kind of Suburbia: https://metwork.co.uk/ research/a-new-kind-of-suburbia/. n BELOW: A ‘Homestead’ concept developed by Metropolitan Workshop for French energy supplier Engie

pil136 January-March 2026

TRIBUTE TO LOUIS HELLMAN

King of cartoonists to retire Louis Hellman, Planning in London’s resident cartoonist is retiring. We pay tribute to the power of Louis’ pen – and the endless opportunity for satire that planning affords

Planning in London

Louis Hellman The world according to a Hellman is usually a dystopia of venal developers, cynical architects, defeated planners, hopeless politicians, and a long-suffering public, victims of all of the above. Yet within the dystopia there is a Utopian trying to get out. The cartoonist invites us to ask not only ‘Why are things like this?’ but also ‘Do they have to be like this?’ What could things be like? The function of the cartoonist is not merely to amuse, but to provoke, to embarrass and occasionally to infuriate. This is a surreal world but closer to the real thing than we might like to imagine. When he received his MBE from the late Queen, Hellman was wrongly announced to her as receiving his award for services to agriculture. He said ‘Actually it is for architecture’. The Queen responded: ‘And what do you do?’ Hellman: ‘I satirise it’. A noble calling, exercised since the 1960s, not least in respect of Planning in London covers. This issue sees the last of them as Louis has more than earned the right to retire . . . with the thanks of all the Planning in London editors. This dystopia shows no sign of vanishing! – PF n

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www.planninginlondon.com

pil136 January-March 2026

TRIBUTE TO LOUIS HELLMAN

>>>

Planning in London

MURRAY FOR MAYOR

Murray for Mayor I will ensure the role of the built environment sector in shaping a better city is understood and show how its strengths can deliver a more equitable, healthier, safer and successful London, says Peter Murray I first started thinking about a political role during the Mayoral election 2020. NLA had tried to organise a hustings of the leading candidates in conjunction with the RIBA, RTPI, CIOB, CPA and numerous other organisations, reflecting the breadth and strength of the built environment sector. Sadiq refused to take part, so all the other candidates followed his example. Instead, we had a debate with their deputies, and I was appalled by the level of ignorance about the significance of design, construction, and development in delivering the Mayor’s major projects, including infrastructure, transport, housing, planning, culture, and the environment. My experience as a board member of Be First, Barking and Dagenham’s housing and regeneration company, inspired me and showed that, with the right entrepreneurial spirit in the public sector, positive change is possible. In 2024, Barking & Dagenham topped Inside Housing’s list of Biggest Council House Builders, and a year earlier was ranked joint first in the DLUHC Planning Performance Tables for on-time major and non-major decisions. It had a design department that did inspiring work both on commissioning new award-winning buildings and public spaces, and on ideas for pattern books and modular construction. Like everywhere else, high interest rates, raging inflation, and increasing regulation derailed progress, and it was back to the drawing board for a methodology that had proved so successful in the early days of the company. It was a powerful lesson on the need for a flexible approach to delivery that is able to respond to events. A conviction that London needs a City Architect added further impetus to my Mayoral bid. Lord Richard Rogers was the de facto London City Architect to Ken Livingstone at the birth of the GLA and the key inspiration of the first London Plan. This was based on Rogers’ ideas of the compact city with good public transport connections to opportunity areas on brownfield sites and development taking place within the GLA boundaries. It is a strategy that has held good until now. In considering how London's growth has been, in the main, successfully accommodated over the last 20 years, I look back to the 1986 Royal Academy exhibition ‘New Architecture: the work of Foster Rogers Stirling’, which I organised with Deyan Sudjic. You can see there the beginnings of Rogers’ thinking around public spaces and the shaping and improvement of cities. We need that level of strategic thinking about shaping London at City Hall today.

www.planninginlondon.com

I have visited a wide range of cities to study the role of design in urban planning from Bangkok to Medellin, Singapore to Toronto, Riyadh to Tirana, Prishtina to Copenhagen. In November, I attended a get-together of City Architects from across Europe organised by the Danish Government in their role as President of the Council of the EU. They came from places like Stockholm, Vilnius, Bratislava, Aarhus, Warsaw and Malmö. Much of the discussion was similar to what we've been having at NLA for the last decade or so, but the big difference was that these City Architects are sitting at the top table. In contrast, over the 25 years of the Greater London Authority, the role of design has dropped down the agenda from the days of the Architecture and Urbanism Unit, which was central to Livingstone's environmental policies, and Peter Bishop heading up design at the LDA to a much reduced Design for London under Boris and then the appointment under Sadiq Khan of Design Advocates (of which I was one). The advocates do a great job, but they are advisory; outside the pen, they respond to rather than set strategic goals. Stepping back from NLA in 2024 allowed me to take a more critical stance on the role of City Hall. The next Mayor’s number one project must be the delivery of more of the right kind of housing. How can we have an equitable city when over 160,000 people are in temporary accommodation? How can we have a successful city when young people can’t afford to live here? To propose solutions to these issues I will bring together the great minds across our sector, from investors to designers, from planners to developers, from communities to construction workers, to respond to government policies and changes in the market with innovative thinking. To do this and help shape wider policies, I will engage with members of the sector over the next year as we build up to the election in May 2028, organising roundtables and visiting the offices of those in the industry who have ideas they'd like to put forward. I will set up a shadow cabinet of young, diverse Londoners who are keen to be engaged in the political game. I’ll stand as an independent candidate so that I can engage with boroughs and governments of all colours. A lack of pan-London collaboration has meant we have failed to deliver modular housing at any scale. One of the key elements of the Farmer Report is that London cannot scale off-site construction without a visible, long-term pipeline of demand, and that individual developers acting alone cannot provide this. Farmer has argued that London’s public-

sector clients (boroughs, housing associations, TfL land, GLA programmes) must act collectively, because together they represent one of the largest and most reliable sources of housing demand in the UK. These discussions with the industry will be set within a context of delivering Net Zero, promoting active travel and car-light city strategies, designing a healthier city for 8 to 80: a child- and age-friendly city, convening an Urban Futures Commission to shape a long-term vision that ensures our children and grandchildren will inherit a liveable London. I do believe London is the greatest City in the world, we come top of the rankings in a range of polls on economic strength, cultural influence, connectivity and financial sector power but we have a way to go to improve liveability. Recent research by NLA, aggregating the economic impact of the built environment sector, shows that it should have much greater political clout than it currently does. It supports approximately 3.8 million jobs, equating to about one in eight jobs in the UK workforce and it is twice the size of the financial sector. Leading up to the Mayoral elections, I will ensure its role in shaping a better city is understood and show how its strengths can be brought to bear on delivering a more equitable, healthier, safer and successful London. PS: If you have ideas about what policies the Murray for Mayor campaign should adopt, please get in touch via LinkedIn (Peter Murray OBE). n

pil136 January-March 2026

OPINION: MORE HASTE, LESS SPEED | PAUL FINCH

FINCH

More haste, less speed Making your reputation by turning the world upside down and then walking away is a familiar trait in British public life, says Paul Finch The plethora of announcements from the government about the built environment sector are a sign not, alas, of an integrated coherent strategy, but a splatter-gun approach to any and every perceived ‘problem’ preventing delivery of the Labour Party’s latest idea of Utopia. For entirely political reasons, many local authorities will not conduct elections in the coming year because they have been given the opportunity to duck out of them. How many of the authorities given such a choice will willingly give up their expenses-paid sinecures if they believe the public are sick of them? None would be the safe bet. Do you remember the referendum on regional government, where the public gave the whole idea a gigantic thumbs-down? Don’t worry, Whitehall and the political class are displaying their usual favourite medical symptom, amnesia, in order to try imposing regional planning instead. If that involves the chaos of local authority reorganisation, the need for new local plans, and doctrinal arguments about (for example) how Surrey should split itself up, so be it. Better still, remove poll opportunities from a pesky electorate which keeps delivering the ‘wrong’ answer, whether regional government or Brexit. But seriously, is it a smart idea to reorganise local and regional government when you are trying to speed up planning and stimulate growth? As with the much-trumpeted claims about the latest revisions to the National Planning Policy Framework, the claims of people ‘improving’ things are difficult to refute because by definition the claims and the improvers will only be found out in several years’ time, when those responsible will be long gone. Making your reputation by turning the world upside down and then walking away is a familiar trait in British public life. History suggests that new arrangements for just about anything will have unexpected consequences which then require further reorganisation which may or may not work. The failure of the National Health Service to deliver competent dental services to most of the population is a case in point.

Planning in London

Some of the latest NPPF changes look perfectly sensible, but then the people who invented the old system seemed to know what they were doing, but apparently got it all wrong. Is the duty to co-operate on the part of local authorities with common boundaries a good thing or a disgraceful brake on ‘growth’? In reality you can argue it either way; there is no ‘right’ answer. If you really wanted to speed up housing delivery, here are some things you could do which have nothing to do with spatial planning: • End all CIL payments, a novel tax which did not exist when we built most of the country’s infrastructure • Reduce ‘affordable’ housing requirements to zero for any development under 100 homes. Again, nothing to do with spatial planning and non-existent when private house-building was at its height • Instruct Homes England and the Mayor of London to immediately begin a direct public housing procurement programme, the latter in fine tradition of the London County Council and the Greater London Council, which actually built stuff, unlike the Greater London Authority • Scrap viability assessments, which are often cutand-paste half-truths produced by a club of consultants

Paul Finch CBE is programme director of the World Festival of Architecture and joint publishing editor of Planning in London

• Make judicial review applicants pay full costs, and prove ability to pay in advance of any review On the spatial planning front, consider the following: • Transfer any requirement depending on measurable data to Building Control • This would cover all environmental data including carbon calculations which planners are not capable of analysing (nor should they be) • Ban any new policy requirements in planning applications for five years The government should also ask Singapore if it could lend us a cadre of staff from its Housing & Development Board to advise on how to get things done quickly and efficiently via public sector-led development. Old-fashioned, but it works! n

OPINION: SPEED UP THE SPEEDING UP OF PLANNING | JASON LOWES

Certainty, flexibility and simplification to speed planning It’s time to ‘speed up the speeding up’ of planning and take advantage of any improvements whilst they last, says Jason Lowes Planning in London has, like all other cities and regions, seen a slowdown in housing delivery, in part because of issues in the planning system. However, it is evident that the current administrations are aware of this and are bringing forward initiatives to try and solve it, which is of course welcome (although, in the context of current political uncertainty, it is unclear how long this commitment will last). Despite media attention for schemes being called in – notably with Data Centres – the planning system seems to be increasingly challenging to navigate in relation to all development. It takes all sorts of development to create long-standing communityfocussed neighbourhoods thus planning consents for employment land are also crucial but, of course, the greatest attention has in recent years all been about housing. This has continued since the election, with the Government’s repeated stance on delivering 1.5m homes, with a focus on affordable at the heart of its campaign. By the end of 2024, just 32,000 homes in London were delivered – one third of what has been determined as required in the capital and almost a one third drop since 2020, despite need in London being at one of its highest levels. Issues include: • Complexities of planning system, which should change for the better as the Government’s reforms kick-in over the next year or so, it is unclear as to how long these improvements will last when they come due to the prevailing political climate; • Planning authorities are under-resourced and, despite the Government’s pledge to recruit 300 more officers over 18 months ago, very few (if any) significant appointments have been made; • Sites being stalled for so long their consents have lapsed; • Viability changes in the meantime, due in part to affordable housing ratios and costs and margins being squeezed along the way; • Extensive consultation requirements with bodies that do not have the resources to deal.

www.planninginlondon.com

But, with so many potential initiatives announced via the media, what can the GLA and the UK generally do about it? The main announcements by Government (and the GLA) have been around ‘speeding up the planning process’, but the initiatives announced themselves need speeding up. And herein lies the problem. In creating ‘widespread planning reforms’ to ‘Get Britain building’, unfortunately, despite the best intentions, we have slowed down the building and created short-term delays. The talent situation is one that needs rectifying. The Government announced in the budget that they will be investing in talent. This will help in the longerterm but right now we need resource, fast. Simplifying the process will also help, with potential government intervention soon to be introduced for any Local Authority that looks to reject a development of more than 150 homes. However, it still takes time to reach that decision in the first place and several hurdles to jump over to get a plan submitted. As with the proposed site acceleration for railway locations, we need a ‘yes’ list for sites that meet a checklist of criteria across the country to provide more certainty to those that seek to build. But this shouldn’t only be about homes, it takes all types of property to build a community.

Jason Lowes is Planning Partner at Rapleys

We have seen various announcements on proposed measures to tackle the supply issue over the last couple of months, the latest from the GLA looking at temporarily reducing the number of affordable homes needed to around 20 percent which would be helpful, as a deliverable consent delivering 20 percent affordable housing is evidently far more effective than a consent that requires 40 percent affordable housing but doesn’t stack up commercially. However, despite the overall challenges that developers are facing in navigating the planning system, the Government is talking a good game in terms of improving the system. Planning applications can take a while to pull together, and our advice to our clients is to start pulling applications together now to take advantage of the Government’s initiatives as they come through – in the current political climate, it is uncertain how long these improvements will be in place. n

My five key suggestions to make a big impact for planning in the short to medium term are: 1 More certainty in the overall planning process, so developers can be more confident in promoting their sites. 2 An encouragement of more flexible planning permissions, so they are more robust to changes in circumstances, not least the market. 3 More streamlined approach to extensions to planning consents that are due to expire or, and to reviewing viability/affordable housing, again to take in changes in circumstances. 4 Simplification of the consultation process for all major schemes. 5 A better public resource strategy to deal with the changes and longstanding shortage of LAs across not just planning but all of the infrastructure needs associated with development.

pil136 January-March 2026

OPINION; PREDICTIONS 1 | TIM FOREMAN

New homes: why 2026 could be the year the market turns Tim Foreman on how policy, land and confidence will shape the recovery

In property sales there are people who need to move and people who want to move. In the last few years, only those who have had to move have been active. Once conditions improve, those who want to move return to the show homes too. That shift creates a positive market: it increases the customer base, keeps chains intact and reduces fall throughs. It does not require a revolution in economics to trigger that change - a further modest reduction in interest rates early next year could be enough to move us over the line. On that basis, I expect to see a noticeably stronger market in early 2026. From need to want: unleashing demand If borrowing costs ease following the Bank of England Monetary Policy Committee decision on 18 December and inflation remains under control, discretionary movers will come back into the market. Many are waiting for the final interest rates reduction this year a clearer signal that era of expensive mortgage is far behind us. Once they return, chains will lengthen, stock will turn more quickly and the market will feel less fragile. That is the moment when policy choices made in 2024 and 2025 will be tested, because the real question is not whether demand will return, but whether supply can keep pace. Supply, land and the weight of regulation Today there are enough new homes to meet demand in many areas, but only for the short term. Years of mixed messages about housing, together with layer upon layer of regulation, have slowed development activity. Costs have risen sharply, and so too have requirements such as biodiversity net gain, affordable housing and building safety regulations. At the start of this process is land values. The cumulative effect of regulation has reduced what developers can afford to pay for land. A landowner with a strong income from their core business will not sell for half of what they were led to expect. If that gap is not lessened, sites will remain in agricultural/commercial use and a shortage of consented,

Planning in London

developable land will stall the market. The recent action taken in London (the government’s Homes for London policy note) shows that the government understands the problem. Once put into practice, reduced affordable housing requirements, lower Community Infrastructure Levy in some locations and more flexible design standards will begin to unlock stalled schemes. A similar, carefully calibrated approach will be needed elsewhere if ministers are serious about achieving 1.5 million homes this Parliament.

Affordable housing, S106 and confidence It is not only the level of affordable housing that matters, but the way it is funded. Registered providers are finding it harder to commit to new Section 106 homes due to a lack of funds, and developers are increasingly left with affordable units that have no obvious buyer. We need a realistic conversation about how S106 homes are priced and supported.

Additional regulatory burdens would be a tipping point for many schemes. Policy now needs to focus on removing friction in the system, not adding to it. At the same time, many households are hesitating because of the wider cost of living. If government wants 2026 to be the year that first time buyers return in force, it will need to address this problem. A refreshed Help to Buy style scheme or a time limited Stamp Duty holiday for first time buyers would certainly help. There is also a case for recycling receipts from earlier Help to Buy loans to support the next generation, who in many areas face tougher deposit hurdles than those to benefited from Help to Buy (2013-2021).

Policy risks and wild cards The one thing the property market does not need in 2026 is further legislation. Additional regulatory

Tim Foreman, Managing Director of Land and New Homes, LRG

burdens would be a tipping point for many schemes. Policy now needs to focus on removing friction in the system, not adding to it. New towns will be part of the long term answer if we are to deliver more than 400,000 homes a year, but they will not help meet housing targets in the remaining 3½ years of this Parliament. Infrastructure, land assembly and governance mean long lead times. Interim policies that allow central government to call in applications near proposed new towns may even reduce delivery in those areas in the short term. We should also watch the transition from leasehold to commonhold. From my experience, the existing leasehold system usually works well for flat owners and the more extreme examples of poor practice are not the norm. Commonhold may look attractive in theory, but shared responsibility for major works is difficult to manage in practice. You cannot mend a roof by committee. If the shift is not handled carefully, it could unsettle buyers in an already fragile flats market. What needs to happen next If I had to pick one action for 2026, it would be a genuine reduction in the regulatory burden across planning and development, combined with targeted support for first time buyers. That means following through on promises to cut red tape at every stage of the planning cycle, revisiting the cumulative impact of requirements on viability and giving households a reason to believe that now is the right time to move. Do that, and when demand moves from need to want, the new homes sector will be ready to respond rather than left struggling to catch up. n

OPINION: PREDICTIONS 2 | LAWRENCE TURNER

Planning in 2026: from ambitious promises to practical delivery Why this must be the year reform turns into permissions, homes and infrastructure, says Lawrence Turner Over the past twelve months the development industry has, on paper, been given much of what it asked for: a new National Planning Policy Framework (soon to be revised again) and legislative reform (the soon be enacted Planning and Infrastructure Bill), both designed to turbo-charge housebuilding. This is alongside the beginnings of a new towns programme, a move back to regional strategic planning, a fundamental rethink of London’s growth model and serious attempts to tackle longstanding constraints such as water scarcity and nutrient neutrality. Planning has been firmly pushed back to the centre of the growth debate, as the government looks to planning and development as a key lever for kickstarting economic growth. But on the ground, consents have fallen, housing completions remain well below what is needed, and many local planning authorities are working with skeleton teams, ageing local plans, and increasing uncertainty for what’s to come. Despite the big announcements, the housing crisis persists. We still build too few homes, affordability continues to worsen, and many communities are already experiencing increased pressure on local schools, roads, healthcare and local services. As a planning consultant, I see both sides of this every day. On the one hand, we now have a much better planning policy environment, with clearer signals about the need for growth. On the other, the reality on the ground, is that nothing has yet changed. The real question is whether in 2026 that momentum can finally be turned into delivery. This means more permissions, more construction and more first-time buyers. What 2025 changed The real first shift over the past year has been less about ambition and more about intent. The previous Conservative and Coalition governments have long set out plans to deliver millions of homes. What has been missing, until now, is the political capital to tackle the obstacles that stood in the

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way. In particular, difficult decisions about housing on greenfield land on the edge of settlements have often been ignored, reflecting the reality that many existing communities, and voters, live precisely in the places where new homes are most needed. The current approach marks a stark change in tone, with government now more actively seeking to confront these issues, rather than manage around them. The Green Belt is no longer treated as untouchable, with the emergence of the Grey Belt concept enabling a more honest discussion about where sustainable growth can sensibly be accommodated around our towns and cities. New towns are back on the table; and Strategic Authorities are being created to help deliver coordinated infrastructure and housing growth across entire housing and labour market areas. In London, the Mayor’s consultation on a new London Plan and the Homes for London policy package, which is currently being consulted upon, have finally acknowledged that the capital cannot rely solely on brownfield sites and even high affordable housing targets to meet its needs. Alongside this, there have been pockets of genuine progress. The unblocking of strategic schemes in water-stressed areas such as Cambridge (which Boyer has experienced first-hand at Waterbeach New Town), shows what can be achieved when government, agencies and developers work together on water resources and mitigation. Early work on the Nature Restoration Fund and nutrient solutions hints at a more strategic approach to environmental constraints. However, 2025 has also been a year of strain. Planning departments are under unprecedented pressure, with significant vacancies, ongoing local government reorganisation and uncertainty about future responsibilities. Local plan timetables remain fragile and confidence in plan-making has been undermined in many areas. Overlay this with nervous market sentiment, tighter regulation and rising build costs, and the

Lawrence Turner is a director with Boyer

result is that too many viable schemes fail at the first hurdle. That matters for all tenures, from market homes through to Build to Rent (BTR) and affordable housing, as well commercial, leisure and town centre regenerations schemes.

What needs to change in 2026 We do not need another revolution: we need to make the reforms already in train to work on the ground, with fewer pauses, clearer national rules and faster, more strategic delivery. 1. Keep plan-making moving despite local government reorganisation Strategic Authorities will only help if they add clarity rather than delay. Every area should enter 2026 with a clear, published timetable for its spatial development strategy or local plan review, and stick to it. Transitional arrangements must be used to keep plans alive, rather than justify drift. Developers can work with firm numbers and clear strategies; they cannot plan around limbo. 2. Turn Grey Belt and growth corridors into real sites The new NPPF, Grey Belt policy and growth corridor commitments will only matter if they are translated into allocations and permissions. In practice that means undertaking a more strategic approach to Green Belt release focussed on lower quality land to deliver more affordable homes, better infrastructure and well-designed development. It also means realising that not all sites will be viable under the “golden rules” concept and being honest about delivery. >>>

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OPINION: PREDICTIONS 2 | LAWRENCE TURNER

3. Treat planning capacity as national infrastructure The funding promised for a few hundred new planners is a start, not a solution. In 2026 we need a serious workforce plan for the planning system: retention of planning fees by local authorities, targeted bursaries, mid-career routes into planning and support for specialist roles such as conservation, ecology and transport. At the same time, we should >>> be doing more in schools and universities to promote planning as a career that shapes places and tackles climate, housing and economic challenges in a tangible way. 4. Use technology to speed decisions, not just add noise Government-backed AI tools can help authorities process information more quickly, test scenarios and improve the evidence base for plans. However, we are already seeing AI being used to generate objection letters at scale. In 2026 we should focus on practical digital gains: standard data formats, better case-management systems, simple online explainers for complex schemes and careful piloting of AI

where it genuinely saves officer time. Technology needs to reduce friction, not create new bottlenecks.

and be prepared to wind down those that do not meet those tests.

5. Remove environmental blockers in a strategic way Nutrient neutrality and water scarcity remain two of the most significant brakes on housing in some regions. The emerging Nature Restoration Fund, water credits and new reservoir and transfer schemes are promising, but they must be accelerated and coordinated. The aim in 2026 should be to move from case-by-case negotiation to clear frameworks, so applicants know what contributions or design standards will unlock development at the outset.

7. Lead a different conversation with communities Finally, 2026 has to be the year we communicate differently about growth. National targets and planning reform will only go so far if every major scheme triggers local distrust. We need consistent national messaging about why homes are needed in both urban and rural areas, clearer explanations of how infrastructure will be funded and delivered, and more effort to give supporters a voice alongside objectors. That applies as much to new towns and Grey Belt sites as it does to town-centre regeneration and Build to Rent schemes. Planning cannot, on its own, fix interest rates, construction costs or investor confidence. But if we can stabilise plan-making, resource the system properly and apply the reforms already announced with discipline rather than rhetoric, 2026 could be the year we move from ambitious speeches to a steady increase in consents, starts and sales. n

6. Back well governed public sector delivery Local authority trading companies and other council-led vehicles will not solve the housing crisis on their own, but they can bring difficult sites forward, especially for affordable housing. The task for the coming year is to learn honestly from the last decade: support models with strong governance, transparent risk-sharing and commercial realism,

SKELETON

STS

Planning in London

OPINION: LONDON HOUSING EMERGENCY MEASURES | SIMON RICKETTS

London housing emergency measures The proposed London housing emergency measures package is underwhelming, says Simon Ricketts That is the message I have been receiving in many discussions with developers and advisors since consultation started on MHCLG’s Proposed London Emergency Housing Package and The Mayor of London’s draft Support for Housebuilding London Plan Guidance, both documents published on 27 November 2025 for consultation until 22 January 2026. I’m picking up that the conclusion is reluctant. Clearly, it is helpful that the drought of new housing activity in London has been recognised. Clearly, it is appreciated that MHCLG and the London Mayor have worked hard at a co-ordinated package as between them which moves significantly, and no doubt with much internal organisational pain, from the previous policy position in terms of affordable housing expectations, in terms of the usual approach to CIL and in terms of some aspects of housing standards. There is also a dilemma on the part of the industry: this is an emergency; measures are needed now; if this set of proposals has to be ditched and replaced with a more effective package, we are just losing more time, unless the industry can point with some unanimity towards practical, easily implemented, improvements to what is on offer. But the reality is that the current package (1) will not be enough and (2) is too caveated and conditional to provide the crucial reassurance that is needed to those who hold the strings in terms of funding or financing. From what I hear I’m not at all sure that the Mayor’s new time-limited route is even likely to be used, as opposed to continued reliance on viability testing. Following the initial joint announcement on 23 October 2025 I wrote a blog post on 1 November 2025 setting out 4 Key Asks For The London Housebuilding Support Package Consultation. None were taken on board in the consultation drafts. Let’s hope that there still is time before the package is finalised. To follow the structure of my previous post: Should there be more focus on stalled sites that already have planning permission? Of course! Why ignore the lowest hanging fruit? The oppor-

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tunity has now passed for primary legislation to reintroduce section 106BA (which could have been a late bolt-on to the Planning and Infrastructure Bill). But why not by ministerial direction reduce the minimum period of five years for the purpose of being able to make applications under section 106A, which are capable of appeal, to say two years – and introduce guidance as to MHCLG’s interpretation of “useful purpose” (of course the courts’ legal interpretation ultimately will be what counts but guidance will still be useful!)? And in any event introduce firm guidance to local planning authorities that they should approach requests for deeds of variation

There is a dilemma on the part of the industry: this is an emergency; measures are needed now; if this set of proposals has to be ditched and replaced with a more effective package, we are just losing more time on viability grounds positively where the case has been made (and set out in the guidance what will be sufficient to make that case)?

Is late stage (as opposed to early stage) review necessary in relation to the proposed “timelimited planning route”? No! The uncertainties caused to funders by the mere existence of any review mechanism the application of which is outside their control has a deadening effect on developers’ ability to fund schemes, utterly disproportionate to the likelihood that any review mechanism will ever deliver any material amount of additional affordable housing, schemes are so underwater. And unnecessary uncertainty has been created because the time-limited route envisages a different set of mechanisms to those which currently exist. The simple change would be for the Mayor’s LPG to specify that for a time-limited period the fasttrack thresholds will be reduced from 35% and 50% to 20% and 35% with the structure remaining

Simon Ricketts is a partner at boutique planning law firm Town Legal LLP

exactly the same as to when review mechanisms will be required and how they will operate. A bucketload of uncertainty would be immediately removed.

Are there unnecessary difficulties with introducing a viability test into the proposed CIL relief? Yes! In fact, this whole new intended structure for 50 to 80% relief from borough CIL is going to be disproportionately complex given that it will rarely make the difference between a project going ahead or not (and with the prospect of later clawback, funders will always assume the worst in any event so it just won’t help bring them over the line). What I’m being told is that where CIL is a killer is on cash flow. On viability – the overall go/stop on development – it is of only marginal influence. If there is going to be any tweaking of the Regulations: • Why not allow for payment at a later stage (you recall that when the infrastructure levy was touted by the previous government as replacement for CIL it was to be payable at upon completion of the development so would there be such a problem with it being paid, say, on occupation)? Boroughs don’t spend the monies upon receipt – timing isn’t critical to them! And Mayoral CIL is simply paying down long-term debt in relation to Crossrail. • Require all boroughs to switch on the potential for exceptional circumstances relief and see what can be done to simplify the process. Ahead of any Regulations, just lean on the boroughs to switch on exceptional circumstances relief (if they refuse that is a warning sign in itself) and introduce advice as to the evidence that should normally be sufficient. Even that would help.

And incidentally this would actually also would help SMEs, currently shut out of the relief proposed in the consultation document by a combination of the £500,000 liability threshold and the proposed £25,000 application fee. And while we’re at it, extend this beyond residential C3 development.

Are the proposed additional powers to be given to the Mayor enough? Probably, but… It really would be useful if the Mayor could call in schemes of 50 units or more even before the borough is minded to refuse them, as long as the statutory determination period has passed – thereby reflecting the current arrangements in the Mayor of London Order 2008 for schemes of 150 units or more. Final thoughts Of course the proposed additional grant funding for affordable housing is welcome. But inevitably it isn’t enough. Surely, we all agree that the thrust of all these measures is not good to the extent that, consistent with the operation of the existing system, it assumes that affordable housing, including social housing (for which there is such a desperate need in the capital) is what has to give in order to enable development to proceed. How can we move to a system where the delivery of social housing is not reliant on, effectively, an affordable housing tax imposed on residential development, given that the current model is not working? To end on a positive note, I was really cheered to hear about Homes For People We Need campaign and to read their report Making Social Rent Homes Viable. Whilst it identifies that £18.83 billion is required to develop 90,000 social rent homes per year, there is a strong investment case for substantial government subsidy, given that temporary accommodation costs of £2.8 billion annually could in theory service index-linked bonds worth circa £160 billion. “In theory an investment by HM Treasury to build c.130,000 Social Rent homes for those families currently in temporary accommodation, assuming £209,000 subsidy per home and thus a total subsidy of £27.2bn, could reduce the current bill for

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Temporary Accommodation to zero”. There are a number of strategic recommendations and suggested policy reforms in the report: “• Social Housing Tax Credits represent a promising approach, enabling private capital deployment now in exchange for future tax relief. • Section 106 Agreements should fix affordable housing values at the planning stage to improve market efficiency. • Right to Buy should be further reformed to preserve the affordable housing stock. • ‘Flex Rent’ approaches linking rents to household income should be considered to optimise revenue generation whilst maintaining affordability. • The Housing Association sector desperately needs recapitalisation in addition to the recent 10-

year rent settlement.” Santa hat-tip to the Planning After Dark Podcast episode Santa Hats, Social Rent and Squeaky Leather Trousers for the chat with Grainger’s Michael Keaveney which introduced me to this. In summary I hope that what is arrived at is fast, simple, measures to help meet the current housing and affordable housing emergency. But then I hope that there is a proper longer-term solution along the lines promoted by this report to help meet the underlying and remaining (national not just London) housing and affordable housing crisis. The current section 106 model is not working!

From Simon’s Simonicity blog which represents his personal views only. n

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OPINION: PRAGMATIC APPROACH TO THE HOUSING CRISIS | OLIVIA HARRIS

Flexibility must guide London’s housing response London’s housing crisis will not be solved by a single reform. But adopting flexible, pragmatic approaches wherever possible will help move the dial, says Olivia Harris The proposed emergency measures to boost housing delivery in London - including a lower threshold for onsite affordable housing provision before viability tests apply - are a welcome and pragmatic step. No one working in the affordable housing sector wants to see an important supply of belowmarket stock reduced, but at a time when development viability is stalling so many schemes across the capital, it is better to deliver 20% of something rather than 35% of nothing. Housing delivery in London is at its lowest level since 2014, and according to the GLA, a third of boroughs recorded zero housing starts in the first quarter of this year. If these emergency measures from the Government and London Mayor get schemes moving and shovels in the ground, more people will have places to live at prices they can afford. Crucially, the announcement signals that policymakers recognise the need for flexibility if we are to be serious about tackling London’s housing stasis. That same principle of flexibility should guide how we think about other policy levers, such as the Community Infrastructure Levy (CIL). CIL was designed to help fund the essentials that make neighbourhoods function, such as roads, schools and playgrounds. Yet, a narrow definition of infrastructure means that councils can’t always use the funds where they are needed most. As a result, there is between £2bn and £4bn in unspent CIL sitting idle in council bank accounts across the country, while housing need reaches crisis levels. According to London Councils, boroughs are spending an extraordinary £5.5 million a day on homelessness - primarily on temporary accommodation for families. Below-market homes may not be seen as conventional infrastructure that keeps cities moving – but without them the UK capital risks grounding to a halt. Research by Savills for Dolphin Living finds that 290,000 households earning less than £90,000 will no longer be able to afford to live in inner London by 2035. This is at a time when the city needs an additional 200,000 workers over the next decade to support our public services and key sectors, such as healthcare and hospitality. Oxford Economics’ Cities & Regions team has

Planning in London

found that the capital’s housing crisis has resulted in the city being the UK’s weakest-growing region since 2008, as skilled workers find the city increasingly unaffordable and unattractive. At Dolphin Living, we see every day how good quality affordable homes for working Londoners not only help people get on in life, and create stronger, more resilient communities – but also benefit the functioning of London’s vibrant economy. How can we fund the affordable housing London so desperately needs – be it properties available for social rent which will transform the lives of homeless families – or intermediate rented homes to enable essential workers on modest incomes to live close to their place of work? Due to the heavily centralised nature of local government financing – the incredible economic

value generated in central London does not translate into the equivalent revenue for its councils to spend on local housing need. Consider Westminster in the very heart of the capital. It is the UK’s most economically productive district and in 2023/4 alone it generated £2bn in business rates for the public purse. However, the vast majority (96%) of these funds were redistributed elsewhere. In the absence of more fiscal devolution, an opportunity surely lies with unspent

Olivia Harris is Chief Executive of Dolphin Living and Housing Lead for the Westminster Property Association

CIL monies and with the principle of flexibility shown in the emergency housing measures. The Westminster Property Association (WPA), together with Westminster City Council, has urged the Government to enable greater flexibility in CIL rules. We first raised this with the Minister of State for Housing and Planning, Matthew Pennycook MP, in May and reiterated the call ahead of the Autumn Budget. Allowing councils, under clear guidance, to allocate a portion of unspent CIL to support the viability of affordable housing schemes could have an immediate impact. Often, the gap between build cost and affordable housing revenue is modest but decisive. While S106 funds can be legally restricted and may place an additional strain on development viability, targeted CIL contributions could unlock schemes that already have planning permission, local support and partners ready to deliver. Such flexibility would not dilute CIL’s purpose. Investment in core physical infrastructure remains essential, and long-term plans for funding improved transport connectivity and community facilities must continue. But enabling unspent CIL to support affordable housing, particularly in urban centres like London where affordability is so acute, is entirely consistent with its core aim of ensuring development keeps our neighbourhoods functioning and supports wider economic growth. London’s housing crisis will not be solved by a single reform. But adopting flexible, pragmatic approaches wherever possible will help move the dial. The Government and GLA have taken an important step with their emergency measures. Extending that pragmatism to CIL could unlock dormant funds and help deliver the affordable homes London’s communities, employers and economy urgently need. n

OPINION: THE USE OF AI IN ENVIRONMENTAL ASSESSMENTS | ALISTAIR WALKER

The use of artificial intelligence in EIAs AI can enhance the quality and robustness of environmental assessment but its role must remain supportive rather than determinative, says Alistair Walker With the advancement of AI in the last few years, it is important that the application of AI in the field of EIAs is closely regulated, and the implications of its use are understood. I am the lead author of a new Institute of Sustainability and Environmental Professionals (ISEP) advice note, launched in November, which provides an overview of AI and key principles for its use in EIA by practitioners. The content below is a summary of that report. What are the benefits of its use in EIA? There are a multitude of potential benefits to applying AI tools in varying aspects of the EIA process. These include baseline data gathering and monitoring, advanced automated geospatial analysis, streamlining document management, identifying cumulative schemes, consultation / review summaries, synthesis of data and predictive modelling, proof-reading documents, and assistance in drafting non-technical summaries. What are the barriers to adoption of AI tools? There are several barriers to the effective development, deployment, and adoption of AI within the EIA process. These include technical barriers such as data quality and availability, model interpretability, scalability and infrastructure, robustness and reliability, and cybersecurity. Legal and regulatory barriers include a current lack of regulation and fast-paced change, cross-border data governance, and safeguarding and intellectual property. Organisational and cultural barriers exist, including a resistance to change, lack of expertise, public understanding and use, and ethical culture. Ethical barriers include bias (of the AI tool), environmental impact (of use), privacy, accountability, and utilisation in respect of ensuring that early career/graduate tasks are not replaced by AI so that avenues into the sector remain and be attractive to new starters. What are good principles of AI use? Use of AI tools to benefit EIA practitioners is encouraged, but AI tools should be used with caution. Six general principles for good application of

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AI in EIA are set out below to encourage best practice and confidence in use, as follows: 1 Understanding, competence and responsibility of use: all users must bear full responsibility and accountability for the application of AI in EIA processes. As such, they need to understand the risks and benefits of use. Most critically, they must understand the intellectual property rights of information provided to a third-party tool and confidentiality of use in respect of the user company policies. AI tools should only be used when their application complies with legal requirements and when users have a clear understanding of how to use them effectively, efficiently and ethically. 2 Alignment to regulatory frameworks, standards and protocols: AI applications in EIA must align with applicable national and international impact assessment (IA) standards, regulatory frameworks and scientific protocols. This ensures that AI-generated outputs are valid, legally defensible and consistent with accepted methodologies. 3 Transparency: for reporting, full and open statements should be provided stating what type and extent to which an AI tool has been used in assessment and creating an IA report to clearly inform the decision-making. This is especially important if any Generative AI (‘GenAI’) tool has been used. GenAI systems are those which combine a powerful, large language model with a user interface application layer to generate text, images, video or code outputs (completions or responses) in response to a user’s prompt (input, questions or instructions. ISEP recommends that, as a minimum, the name of the tool or system, date, manner of use and location in document of outputs should be stated. Equally, any third-party soliciting comments on an IA report must disclose their use of AI tools, if applied. 4 Accuracy and verification: all users need to understand that AI tools/models are not likely to be perfect and errors will occur, since these tools/ models are developed based on certain parameters. All users should apply oversight to AI outputs to prevent errors and ensure accurate representation. 5 Garbage in; garbage out (GIGO): AI models are defined by the input data. The better the quality of the input data, the better the output. Users should

Alistair Walker is technical director at Lanpro

provide as many relevant details as possible into the AI tool to ensure more reliable, accurate outputs, reducing likelihood of bias. 6 Utility, not reliance: in general use, users need ensure they do not simply rely on the AI outputs for reporting as the outputs. Using the outcomes without necessary checks in place will hinder professional development in understanding of process, critical thinking and development of solutions. AI tools used in the EIA process need to support individuals in their workings and decision-making, not replace these processes. Organisations should look to offer ongoing training and capacity building for users of AI tools to ensure they adopt in the most effective manner since AI evolves so rapidly. AI is already beginning to reshape the way EIAs are prepared, reviewed and understood, but its value will only be realised if it is applied with care and clarity. The opportunities are considerable: better data, faster analysis, more consistent reporting and the ability to focus expert time on the judgments that matter. Yet these advantages come with obligations. Practitioners must stay alert to the limitations of the technology, ensure that professional oversight is never diluted and maintain the transparency that underpins confidence in the EIA process. If used well, AI can enhance the quality and robustness of environmental assessment. But its role must remain supportive rather than determinative, enabling practitioners to work more efficiently while still retaining full responsibility for their outputs. The principles set out in the ISEP Advice Note provide a practical framework for doing so, guiding the sector towards innovation that strengthens, rather than compromises, the integrity of environmental decision-making. n

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OPINION: GATEWAY 2 DELAYS | SARAH ROCK

Gateway 2 delays – will 2026 be a turning point? The Gateways process is a welcome additional safety standard but its application has been fraught with confusion, frustration and costs. The announced changes must start to alter the landscape, says Sarah Rock The Building Safety Act 2022 introduced three Gateways into the building control approval process for building or carrying out certain works to high-rise residential buildings (HRBs) in England, the first at planning stage, the second at building control approval stage and the third at completion. Gateways 2 and 3 act as hold points, meaning they must be passed successfully before a spade can be put in the ground or a completed building may be occupied. The Gateways, which have been managed by the Building Safety Regulator (BSR) since October 2023, have become notorious in the construction industry for causing delay and costs to projects – but why? Making a Gateway 2 submission requires a construction-ready design package typically found at RIBA Stage 4 displaying a clear understanding of how the building will be constructed and how it will meet building regulations and fire safety standards. Also required are full building plans, specifications and schedules with descriptions of materials, construction methods and timeline for the project alongside more detail including competency declarations, change control plans and the fire and emergency file. Requiring such a mature design before allowing work on site has front-loaded the design process and requires having a full team on board early. Once received, the BSR has a statutory period of 12 weeks (new HRBs) and 8 weeks (works to existing HRBs) to process the Gateway 2 application. However, as has been widely discussed in the industry press these timeframes have not been met and as was reported by the BSR chair in October last year the average time that firms were waiting for Gateway 2 approval across the UK stood at 43 weeks, 48 weeks in London. Such delays have huge potential knock-on effects for the industry – supply chains are in limbo, costs of materials are fluctuating and the prices of high-rise schemes are spiralling. Funders are understandably less willing to lend against projects involving the Gateways. In addition, a lot of the projects stuck in the Gateway 2 log jam are remedial projects to fix dangerous

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defects discovered post-Grenfell. The causes for the delays are numerous and vary depending on which side of the fence you are sitting. The BSR has complained that missing or inadequate information is a major issue. It is easy to see that such a new and complex procedure might have caused some teething problems to developers attempting to obtain a successful application for the first time. From the developer's point of view, a lack of transparency from, and communication with, the BSR teams has resulted in much frustration. In fact, the teams themselves have potentially been a cause of the issue. External multi-disciplinary teams assembled upon receipt of an application has led to inconsistencies between applications and longer review periods. In recognition of the issues and the knock-on

It is hoped that the improvements underway at the BSR and the improved level of guidance available to developers will assist in reducing the time taken to process Gateway 2 applications effect to the industry (as well as to the Government's housing pledge of 1.5 million new homes by 2029) major reforms were introduced at the BSR last year. The BSR is being transferred out of the Health and Safety Executive and is to become an arm's-length body under the Ministry of Housing, Communities and Local Government. A new non-executive chair and new chief executive were appointed (both with significant previous fire commissioning experience). Over 100 new staff are being hired with the hope that they will go towards forming internal MDTs and greater transparency and collaboration with the applicant's design team is also hoped for. Further assistance has been provided by the Construction Leadership Council who in July last year published the Guidance on Building Control

Sarah Rock is a partner and head of construction at Boodle Hatfield

Approval Applications for a new Higher-Risk Building (Gateway 2). This guidance provides the baseline principles to guide developers submitting applications and includes practical recommendations on the approach and submission of relevant information. In addition, in December last year the Government provided further guidance for Preparing Information for a Building Control Approval Application. It is hoped that the improvements underway at the BSR and the improved level of guidance available to developers will assist from both angles in reducing the time taken to process Gateway 2 applications to within the statutory timeframes. The additional 100+ members of staff are a very welcome addition but it should be understood that it is likely to take some time for these new starters to get up to speed on what is of itself a new and complicated process. The additional guidance for developers is hopefully going to prove helpful but better communications with the MDT team members themselves seems to be a bigger breakthrough. When speaking with developer clients the lack of transparency and inability to speak with anyone within the BSR has led to frustration and confusion in addition to costs and delays. The rationale for the Gateways process is simple to understand and is a welcome additional safety standard for HRBs following the terrible tragedy at Grenfell. The application, however, has to date been fraught with confusion, frustration and costs. The changes announced last year must start to alter the landscape, reduce the delays and provide for a more cohesive system or developers will stop building up and the housing crisis will continue. n

The next meeting of the London Planning & Development Forum is the annual planning update afternoon conference on Tuesday 24th March at Dentons 1 Fleet Place EC4M 7WS In collaboration with the Cambridge University Land Society and the Association of Consultant Architects To attend please book at https://tinyurl.com/hd2p224y For the agenda nearer the date please also look at planninginlondon.com >LP&DF

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pil136 January-March 2026

OPINION: THE LATEST ON VIABILITY | ANDREW GOLLAND

How to tackle the housebuilding crisis Viability is the culprit and London needs more effective strategic policies, argues Andrew Golland Government, the press, industry and the professions are increasingly concerned about housing starts. Government is under pressure to meet ambitious housing targets; the industry must answer to employees, financiers and shareholders; and professional bodies have a responsibility to help ensure the system operates more effectively. There is no doubt that housing starts have fallen. The table and chart illustrate the scale of the decline. Regionally, Northern Ireland has proved the most resilient since the Covid pandemic. Most other regions have experienced a gradual downturn, while Scotland and Wales have seen particularly significant falls in housing starts. There is particular concern for smaller developers. In response, the House Builders Federation (HBF) has published a report identifying barriers to delivery and making recommendations—many of which focus on speeding up the planning process: www.hbf.co.uk/research-insight/planning-forsmall-sites Further HBF research highlights the specific challenges facing Wales: www.hbf.co.uk/research-insight/wales-housingsupply-2025 The case of the Capital One statistic stands out: Greater London. Housing starts have fallen dramatically over the last five years, to just 27% of previous levels, with an apparent collapse over the past 12–18 months. There are likely to be several reasons for this. These include a relatively stagnant housing market set

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against rising construction costs, leading to falling land values as developments progress. This is a particularly alarming prospect for smaller developers, who cannot offset losses on one site against gains elsewhere. The decline may also reflect reduced levels of investment in the capital more generally, with the Mayor frequently citing the UK’s exit from the European Union as a contributory factor. It remains possible that the most recent figures represent a cyclical downturn rather than a structural problem for London. Either way, Mayor Khan appears unwilling to wait to find out.

Viability: the culprit once again? The response to the apparent collapse of housebuilding in London is a Package of Support for Housebuilding in the Capital (November 2025): https://assets.publishing.service.gov.uk/media/68f a1ab730c331c88be6f00a/support-for-house-building-in-london.pdf The package includes: •Temporary relief from the Community Infrastructure Levy (CIL); • A time-limited planning route; • Expanded GLA call-in powers for major schemes; • A City Hall Developer Investment Fund. Government is reportedly backing this package. Implicit throughout is an assumption that viability assessments are largely responsible for the current low point in housing delivery. The proposed time-limited route offers planning consent within a fixed window (to 2028), provided schemes commit to 20% Affordable Housing, thereby removing the need for a

Dr Andrew Golland specialises in the field of housing, planning and regeneration

viability assessment. Linked to this route are potential CIL reductions (up to 50% of a borough’s charge) and possible grant funding for Affordable Housing. However, the latter appears limited to applicants with GLA Investment Partner status, which is likely to exclude many smaller developers. The package is currently out for consultation and may yet be refined—or rejected altogether. My concerns are as follows: • Policy change alone has limited impact on delivery. The existing Fast Track route (35% Affordable Housing with no viability review) has been in place for some time and has coincided with a sustained decline in output. Pulling harder on the same policy levers is unlikely to produce different results. • Removing viability assessments does not make unviable sites viable. This approach ignores the role of existing use values, which are a particular issue in London given the prevalence of brownfield land and complex property interests. • Marginal changes can matter. In many cases, reducing Affordable Housing from 20% to even 19%

could materially improve scheme viability, especially within an increasingly demanding planning system. • A blanket 20% Affordable Housing policy is flawed. Under Ken Livingstone, the question was asked whether 50% Affordable Housing could work, and the evidence showed it could not. The same logic applies here. In higher-value areas, delivery above 20% may be achievable; elsewhere, 20% will never work. A London-wide policy risks conflict with borough-level policies and potential judicial review, as has happened previously when local thresholds have prevailed. • The scope of the changes is unclear. If they apply to smaller schemes, they may conflict with local authority targets and with the complex protocols governing commuted sums and review mechanisms—despite proposals to waive some requirements under the time-limited route. There is also a broader economic issue. Policy adjustments and grant funding often translate into higher land values rather than increased housing output. Landowners reprice their sites accordingly, capturing the benefit. The productive sector—housebuilders—sees little gain, while Affordable Housing

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delivery may ultimately suffer. These measures therefore risk being counterproductive, both in terms of output and community benefit.

What could a regional body do better? While the figures suggest London warrants a tailored response, it is difficult to ignore the political context. A collapse in housing delivery in Labourrun London would carry significant political consequences, which may explain what appears to be a somewhat knee-jerk reaction. Nevertheless, this was an opportunity for a regional body such as the GLA to adopt a more strategic approach to delivery. CIL, for example, is a blunt instrument for funding infrastructure. It cannot generally be challenged on viability grounds unless the local plan explicitly allows it. Making CIL relief contingent on changes to Affordable Housing policy risks creating a chaotic and inconsistent system. Rather than an ad-hoc package, a more detailed examination of the interaction between CIL and Affordable Housing policy would have been preferable. In some locations CIL has only a modest

impact; in others, it is significant. A regional housing policy could also do much more to standardise technical approaches to Section 106 delivery. Affordable Housing thresholds vary widely across Greater London, often with little clear evidence to justify the differences. The same applies to commuted sum calculations. While the GLA’s Affordable Housing SPD (2017) provides broad guidance, it has not filtered consistently down to borough level and does not adequately reflect realworld variables. For viability consultants, this complexity is manageable. For smaller developers navigating an opaque and inconsistent policy landscape, it represents a significant barrier to delivery. More up-to-date and authoritative regional guidance – particularly on review mechanisms and land value benchmarks—would be far more effective than the current proposals. Instead, valuable time early in this government’s tenure has been spent assembling what appears to be a fragile and poorly evidenced policy package. Without a confident housing market and rising values, it is unlikely to succeed, regardless of the intentions of policymakers. n

OPINION | GREEN BELT RELEASE AND AFFORDABLE HOUSING | CHRIS HEMMINGS

How will green belt release affect affordable housing? In the face of delays I expect we’ll see a rush of speculative planning applications with many more decided at appeal, thinks Chris Hemmings The publication of a revised NPPF last year was the first in a series of major planning reforms to be introduced by Labour. Among the NPPF’s most significant changes was the introduction of the ‘Grey Belt’ and the ‘golden rules’ by which such land may be released for development. Research suggests that 30,597 Grey Belt sites across the country have the potential to boost housing delivery by as many as 3.4m properties – which would meet the government’s ambitious housing targets for a full two parliamentary terms. Of course not all of this land is suitable and available for housing, and the 30,597 sites quoted above would average just 111 homes per site. Furthermore, applying the new rules associated with Grey Belt release will be far from straightforward. Addressing housing need Prior to the general election, Carter Jonas carried out some comprehensive research of the Green Belt which demonstrated that only a very small percentage of land is designated for environmental purposes, suggesting greater scope to release Green Belt land. And, despite higher percentages of overlap of Green Belt and other designations (specifically in London), there is still a significant proportion of land without an environmental designation that could be used strategically. The Grey Belt According to the NPPF’s definition, any Green Belt site, including previously developed or brownfield land, could be reclassified as Grey Belt provided if it can be shown to ‘not strongly contribute’ to three of the five purposes of the Green Belt: to check the unrestricted sprawl of large built-up areas; to prevent neighbouring towns merging into one another, and to preserve the setting and special character of historic towns. As with any policy, there are exceptions, such as sites with irreplaceable habitats or at risk of flooding. The ‘Golden Rules’ The ‘Golden Rules’, set out at Paragraph 156 of the NPPF, are: a. affordable housing which reflects either: (i) development plan policies produced in accordance

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with paragraphs 67-68 of this Framework; or (ii) until such policies are in place, the policy set out in paragraph 157; b. necessary improvements to local or national infrastructure; and c. the provision of new, or improvements to existing, green spaces that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces. The text of ‘Golden Rules’ (b) and (c) hasn’t changed since the document was published for consultation. However, there has been some subtle but limited changes to the level of affordable housing requirements (a), with the change from ‘at least 50% affordable housing’ to delivering above policy levels of affordable housing in accordance with Paragraph 157. So, for areas with an existing 30% affordable housing policy, this may rise to

In the short term I suspect we will see an increase in developers looking to challenge the affordable housing quotas through the Planning Inspectorate and of course this will result in delays. 45% as the Government states that a 15% premium is required in the absence of updated development plan policies. For areas with no affordable housing requirement, the default position is 50%. On a positive note, the Government has listened to the development industry. But in the revised Planning Practice Guidance the submission of a site-specific financial viability assessment (FVA), seeking to lower the proportion of affordable housing or developer contributions is not allowed. However, the Government intends to review the viability guidance and the circumstances which may merit a FVA being undertaken,

Chris Hemming is a Partner with Carter Jonas

such as for large sites or on previously developed land. The timescales for this review are not provided and therefore, for the time being, any landowner seeking to promote its land for release from the Green Belt will need to deliver above policy levels of affordable housing in accordance with Paragraph 157. It remains to be seen what impact this policy will have on the appetite for Green Belt releases, but the higher proportion of affordable housing will provide viability challenges, and without the recourse to challenge viability, this may inhibit delivery. Initial impact of the changes In the short term I suspect we will see an increase in developers looking to challenge the affordable housing quotas through the Planning Inspectorate and of course this will result in delays. There’s an argument that larger schemes which are in the national interest should be determined nationally and – no doubt to avoid a local backlash - the Secretary of State has said that the government would welcome a threshold whereby a large housing development goes to the Planning Inspectorate, but I doubt this would go down well locally. Allocations for development through the local plan process will also take time and furthermore, proposed changes to local government structures will add to this delay. And in the face of delays, particularly bearing in mind the significant potential that some Grey Belt sites offer, I expect we’ll also see a rush of speculative planning applications, with many more decided at Appeal. n

OPINION: TAKE-UP AND IMPLEMENTATION OF BNG | RICHARD HOLLIDAY

The disparity in take-up and implementation of BNG If BNG is to fulfil its potential, delivery must be achievable on a national scale, not just where favourable conditions already exist, says Richard Holliday The requirement for a minimum 10% Biodiversity Net Gain (BNG) has been in place for over a year, and while the sector’s response to the requirement has been generally positive, there are clear inconsistencies and difficulties in how the policy is being applied in practice – from small to large-scale projects, and affordable housing developments. It is broadly understood that BNG mandates all new developments leave biodiversity in a measurably better state, with a regulatory minimum standard of 10% across all local planning authorities (LPAs). However, more than one year on, there are still inconsistencies in the approach and requirements between regions and authorities, and how some LPAs are seeking higher BNG outcomes. To understand the evolving market, our report, Biodiversity Net Gain: Navigating the Evolving Market, analysed over 3,300 hectares of development sites across England. It found that the average habitat baseline value is 3.45 units per hectare. To secure a 10% net gain on a typical 10-hectare site, developers must, therefore, enhance or create habitats to achieve at least 37.95 biodiversity units (BUs). If the required 10% uplift cannot be delivered on site, the costs for off-site compensation can quickly escalate and the availability of habitat sites can vary considerably. Balancing BNG demand with land supply Such figures illustrate just how critical land access and strategic planning are to fulfilling BNG, and why capacity varies so widely across the country. By its very nature, the UK is an ecologically diverse landscape. Ancient woodlands, chalk grasslands and coastal salt marshes are present, as are highdensity urban environments, brownfield and heavily constrained sites. There are very different capacities for meeting BNG criteria both on and off-site. For instance, consider the East and South East. With established habitat banks to enable biodiversity improvements, the opportunities to provide 10% BNG exist. However, due to the level of housing delivery expected in these regions, the availability of habitat banks will be critical to successful delivery. Elsewhere, these off-site opportunities are less common although more habitat banks are brought to market regularly, and this is where the effective execution of BNG becomes a far more challenging

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prospect. For affordable and social housing projects the difficulty can be all the more profound.

Burden and opportunities for the unit market There are significant differences not only in regions, but also habitat types. Notably, when measuring the biodiversity value of existing land, the contrast between greenfield and brownfield land is not as pronounced as many anticipated. While greenfield sites have an average baseline of 3.60 BU/ha, brownfield sites typically sit at 3.17 BU/ha. This can sometimes spell trouble for affordable housing, which is often constructed on brownfield land. Though such sites may benefit from existing infrastructure and be perceived as more sustainable, their constrained size offers limited opportunities when it comes to providing BNG on-site. Under current policy, there are no ‘biodiversity discounts’ for such schemes. The challenge of realising BNG applies across all types of development land, and with ambitious housing targets in place, the appetite for habitat banks is poised to rise sharply. Add to this the likely upcoming extension of BNG demands to Nationally Significant Infrastructure Projects (NSIPs), now expected in May 2026, and competition is set to intensify. With many habitat banks coming to the market over the last 12-18 months; others still a work in progress, and delays to Local Nature Recovery Strategies (LNRS) – which, once in place, could further shape the value of BUs, developers are in danger of falling behind delivery targets. At present, biodiversity units can be sourced from across the country, but with the spatial risk multiplier favouring and supporting local delivery. However, should LPAs begin to press for BNG to be delivered strictly within their own boundaries, the options available to developers will narrow considerably, placing even greater pressure on costs and locations where land and habitat banks are already stretched. On- and off-site BNG Our report reveals that 54.7% of developments are delivering BNG entirely on-site. While this may be within reach on some sites, it is not always realistic. Where on-site provision is not possible, developers are instead turning to off-site solutions –

Richard Holliday, Associate Partner, Carter Jonas (Leeds)

whether through their own land holdings, the purchase of BUs from third-party providers, or, as a last resort, through the national statutory credit scheme, although evidence suggests the latter option is rarely used, presumably due to the prohibitive costs involved. Though often more viable on larger or less constrained sites, on-site BNG can become far less feasible for affordable and social schemes working with tighter budgets and sometimes more heavily constrained sites. Yet without adequate availability and streamlined coordination, momentum will stall, most notably in areas where need is greatest, leaving social and affordable housing initiatives specifically vulnerable. The impact of uneven BNG delivery on targets With government targeting an ambitious housing target of 1.5 million homes within five years, demand will inevitably increase exponentially. Onsite, this may pose issues in relation to density and viability, while off-site, requirements may well exceed supply, at least initially. For affordable and social housing, cost sensitivity is a constant concern. With disparity across the UK – particularly in densely built-up zones, where the necessity for these homes is arguably at its highest – premium prices for off-site BUs threaten project feasibility. And for smaller developers and housing associations (HAs) especially, absorbing these additional costs will prove increasingly difficult. Getting BNG right nationwide If BNG is to fulfil its potential, delivery must be achievable on a national scale, not just where favourable conditions already exist. BNG will risk becoming something of a postcode lottery. A consistent framework, grounded in practicality, is the only route to achieving fair, functional outcomes across the country. n

pil136 January-March 2026

BRIEFING: THE PLANNING AND INFRASTRUCTURE ACT | ANALYSIS AND OPINIONS

On the Planning and Infrastructure bill gaining Royal Assent New law will ‘halve’ planning delays, claims Housing Secretary Steve Reed In an interview, The Times asked for Steve Reed’s response to repeated industry warnings that the government will miss its target of 1.5 million new homes by 2029. He replied: “I agree, it’s challenging. It’s meant to be challenging because we want to build the maximum number of homes that we can over the lifetime of this parliament. If we set an easy target that was easy for me to hit, then no one is going to be energised by that. You have to set a stretching target, but it also has to be achievable. I think that’s the figure that we’ve got to.” Reed predicts a “hockey stick” effect as reforms ramp up the amount of homes getting built towards the end of Labour’s five-year term. He claims a new default yes to homes within 800m of a train station in areas with jobs — as introduced in national planning policy last month — on its own “could get nearly a million homes built”

Here’s what some of the commentators think Sam Bensted, assistant director, British Property Federation, said: “The Planning and Infrastructure Bill gaining Royal Assent is welcome and should pave the way for more strategic planning and streamlined decision making at the local level. “It is crucial that more homes are delivered and at pace to meet housing need. Greater certainty in the local planning process, and the greater delegation of planning decisions to planning officers, should go some way to achieving this. A lot of the detail that will come forward through the emerging Spatial Development Strategies is still to be worked up, and it is vital that these new strategic plans also effectively plan for employment uses to generate jobs alongside new homes. The larger than local approach must be applied to industrial and logistics space, which enables goods to move efficiently around the country, boosts employment and creates economically sustainable communities. The detail around the Environmental Delivery Plans and the new Nature Restoration Fund will be crucial. We want reassurance

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that the new approach will be delivered in a way that genuinely protects and restores nature in tandem with speeding up the development process.”

The Town and Country Planning Association: The bill heralds a loss of “local democratic accountability” with a risk that local people “may have no opportunity to present their case in front of elected members”. The bill gives the government powers to block all committees of locally elected politicians from deciding most planning applications. Instead, trained local planning officers will decide most cases, including for schemes of up to 49 homes under current proposals. Catherine Williams, planning director of the Home Builders Federation (HBF): Developers have long argued that politicians elected on an anti-development platform often block schemes that end up being approved on appeal, causing years of delay and costing hundreds of thousands of pounds per case. Catherine Williams says: Stopping this “will speed up the process; most political decisions on planning should come earlier when councils draw up their long-term local plans.” Victoria Hills of the RTPI: “Councils and other bodies that must be consulted about planning applications will be able to set their own fees to cover costs. This is “one of the most important measures in the bill” as “a lack of resourcing in the planning system has been undermining good development for years. For it to work, the money must be reinvested in planning, she added.” The Association of Consultant Architects responds: To give monopolies power to set their own charges and even to allow higher charges for the most inefficient is wrong unless private agents are licenced to compete with councils in the development management business by processing applications.

Housebuilding has been decimated in swathes of the country by rules that require you to prove any new home will not add nutrient pollution to rivers, where industrial farming and water companies are largely to blame. To cut the Gordian knot, the bill creates a nature restoration fund. Developers will be able to pay standard levies to not only offset damage, but improve the environment in line with ten-year, area-based plans drawn up by Natural England, a government quango. The CPRE says ... it has “major concerns” that Natural England lacks the resources to draw up these plans, and is “not convinced” that developers will be required “to avoid damage to our most important wildlife sites.” Some wildlife campaigners have accused the government of allowing “cash to trash” nature. Lawrence Turner, a director at Boyer: We support the Planning and Infrastructure Act and its aim to remove blockages and speed up planning decisions, whether through the Nature Restoration Fund, CPO reform, proper strategic planning, or a national scheme of delegation and mandatory member training. The focus now must be on delivery. The regulations must be clear and workable, councils properly resourced, otherwise uncertainty and delay simply get baked back into the system. Paul Miner of the Council for the Protection of Rural England (CPRE): Wider new strategies will plan for housing, transport and infrastructure across economic areas that span individual council borders. This will fill a “major gap” left by the abolition of regional planning in 2010. “They will encourage the re-use of brownfield sites and regeneration of urban areas, rather than unnecessary building in the countryside,” However, it coincides with other local government reforms in the southeast, delaying plans where the housing shortfall is at its worst, says Edward Clarke, associate director at Lichfields.

BRIEFING: NEW NPPF | RACHEL CLEMENTS & MATTHEW SPRY OF LICHFIELDS

Tipping the scales? Can the revised presumption in a festive NPPF help unlock growth? Rachel Clements & Matthew Spry give us a first response to the new consultation NPPF Default “Yes” at stations, Brownfield passports bring good cheer!1 In what is now an annual Christmas tradition2 (in which Government alternately publishes a version of the national planning policy framework either for consultation or adoption) a new NPPF has landed, this time for consultation with much-awaited national decision-making policies (NDMPs). There is a significant body of proposed policy to digest and consider before one pontificates on the document as a whole, but this blog focuses on the structural architecture of the NDMPs (notably the timing of implementation and relationship with the statutory development plan) and the striking proposals to reform and strengthen the presumption in favour of sustainable development (“the Presumption”). >>>

The bill strips out significant parts of the “unwieldy two-year statutory pre-consultation period” on major infrastructure such as reservoirs, pylons and data centres, he comments. How well it will work depends on secondary legislation and guidance yet to be drafted, says Clarke. CPRE thinks it will speed things up, but not as much as halving the current four-year average time taken to decide nationally significant infrastructure projects, Robert Bruce, planning partner at solicitors Freeths: National planning policies are likely to be a quicker route for the changes the Country needs, with a total re-write of national planning policies published in the draft National Planning Policy Framework issued for public consultation on 18 December. Ben Standing, planning partner in law firm Browne Jacobson Following hot on the heels of the wide-ranging reforms to the National Planning Policy Framework (NPPF) announced last month, the passage of the Planning and Infrastructure Bill “indicates the govern-

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A daunting inheritance When the Government took office over 18 months ago, it faced a daunting inheritance: our blog – a new dawn has broken, has it not? – summarised the situation: 1 The planning system was targeting annual housing delivery of just 259,000, with 75,000 homes a year needed in locations constrained by Green Belt

2 Most areas had plans that were – or soon would be – ‘out of date’ 3 Residential planning permissions were well below what was needed to deliver 300,000 per annum 4 Decision making on applications is unpredictable and most projects take at least 2-3 years to pass through planning – a finding reinforced by our subsequent research for LPDF and >>>

ment is doubling down on its commitment to putting housebuilding at the centre of its economic growth mission. “There’s a clear link between the legislative and policy instruments being used by government. While the latest NPPF reforms aim to unlock small and medium-sized plots for development via a suite of changes – including a new ‘medium’ category for sites, exemptions for smaller sites from biodiversity net gain regulations and new benchmark land values – much of the focus of the Planning and Infrastructure Act is on large-scale developments. “This includes streamlining consultations for nationally significant infrastructure projects (NSIPs), bolstering development corporations to deliver largescale new towns and communities, and implementing greater compulsory purchase order powers for critical infrastructure such as houses, schools and hospitals. “Replicating spatial development strategies that are already established in London across the English regions is designed to facilitate a joined-up approach across multiple local authorities to identify the most suitable places to build houses and associated infrastructure. To help meet its 1.5 million homes target this parliament, the government wants to simplify a

fragmented decision-making process within local authorities, embedding consistency on a national basis regarding who determines planning applications. This will make it easier for developers to understand how their applications will be handled. “It’s important, however, that government considers the impact of new housing on local communities. With the discourse often around which areas carry the ‘burden’ of new housing, planning reform should be complemented by a dedicated drive to meaningfully engage communities so the benefits of development are shared by everyone. “While electricity bill discounts for communities hosting new energy infrastructure are a step in the right direction, the government should consider the establishment of citizen assemblies to ensure developments respond to community priorities, such as a lack of GP and school capacity, inadequate roads and railways, or underinvestment in leisure facilities. “For developers, they will also want to see the government consider how to improve the viability of construction projects by tackling acute skills gaps, and rising costs of raw materials and borrowing, while addressing regulations and new taxes like the Building Safety Levy that continue to squeeze margins.” n

pil136 January-March 2026

BRIEFING: NEW NPPF | RACHEL CLEMENTS & MATTHEW SPRY OF LICHFIELDS

>>> Richborough. This led to the conclusion that a) net additions were unlikely to significantly exceed 200,000 in the short term and will need to ramp up; and, realistically, there would not be any great boost to supply arising from Labour’s proposals for strategic plans, new local plans, and new towns before 2029. In combination, this meant that: 1 any increase in housing delivery would need to arise from immediately encouraging the submission and approval of planning applications ahead of local plan, including in areas of green belt 2 in view of the low starting point, the policy support for housing delivery to achieve this stepchange would necessarily need to not only reverse the December 2023 NPPF, but go beyond the 2012 or 2018 iterations of the NPPF and be rapid in its effect. The December 2024 NPPF and new Standard Method was a response to that agenda, and after a slow start,3 we are seeing some positive effects,4 notably in terms of the Standard Method and pathway for development provided by Grey Belt. However, the core of NPPF policy - the Presumption – was little changed by last December 2024's document, despite the Labour Manifesto having included reference to it being “reformed and strengthened”5. In our analysis of October 2024, we looked at how approval rates for schemes determined under the Presumption were falling and highlighted the significant levels of decision making uncertainty for: 1 how a proposal performs against specific policy tests based on interpretation of technical evidence and the significance of any breach or compliance; 2 The weights given to various material considerations in balancing harms versus benefits; and 3 The overall conclusion one reaches in the planning balance. In simple terms, in the period since 2012, effective decision making has developed a resistance to the Presumption much as bacteria has evolved to outsmart or resist antibiotics. We made various suggestions for the next NPPF 'presumption' to aciheve its objectives for housing delivery, including: 1 Be clearer on goals – hardwire the Government’s objectives into the NPPF; 2 Strengthen the presumption – amend the wording to nudge presumption towards default approval; 3 Prescribe weights for benefits – for example, substantial weight to key benefits like homes; 4 Address size relativity - Confirm that housing benefits apply equally to small sites; and 5 Limit Weight on Non-Valued Landscapes make clear that harm to ordinary countryside or non-designated landscapes should carry only limit-

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ed weight, reducing subjectivity and uncertainty. Against these suggestions, this blog looks at how do the proposed changes to the NPPF measure up. Further, there has been a recent debate (not rehearsed here) about whether new National Development Management Policies should be ‘statutory’ as per s.93 of the LURA, or can be nonstatutory as per the current NPPF. The Government has settled on the idea that, at least for now, they should be non-statutory which means they operate much as per the current NPPF, within s.38(6) and the primacy of the development plan. In due course, new streamlined local plans should create a simpler decision making framework, but with these some years away, does the new NPPF include the provision necessary to achieve the goals of streamlining and simplifying decision making against existing development plans?

We turn to each of these topics in turn. Clearer goals? The new Introduction The introduction to the new NPPF does not set out an overarching explanation for the national context within which the documents sits nor the goals of the changes. Rather, it provides a user guide to the new format structure and context of the NPPF. There is no reference to 1.5 million homes, the housing delivery emergency we find ourselves in, or the vital importance of economic growth to national renewal, or indeed to other important goals. This is a missed opportunity to ‘hardwire’ the national mission into decisions which will ultimately rely on the aggregation of individual decisions on plans and applications based on judgements and weightings. However, the draft does acknowledge at paragraph 7 that “Some of these policies indicate how much weight the government would expect a particular consideration to be given, including cases where it is appropriate to give substantial weight to certain benefits, and the limited circumstances in which it is expected that permission would be refused.” This is a subtle but potentially clear steer that less judgement and more formulaic decisionmaking is being created through these proposed changes. A Stronger Tilt? ‘Substantial’ vs ‘Significantly and demonstrably’ Gone is the current NPPF paragraph 11d); now we all hail the proposed national decision-making policies S3, S4 and S5. The wording of the proposed new presumption has been strengthened. The proposal is now that development should be approved “unless the benefits of doing so would be substantially outweighed by any adverse effects”. Under the current NPPF, in applying the presumption, any adverse impacts of a development would need to “significantly and demonstrably outweigh the benefits” to be refused.

We note, firstly, that although perhaps making no practical difference, the subtle reordering of the sentence makes it more positive, i.e. the benefits would need to be outweighed, not adverse impacts having to outweigh benefits. Secondly, the proposed wording changes the tilt from “significantly and demonstrably” to “substantially” which seems important. Clearly this may well find itself being interpreted by the courts, but on face value it looks like a strengthening: a stronger tilt towards approval. A root through the dictionary indicates the word ‘significant’ equates to something that has meaning, is important or noteworthy. ‘Substantial’ equates to being of considerable importance, scale or value. When applied to ‘weight’ in the planning balance, 'substantial' sits above ‘significant’ in the scale. Arguably one might interpret this as nudging the planning judgment required in the presumption from something which is currently more discretionary, to something which is more quantitative. The presumption is also proposed to widen across more circumstances (see Policy S3: Presumption in favour of sustainable development). An out-of-date plan or unmet need (via the Housing Delivery Test outcomes) or a lack of five-year housing land supply (5YHLS) is no longer determinative for the presumption to apply in many circumstances. As proposed, the presumption applies on all development proposal sites (including within settlement boundaries- see Policy S4: Principle of development within settlements), except for some circumstances for development outside settlement boundaries, as set out in Policy S5: Principle of development outside settlements. Policy S4 Part 1, expects development proposals to be approved within settlements unless the benefits would be substantially outweighed by any adverse effects. It goes on at Part 2 to stipulate what these adverse impacts might be which is defined relatively narrowly. Policy S5 provides a list of “certain forms of development which should be approved outside settlements”. Part h) relates to development for housing and mixed-use development which would be within reasonable walking distance of a railway station (on which we have a separate blog), but the most interesting is part j) which confirms the presumption applies to the: “j. Development which would address an evidenced unmet need (including, but not limited to, development proposals involving the provision of housing where the local planning authority cannot demonstrate a five year supply of deliverable housing sites or scores below 75% in the most recent Housing Delivery Test), and where the development would: 1 be well related to an existing settlement (unless the nature of the development would make

this inappropriate) and be of a scale which can be accommodated taking into account the existing or proposed availability of infrastructure; or 2 comprise major development for storage and distribution purposes which accords with policy E3.” This means a housing development proposed outside a settlement boundary where there is lack of 5YHLS, or failure or unmet needs via the HDT outcomes, subject to parts i) and ii) above, should be approved. The Policy goes on at part 2 to stipulate (much in the same way as Policy S4) the circumstances when such development proposals are likely to be substantially outweighed by adverse effects, these include: “situations where the development proposal would fail to comply with one of the national decision-making policies which state that development proposals should be refused in specific circumstances.”6 Even more interestingly in the context of housing development, part 4 of the Policy refers to any other development proposals which do not fall within the categories a) to j) “should only be approved in exceptional circumstances, where the benefits of the proposal would substantially outweigh the adverse effects, including to the character of the countryside and in relation to promoting sustainable patterns of movement.” No such reference is made to the character of the countryside in the context of housing and mixed-use development which would be within reasonable walking distance of a railway station nor housing where there is a lack of 5YHLS or a failure of the HDT. This does mean, that proposed residential developments outside settlements where there is a 5YHLS and no HDT failure, would only be approved in exceptional circumstances. As a first cut, we have attempted to capture the clearer structure of the new presumption – and how it applies - within our decision tree here:7

As set out earlier in this blog, these proposals go further and stipulate weight the government would expect a particular consideration to be given, notably for housing delivery and business growth. Policy HO7: Meeting the need for homes, applies substantial weight to “providing accommodation that will contribute towards meeting the evidenced needs of the local community, taking into account any up-to-date local housing need assessment, and other relevant evidence (including the extent to which there is a five-year supply of deliverable housing and traveller sites, and performance against the Housing Delivery Test).” On face value, could this mean that a disagreement on housing mix might reduce the weight to be applied to housing delivery if what is proposed differs to an local plan evidencebased document? The extent of 5YHLS shortfall is often cited as a reason under the current system which impacts the weight to be given to the delivery of housing, but in the context of the national imperative for the delivery of homes, is this appropriate? The current NPPF 2024 at paragraph 85 requires significant weight to be placed on the need to support economic growth and productivity. In the proposed NPPF, substantial weight is ascribed in Policy E2: Meeting the need for business land and premises to: 1 “The economic benefits of proposals for commercial development which allow businesses to invest, expand and adapt; especially where this would support the economic vision and strategy for the area, the implementation of the Industrial Strategy, support improvements in freight and logistics and/or reflect proposals for Industrial Strategy Zones and AI Growth Zones; 2 Benefits for domestic food production, animal welfare and the environment which can be demonstrated through proposals for development for farm and agricultural modernisation.”

https://www.dropbox.com/scl/fi/5cbz2beuxahlxivdupk91/Lichfields-decision-

How will the new Framework sit alongside the development plan? The Government wants the Framework and new NDMPs to apply immediately from its publication in final form (Annex A: Implementation para 1). The Annex (para 2) includes the provisions that: Development plan policies which are in any way inconsistent with the national decision making policies in this Framework should be given very limited weight, except where they have been examined and adopted against this Framework. Other development plan policies should not be given reduced weight simply because they were adopted prior to the publication of this Framework. This is a strong indication that, within the framework of s.38(6), the Government intends the new NPPF, once adopted, to significantly reduce the salience of policies from existing local plans, including

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The fly in the ointment for those seeking an NPPF that maximises the prospect of housing delivery, is the Annex A transitional provisions which at para 3 provide protection for Local Plans adopted in the past five years and which, in those areas, for the rest of this parliament will bake in the Gove-era housing legacy that the current Government is so keen to say it has replaced. We explore this further below.

Attributing weights to benefits and harms At present, while the Framework ascribes some specific weights to some different harms and benefits, the majority are left to the judgement of the decision maker. Meaning the Framework is not collectively guiding decision makers on the support necessary to deliver 1.5 million homes or turbo charge the economy.

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those that are yet to be adopted pursuant to the December 2024 NPPF transitional arrangements. This is arguably about as far as the Government might have been expected to go to within the current legal framework in pursuing the original idea behind NDMPs that originated in the 2020 White Paper and led to s.93 of the LURA. That said, the new NDMPs clearly rely on existing settlement boundaries in existing local plans to define the circumstances in which policies S4 and S5 apply, so insofar as these are based on policies examined and adopted prior to any new Framework, these continue to attract significant weight, with development outside settlement boundaries. In this regard, it is of some concern that Annex A para 3 is clear that where ‘unmet need’ is a precursor for developing new homes under Policy S5(1)(j), this is determined based on HDT and the five year housing land supply performance against targets in adopted plan for five years from adoption, even if this is lower than the current Standard Method. Under current wording, this applies even to local plans prepared under previous versions of the Framework, including an estimated 39 Local Plans that have been adopted or remain under examination since July 2024 many of which were advanced by those Councils specifically in order to bake in lower housing targets than would now apply under the current Standard Method – in other words to plan for fewer homes. Our analysis is that the housing targets across these 39 Local Plans are 15,411 homes less per annum than the Standard Method for those areas, and many will also avoid addressing unmet housing need. Annex A para 3 thus has a combined opportunity cost for housing delivery of around 77,000 homes across five years. The Government seeks to address this through its provisions at Annex D Para 9 with the 20% uplift on five year land supply. But amidst the general boldness of the new NPPF proposals, this seems a curiously tentative misstep.

Summary and Conclusion The Government’s latest NPPF proposals introduce significant reforms aimed at accelerating housing delivery and simplifying decision-making with a clearer ‘rules-based’ approach. The specifics of individual policies will need to be considered further, and its effects will depend on how it is considered in the round for different forms of development and location. However, it represents, without doubt, the clearest and most coherent formulation of national policy for decades. Ahead of new strategic and local plans emerging, the policies for decision making will have the greatest impacts on what actually happens on the ground. In this blog we focus on the Presumption and do not address the significant body of proposed policies focused on improving the performance of preparing >>>

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>>> and determining applications (Policies DM1 – DM7) which look to contain a number of welcome measures. There are also issues to be considered in terms of how ‘unmet need’ is demonstrated for economic growth in E2. Central to the changes is a strengthened Presumption in which its structure and the tilted balance component significantly shifts from its 2012-era. Among the changes is amending “significantly and demonstrably” to “substantially outweighed,” creating a clearer tilt toward approval, and applying the Presumption across more circumstances. The draft framework also prescribes substantial weight to housing and economic growth benefits and makes clearer which factors/circumstances will make refusal more likely, reducing some of the inherent subjectivity in planning judgments. While NDMPs will operate non-statutorily within the current legal framework, they are intended to kick in immediately on formal adoption, with limited weight applying to existing Local Plan policies that are in any way inconsistent. It creates a fighting chance of addressing some of the delays and obfuscation that has driven up delays in planning decision taking since 2014, although other factors – notably around nature recovery and utilities - remain to be addressed. Provisionally, we can say that the impact for housing delivery should be significantly positive (at least in the medium term) but that is moderated by the Annex A transitional provisions protecting recently adopted local plans, which risks constraining delivery in at least 39 separate areas by an estimated 77,000 homes over five years. n FOOTNOTES [1] Thanks to Microsoft 365 Co-Pilot [2] Recollections vary as to when this ancient custom began, but who can fail to remember the December 2022 NPPF consultation which downgraded housing targets. [3] See for example this BBC analysis of the lagging indicator that is permissions [4] See this Planning Portal Analysis up to September 2025 [5] See Labour Manifesto here [6] These policies are: Policy TC3(4): Main Town Centre uses outside town centres failing sequential test or significant adverse impact on TC4 Policy M5(1): Proposals for the extraction of peat at new or extended sites Policy L3(4): Do not make efficient use of land Policy DP3(2): Not well designed Policy HC5(1): Hot food takeaways or fast-food outlets failing a) and b) Policies F6(1)(a) and F7(2): Flood risk Policy N2(2): Significant harm to biodiversity Policy N6(1)(a) and (2) : affecting site of international importance or loss of irreplaceable habitats Policy HE6(4): substantial harm to, or the total loss of, the significance of a designated heritage asset [7] We won’t have got this right, so comments welcome!

Planning in London

Major consultation on a revamped NPPF Housing Secretary pledges to 'go further than ever before' to hit 1.5 million homes MHCLG: • Thousands more homes to be built faster in every region thanks to biggest rewrite of planning rules in over a decade • Changes include saying ‘yes’ to brownfield, ‘yes’ to building around train stations and ‘yes’ to building more blocks of flats, alongside cutting costs and delays for housebuilders and businesses of all sizes • Accelerating government ambitions to build 1.5 million high-quality homes with the right infrastructure, creating new jobs and boosting clean energy Hundreds of thousands of new homes will be built under the biggest housebuilding surge in a generation thanks to the most significant rewrite of planning rules in more than a decade. Having already reversed anti-supply measures in the National Planning Policy Framework (NPPF) last year, the government is going further to make the system clearer, more predictable, and faster to build 1.5 million new homes over this Parliament. New changes unveiled on 16th December will help optimise land use through well-designed, higher-density development, simplified biodiversity rules for smaller sites – and fast-track good housing projects that meet national standards for energy efficiency. With families and children stuck in temporary accommodation and young people locked out of home ownership, the only way to start fixing this for good is to build thousands more good-quality homes in every region. And today’s proposals directly build on the immediate and urgent steps already taken to fix a planning system that too often has blocked rather than built. Key revisions include: • A default ‘yes’ to suitable homes being built around rail stations, alongside minimum housing density rules. • Providing the same ‘yes’ to new homes building upwards in towns and cities, fast-tracking development schemes that meet high standards for welldesigned homes. • Making it easier for developers – particularly SME builders – to build higher density housing, such as modern apartments and flats, on smaller sites and under-used land where appropriate.

• The new ‘medium site’ category for sites between 10 to 49 homes so SME builders face proportionate rules and costs for their site size – including considering a possible exemption from the Building Safety Levy. • Streamlining standards on energy efficiency and Biodiversity Net Gain to give builders certainty on plans for new homes. • Encouraging a more diverse mix of housing, such as rural affordable homes and accessible homes for older people and those with disabilities, providing certainty for developers to meet the housing need of every group across local communities. • New builds to include nature-friendly features, such as installing swift bricks, to support wildlife – adding little to building costs whilst delivering a win-win for nature and housebuilding. • Preferential treatment for developments that strengthen local economies and provide new services, including shops, leisure facilities, and food production. These measures will pave the way for a stable, rules-based system where developments that meet clear standards can move quickly from plans to construction – the most significant rewrite of national planning policy in over a decade. The new rail and densification policies are expected to unlock a potential 1.8 million homes in the coming years and decades. To ensure these changes make an immediate difference, the government is proposing that they effectively override conflicting policies from day one, so everyone is working from the same rule book. This is another major step forward in the government’s unrelenting focus to build 1.5 million highquality homes, create jobs, and bolster clean, homegrown energy in every corner of the country – tackling record-high housing waiting lists and supporting the dream of homeownership for working families. Chancellor of the Exchequer, Rachel Reeves: “For too long our economy has been held back by a housing system that slows growth, frustrates business, and prices the next generation out of a secure home. These reforms back the builders not the blockers, unlock investment and make it easier to build the 1.5 million new homes across every region – rebuilding the foundations of our economy and making affordable homes a reality for working people once again.”

Here’s what some of the commentators think Paul Belton, partner with Carter Jonas (Cambridge) said: “Following a raft of changes to the NPPF introduced in December, these latest proposals represent a fuller and more definitive update to national policy to support development and help create and grow good places in which to live and work. The draft NPPF is said to mark the culmination of a sustained push over the first period of parliament to overhaul the planning system. The draft seeks to hard wire a set of clear, more rules-based policies to make planning policy easier to use, underpin the development of faster and similar local plans and be more directive of decision making in support of both appropriate housing and commercial development. From a quick review it is clear that some policies are fine tuning proposals introduced last year, whereas other proposals are more radical. It is clear that the Government is committed to overhauling the planning system, streamlining processes and providing a policy framework that is equipped to boost housing and economic growth. The idea of easing the burden on small and medium sized development will be welcomed by many while ideas such as a presumption in favour of proposals near to well-connected train stations could also open up new opportunities. Any approach to tackle issues relating to infrastructure shortfalls will also be welcome to the development industry as a whole.” Ben Standing, Partner in planning at law firm Browne Jacobson: “It’s clear that with the government putting its pledge to build 1.5 million homes at the heart of its economic growth ambitions, it’s pulling on every lever it has control over by making sweeping changes to environment regulations and planning policy. “The latest consultation on an amended NPPF – which comes just a year after publishing a revised version – brings forward significant changes to how planning decisions are made by local and national government. “In particular, there is a targeted push to unlock small and medium-sized plots of land for development by creating a new ‘medium’ category for sites, exemptions for smaller sites from biodiversity net gain regulations and new benchmark land values. “These are often regarded as the most difficult

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sites to bring forward for development due to land costs and local opposition. While the government wants to introduce a permanent presumption in favour of suitable development, it must be mindful of how councils and developers engage communities early on so that valid concerns are mitigated ahead of construction work. This can ensure local people feel they are benefitting, not suffering, from national development targets. “More broadly, there is a danger that constant planning policy flip-flopping actually holds back development rather than accelerates it. In our experience, regular significant changes to the system creates uncertainty for developers on how to cost these in, while local authority planners require sufficient guidance so they can make good decisions. “Planning policy will only ever be one piece of the jigsaw in the government’s quest to build more homes. It must address the viability problem by tackling the wider economic and skills challenges that make construction so expensive.”

Planning Director at the Home Builders Federation, Catherine Williams: “The draft NPPF reinforces Government’s commitment to reforming the planning system and removing barriers to homebuilding, retaining a clear focus on sustainable development while protecting the natural environment. Proposals to reduce the complexity should help to reduce delays, speeding up the time it takes to get permissioned sites to the point when homes can be built and giving some much-needed encouragement to a dwindling number of local SME home builders. This progressive approach is urgently required if the industry is going to reverse the trend of recent years that has seen a decline in the number of homes being consented.”

Chair of Berkeley Group, Rob Perrins: “Our country’s housing supply is constrained by the layers of overlapping policies and regulations which make it impossibly slow, complex and expensive to build homes. We commend these positive reforms which, once adopted, will help to rationalise this dysfunctional system and create a more consistent and certain process that actually delivers the high-quality private and affordable homes people need at real scale and pace.” Chief Executive of Urban&Civic, Nigel Hugill: “All experience is that establishing clear presumptions has a material impact on both the direction and the operation of our planning system. We welcome these proposals as addressing the treacle in the existing system which unnecessarily slows down decision making and delivering for our communities.” Chief Executive and Executive Chair at Vistry, Greg Fitzgerald: “This is further evidence of this government’s welcome continued commitment to modernising and streamlining the planning system. At a time when families are stuck in temporary accommodation and young people are locked out of homeownership, delivering thousands of good quality homes in every region is essential to fixing the housing crisis for good. The new National Development Management Policies and refreshed National Planning Policy Framework will protect quality and encourage delivery at pace. Importantly the changes will provide the clarity needed to take bold decisions, support environmentally responsible new homes and enhance local services. We now need local councils to respond swiftly and grant the permissions required to unlock sustainable and thriving communities.” n

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LETTERS

A contribution by Paul Finch at the September Forum led to an outbreak of professorial correspondence... and so it continues

Responding to a London house-building crash From Professor Michael Edwards, Bartlett School, UCL This note takes off from an exchange (PIL 2025, 24-25 ) with Paul Cheshire and should start with an appreciation. The various analyses which Cheshire and his collaborators have done over the years have fascinated me and they flesh out my grasp of the political economy of UK housing. Differences come from a difference of standpoint. My long view of British land and property problems is to remember the continuous history of class relations from mediaeval times without intervening revolutions or major reforms. Elites have always captured and shaped laws and institutions. Planning laws, tenure forms, green belts, conservation and other measures add to the restrictive powers of property owners to exclude what they do not want or to increase the scarcity of what they have – and to harvest the rents they can secure from new development or from the standing stock. The planning system and policies are but one of the mechanisms which underpin the resulting rentier economy; the other role planning plays is of course in providing the necessary infrastructure. I have learned a lot from Cheshire’s, and other people’s, analyses about how house prices are affected by the income elasticity of demand, by conservation areas, by proximity to free public facilities where quality is deemed to vary (schools especially). I’ve also learned a lot from studies of how developers restrict access to building land in provincial England through the use of opaque options

Planning in London

(Colenutt 2020). In metropolitan England we are also afflicted by the scale of the agglomeration economies generated in London and the tendency for these economies to be harvested as land values and house prices by the simple operation of πr2 : central land is fundamentally scarce and when it runs out the state will provide more railways to enlarge the effective city. But is the long complex accumulation of land rights quickly reversible, especially now that residential (home and land) values are such a central underpinning of the banking system and of the strategy of so many households? Simply reducing the discretion for planning committees to ignore policy would achieve little additional housing output; policies themselves would have to change radically and even the advocates of deregulation admit that it would take decades for house prices to be detectably lower because such falls would likely be dwarfed by speculative price inflation. It’s also now clear that building our way towards affordability through massive national target-setting would consume more of the UK’s carbon budget than is conceivably available (zu Ermgassen and others, 2022). The failure of land and house prices to fall much as demand declines is a serious problem. The current major setback for newbuild sales doesn’t seem to be producing the falls in land values which would be necessary to end the pursuit of house-price growth as an incentive. It doesn’t seem even to enable developers to discount what they pay for sites to reflect rising standards and costs. The government and Mayor in their emergency

Michael Edwards is an Hon Professor at the Bartlett School, UCL

responses to the declines in the London market have chosen all the wrong things: propping up prices and caving in to developers’ calls for lower standards and reduced land value capture. What could they have done instead? Developers have always argued that increased production for the market would bring prices down and that their high rates of profit are a just reward for taking risk. Here we are with prices falling and the authorities could have waited for the prospective affordability improvements to follow. Waiting for these benefits to filter through in the absence of a crash was always going to be so slow that it would be swamped by actual house price inflation. Other things which government and Mayor could have done would have been to remove some of the blockages which are leaving so many London flats unsold or incomplete. They could accellerate the implementation of commonhold and the extinction of leasehold; they could transform the quality controls in construction and insist on a robust system of guarantees on new dwellings. They could have allocated more funds to the acquisition of already-completed and part-built homes for

Professor Paul Cheshire is Emeritus Professor of Economic Geography at the LSE

A plan for London’s housing crisis social renting by councils and other non-profit providers. The Mayor on his own could signify that his next London Plan will bear down heavily on speculative bidding in the land market by reinstating strong upper limits on density and building height, removing some of the uncertainty which developers (and community groups) so dislike. He could, and should anyway, redefine housing targets in terms of square metres or rooms, rather than ‘units’. The current pursuit of units (dwellings) gives us far more small flats and fewer large ones than would be required to meet social need. Better still he could signal a presumption against demolition of structurally sound council homes to swing effort towards maintenance and retrofitting. Landed interests would respond ‘where would London’s growth be acommodated?’ Perhaps London has acommodated enough and some serious debate on regional re-balancing is overdue (Edwards 2025). Michael n Colenutt, B (2020) The property lobby Bristol, Policy Press Edwards, M (2025) Rent, Agglomeration, and the Economy of London The Value of Place: exploring regional development and land use strategies F Moulaert and A Mehmood. London, Edward Elgar zu Ermgassen, S, M P Drewniok, J W Bull, C M Corlet Walker, M Mancini, J Ryan-Collins and A Cabrera Serrenho (2022) A home for all within planetary boundaries: Pathways for meeting England's housing needs without transgressing national climate and biodiversity goals. Ecological Economics 201 https://doi.org/10.1016/j.ecolecon.2022.107562 PIL (2025) exchange of letters between Michael Edwards and Paul Cheshire Planning in London, 24-25

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From Professor Paul Cheshire LSE London has a real housing crisis. But the Mayor’s still-to-be-consulted on proposals (Nov 27, 2025) to mildly relax the mind-numbingly complex regulations for cycle parking spaces in new buildings, withdraw the ill-conceived, dual-aspect requirements and mildly relax the requirements for the proportion of affordable housing in new developments1, are not the solution. All these are currently significant barriers to building in London but have nothing to do London’s decades-old problem of consistently building too few houses and grotesquely failing to meet targets. As explained in my contribution in the last issue, this failure is not the outcome of such short-term factors (although together they have depressed house building since 2023), but of a multi-generational constriction of land supply and a dysfunctional planning system. The underlying reasons for the unaffordability of housing in London are long term and structural, going back to 1955 when Duncan Sandys (not as the more naïve believe, Attlee’s Labour government) promoted the Metropolitan Green Belt and stopped all house building in the Home Counties, so protecting Conservative seats. This action froze the supply of housing land, not only in a 480,000 ha area surrounding London – its whole natural urban hinterland – but also land supply within it. As was shown in London First (2015) there are over 33,000 ha - 23 percent of the GLA area - of Green Belt inside the GLA itself, so off limits for building. Much of this is accidental – left over from the old LCC before WWII which bought up land as green lungs for Londoners. They managed to buy 20,000 ha. but no rights of access were secured. When the LCC was abolished in 1965, the land passed to the Boroughs. Bromley, for example, acquired great tracts, so that 52 percent of its area is still classified as Green Belt, mostly now farms

owned and rented out by the council. Further expanses of Green Belt land in London have been converted into golf courses – our system allows this but not building on it – except, perhaps, for club houses. The area of golf courses inside the GLA is double the size of the Borough of Kensington and Chelsea (London First, 2015). Before the Green Belt froze our urban land supply and before the 1947 Act turned building houses into a lottery decided by local politicians, it was a regular yearly event to build more than 75,000 houses in the area now covered by the GLA: an annual average of 76,055 was built over the four years 1934 -37. This compares to less than 25,000 a year for the four years 2014 and 2017 or 31,000 a year for the decade from 2014. The recent announcement by the MHCLG (18 Nov 2025) that: “Housebuilding near well-connected train stations will receive a default “yes” in future if they meet certain rules, ensuring more homes are built” provides a real opportunity for the London Mayor to finally do something about building houses. Just building on land of no amenity, environmental or recreational value within 800 metres of stations within the GLA boundaries, would release 3,055 hectares of land: at a conservative allowance of 40 dwellings per ha. that is enough for 122,200 additional homes (see Cheshire and Buyuklieva, 2019, or https://www.centreforcities.org/data/buildableland-commuter-stations/). That is four times the annual rate for the decade from 2014, seven times the rate of the dismal and unacceptable performance of the past two years. The problem is that like Labour’s other planning reforms, the new guidance assumes the existence of local plans and local willingness to allow houses to be built. In the NIMBY LAs surrounding London both these ingredients are missing. But London Boroughs mainly do have a valid plan and the GLA, at least, >>>

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claims to be in favour of building houses. Sevenoaks has history for finding neither ‘well-connected’ stations nor land near them. At a planning appeal in 2021 the LA claimed Knockholt, a Zone 6 station with a 35 minute service to London Bridge, was unsuitable to accommodate more commuters. Without firm and clear guidance from the GLA as to what constitutes a ‘well-connected station’ and how near a proposed development must be to be called ‘near’, there may be London Boroughs with plenty of suitable Green Belt land equally unwilling to find any land ‘near’ ‘well-connected’ stations. So, the latest guidance from the MHCLG provides a prize opportunity for the GLA to take decisive action and provide a clear-cut, London-wide definition. Uncertainty is the enemy of development. Our existing planning system, by making all decisions discretionary, injects uncertainty everywhere, greatly reducing the volume of construction. Decisive action by the GLA on interpreting the new guidance would eliminate one source of uncertainty. Unfortunately, the Mayor seems unable to recognise another, equally damaging source of uncertainty facing developers: what will be the planning obligations imposed under S106 Agreements? Here there is an easy win. Impose a stonking Green Belt building levy instead of S106 Agreements and insist the proceeds are devoted to local infrastructure and additional publicly funded social housing. If the Mayor really wanted to get the structure of incentives aligned, he could make the size of the levy – say 30 percent of the market value of the development – fall with the speed of construction. For example, the 30 percent levy could be reduced by 1 percentage point for every month less than 18 it took to deliver the houses.

Conclusion If London’s housing affordability crisis is to be improved the vital thing is not to build more ‘affordable’ houses – particularly if any are at the expense of other houses. As Gleeson (2023) showed, the vital thing is to build as many houses as possible. The more we build the more affordable they will become. The sacrosanct preservation of the Green Belt has been accepted by successive London mayors but the new government guidance of a presumption in favour of development near well-connected stations gives the current Mayor a fantastic opportunity to actually get more house built. The new guidance, to be effective, requires active implementation by LAs. This will not happen without appropriate measures taken by the GLA. These measures are needed to provide certainty as to where exactly such land is but also to align incentives so the private sector gets on with the job and at the same time generates funds for proper social housing. Paul n

Planning in London

Consensus, dissensus and puzzlement in reactions to Mayor Khan’s pre-Plan consultation Professor Ian Gordon is Emeritus Professor of Human Geography, Department of Geography and Environment LSE

From Professor Ian Gordon, LSE Away from the City Hall control centre, there has been one strong consensual theme to the past sixmonths of debate over the Mayor’s Towards a New London Plan1. This has highlighted housing as the key problem element, with an ever-grow-

>>> Footnote 1 All these are illustrations of the destructive power of good intentions. As a life-long London cyclist I have always found solutions to parking my cycle and Brompton has hugely helped but put well-meaning bureaucrats in a room and they can draft a 50 page document on the subject. Developers and planners then have to read, digest and implement these rules. There are 15 different requirements for spaces per new dwelling depending on location and dwelling type and these are complemented by detailed definitions of the space, design and location of cycle parking facilities. For example, a cycle requires a space of between 0.7 and 1.4m2: but this depends on a raft of other regulations. As if designing, getting planning permission and then building a house was not difficult and uncertain enough already.

ing supply deficit - despite the promises of previous London Plans – sharply raising living costs for all, except earlier owner-occupiers. And evidenced a general lack of faith in any credible strategy being offered to get a stronger grip on this issue in the next one. The fact that the government seems to want an instant turnaround in deliver- >>>

References 1 Cheshire, P. and Buyuklieva, B. (2019), Homes on the Right Tracks: Greening the Green Belt to Solve the Housing Crisis, London, Centre for Cities. 2 Gleeson, J. (2023) The affordability impacts of new housing supply: A summary of recent research, GLA Housing Research No 10, GLA August 2023: 3 London First (2015) The Greenbelt: A place for Londoners?, London: London First. 4 Mayor of London (2025) Consultation Opportunity – Support for Housebuilding LPG 27 Nov 2025: https://www.london.gov.uk/programmesstrategies/planning/implementing-london-plan/london-planguidance/support-housebuilding-lpg 5 MHCLG (2025) 18 Nov 2025: https://www.gov.uk/government/news/housebuilding-around-train-stations-will-begiven-default-yes Professor Paul Cheshire is Emeritus Professor of Economic Geography with a longstanding interest in the economics of housing, land use and land use planning. He is a former member of the Board of the National Housing and Planning Advisory Unit for whom he acted as interlocutor for London.

ies, whereas current output levels had collapsed, has heightened the stakes. But maybe also distracted attention from the consultation document’s disregard for the question why a series of previous London Plans have fallen far short of their housing targets - even when problems had been clearly pointed out by the Plans’ professional Examiners, and in the Outer London Commission’s set of briefing reports for an incoming Mayor in 20162. Despite such shared frustration, much of the recent debate in forums such as this has involved groups of participants clearly talking past each other – with a cleavage not simply reflecting degrees of pessimism but rather two radically different beliefs about how the contemporary London housing system functions, which colour judgements as to the sorts of strategy that are feasible and relevant to escaping the trajectory of evident failure. On one side of this divide, are those who think in terms of a basically dual (social and market) system, roughly recognisable from the GLC era. Normatively, this emphasis reflects an enlarged gap between market housing costs and the financial resources of many Londoners in what continues to be a very expensive and unequal city. The capacity of social agencies to respond to the scale and incidence of need, independently of market pressures, depends on two sorts of power that have been eroded - some legal entitlement to compulsory purchase of sites at existing-use value; plus continuing social ownership, with no occupiers’ right to buy – and plus massive financial support. Even with the best (Mayoral/national) will behind it, starting from a status quo with a very attenuated social sector, restoring that kind of capacity via (targeted) new construction would be incredibly slow. The other model starts from a recognition that – since Thatcher – the housing system in (and around London) involves a whole panoply of more-or-less integrated (sub-) markets, for different kinds of product, in different places – and with different time horizons. But with a great deal of interaction across these, as individuals respond to availabilities and to the responses of others faced with shifting sets of opportunities. The degree to which these interactions actually spread impacts across the boundaries between more/less affordable market segments – and across wider areas – was very clearly shown a couple of years ago in a fine GLA Housing review of local studies in comparable kinds of location. From this perspective, the headline issue is one of degrees of general (un)affordability, that swing up/down, but have got markedly worse, both for those at the top/bottom and in inner/outer areas. Within this framework, affordability is more of a macro-issue than one that can be addressed incrementally/piecemeal via targeted construction. On the demand side pressure on prices comes

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partly from the growth performance of the London economy – that few might want to check – plus boosts to the liquid assets of the rich (notably via QE) that London agencies can scarcely touch. Whereas the elasticity of supply of (desirable) sites is something they can more clearly do something about, notably by easing the rigidity of Green Belt development bans. As academics have long argued and the Mayor seems to have been led to accept, nine years after the Outer London Commission advised him so to do Taking Markets Seriously as the Missing Key to Planning Strategically for London A market-wide perspective on affordability as the issue - rather than securing a quota of identifiably “affordable” dwellings within inevitably marginal additions to the dwelling stock – has two other important (and genuinely strategic) implications that have yet to be picked up by the Mayor. One of these, which was also core to the OLC’s advice, is spatial -the need to engage with functional region authorities and actors across the (very much) wider housing market region. This is basically because locational responses to relative shifts in the supply/demand balance, and (hence) prices, are transmitted through chains of mobility and interaction. A key example, with several important lessons, was the move by the Blair government 25 years ago, to reinforce urban compaction, with a strong prioritisation of brownfield sites. This bit most strongly in outer areas of the Wider South East (WSE) beyond the Green Belt, with least direct effect within London areas with minimal (unrestricted) green areas liable to be built on. Dwelling prices went up strikingly right across the region, however, encouraging denser patterns of development, most dramatically within the metropolitan core. Inside London, however, the numbers of completed dwellings barely increased – and the net effect across the WSE was much more strongly negative than policy-makers can have anticipated3. The reason for disappointment/miscalculation on this score was not, however, simply a lack of attention to the connectedness of housing/development markets across a much wider area. But also a neglect of the other strategically crucial dimension of action in these markets, namely time. Tightening constraints raises the likelihood of a sustained upward trend, so long as the region retained its economic attractiveness. In which case it would be perfectly reasonable to use densification as a means of maintaining a steady output/income- stream, while conserving sites as an asset for future years, when the expected returns would be at least as great. This case is a reminder (from market behaviour) that planning, especially of complex regions, is supposed to be about the long-run (and trying to avoid short-term crises) - not just extrapolating from

short-term trends, or surveys of actors’ intentions which are always liable to change in such a dynamic market context. Strategic planning needs (a set of) game plans, in which some actions are initiated speedily and opportunistically to get things moving, which could well be the case in the Green Belt context for railway station opportunity areas. But at the same time there need to be lines of development that are less purely opportunistic, leading on to coherent new growth areas (alongside reinforced green ones) with identifiable economic, social, logistic and partnership benefits . And which will not seem to CPRE supporters as simply a chaotic erosion of prized environmental assets, justifying a return to rigid Green Belts, as might well happen. The trouble is that with the retreat of the GLA from any serious engagement with its regional neighbours (since 2019) that might very well be the outcome – which Towards a London Plan’s statement that “ there may be opportunities for joint work to plan for growth across London’s boundary” does little to allay. Some Concluding Worries As I see it, the situation with the London Plan is deeply problematic in relation to housing development/affordability which has become the key issue, both in the city and in relation to Labour’s national policy commitments. The government’s ambitions have been geared to a short-term horizon within which they could not conceivably be realised. Even with major innovations and real learning on the London (or Wider South East) front, of which there is no sign. Before Mayoral planning (as distinct from permissiveness edicts in implementation) can make a substantive difference, the Plan will need formal approval after an Examination in Public, in which government housing targets will clearly figure. Inspectors have previously been (rightly) sceptical about claims in relation to more modest targets but have given the Mayor’s judgement the benefit of the doubt. It is hard to see that being repeated. And I see no sign that the GLA is girding up to/preparing the ground for the kind of long-term, sustained and regionally co-operative action that successful strategic planning for such a sophisticated and nationally crucial region demands. Ian n FOOTNOTES 1 Outer London Commission (Chair Will McKee) Seventh Report: Accommodating London’s Growth: executive summary, GLA, March 2016. 2 James Gleeson ‘The affordability impacts of new housing supply: a summary of recent research’, Housing Research Note 10, GLA Housing and Land, August 2023. 3 Ian Gordon ‘Finding sustainable bases for metropolitan Green Belt reform’, pp. 103-107, Town and Country Planning, March/April 2019.

pil136 January-March 2026

Planning in London

BRIEFING: CLIPBOARD

CLIPBOARD

Consultation on changes to VAT treatment of social housing sites welcomed The government’s pledge to revamp VAT rules on land intended for social housing has been welcomed by the Housing Forum and National Housing Federation (NHF). Budget documents said: “The government will shortly consult on the reform of VAT rules to incentivise the development of land intended for social housing.” The Housing Forum, which has long argued that changing VAT rules could unlock more homes, said: “We are also very pleased to see a consultation on the VAT treatment of sites destined as social housing. This is something we’ve been calling for, and will help ease cash flow pressures.” Currently, in order to qualify for zero-rating VAT on the sale of land to a housing association the developer must have started work beyond the foundations. If the land is sold before this point there is an irrecoverable VAT cost for the housing association. The Housing Forum argues this forces developers and RPs into more complex legal arrangements and makes it hard for RPs to get involved at an early stage. It has also said it delays RPs’ access to grant and causes cash-flow issues for developers. A spokesperson for the NHF said: “This is welcome and we think it will improve efficiency and viability, and was something we wrote to the government about ahead of the budget.” The NHF has said previously that changing the rules so the VAT zero rating applies at the point of land sale, where outline planning permission exists, would overcome “delays, complexities and additional costs.” It said this “could accelerate affordable housebuilding at no additional cost to the taxpayer.” – Housing Today

New land policy changes in the UK An emergency package of measures is coming to London and we as a development sector should welcome the bravery of the Government and City Hall in getting on the front foot. But already some are breaking cover to raise concerns. Let's attempt some myth busting but also have a

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Construction of the HS2 Euston terminus paused in 2023

genuine debate as developers about the facts on the ground: 1) "These measures are designed to protect developer profits": Nope: developers and investors across the London market are taking significant losses on the majority of live schemes. The result of significant cost inflation, poorly timed regulatory interventions, time elongation and weak demand. Losses effect us all, it scares off fresh capital. It's not about profit, it's about giving the sector a chance to recover. Plus profit gets taxed and profit = growth. 2) "land is finite and we should maximise affordable housing on it". Yes land is finite but across the City there is a huge amount of brownfield land and much has been opened up by the brilliant Crossrail upgrade. There are over 200,000 homes consented but stuck. High density development can yield multiples more if we allow it the chance. Let us not let the perfect get in the way of the practical. 3) "developers will bank these less onerous consents and then sit on them until the market recovers." Nope - the measures are time limited and will encourage developers and builders to get shovels in the ground. 4) "the homes built won't be affordable". If we can get the incentives right many of these homes will be for rent. The GLA's own research shows that boosting supply will soften prices. Developments will still need to offer some affordable housing, but everyone recognises that the current thresholds

create negative land value. Moreover, the UK state does not have the cash to build homes, it must encourage others to invest and take the risk. Surely something is better than nothing. Will these measures be a silver bullet? Say's law: supply creates its own demand. Let's see, we all hope it will help. – Nick Cuff on LinkedIn

£360m job at Euston The government has put firms on notice for a £360m design and engineering job for the programme of works at Euston station and the site’s huge surrounding mixed-use development. The Department of Transport (DfT) will launch a preliminary market engagement exercise for the five-year role next month, with a full contract notice to be published on 1 May next year. The appointed team will work with the Euston Delivery Company (EDC), a government-backed entity established to oversee a programme of upgrades to the existing mainline station, enhancements to the London Underground interchange and linked bus and taxi facilities. The EDC is also overseeing the development of the surrounding residential and commercial district, which landowner Network Rail has previously suggested will include a new life sciences cluster as an extension of the nearby King’s Cross Knowledge >>> Quarter.

pil136 January-March 2026

>>>

BRIEFING: CLIPBOARD

CLIPBOARD

The job will not include the new central London terminus for HS2, which is part of the wider Euston masterplan but is being delivered separately through a private finance partner. In a preliminary market engagement notice posted on Friday, the DfT said the appointed EDC design and engineering partner will work closely with Euston masterplanner Lendlease and its appointed design lead Allies & Morrison on the development of the programme. Work is expected to include scheme design on behalf of EDC, large-scale transport engineering design, architectural masterplanning, programme planning and scheduling, cost control, strategic planning and delivery oversight. The appointed supplier will need to have “proven experience in delivering designs for complex, multimodal transport infrastructure” and the ability to “shape and translate early-stage design into feasible and buildable solutions within constrained cost and programme parameters”, according to the DfT. A market engagement exercise conducted jointly by the DfT, EDC and HS2 will be held from the middle to the end of November with the aim of better understanding market interest in the contract and to explore risk appetite, proposed timelines and delivery structures. The exercise will also include potential bid structures for the job, which would likely be delivered by a consortium. Construction of HS2’s Euston terminus was paused by Rishi Sunak in 2023 amid spiralling costs. Work on the line’s tunnel approaches by the SCS joint venture between Skanska, Costain and Strabag is set to begin next year when the TBMs launch. A service tunnel has been dug to the Willesden logistics hub to take the spoil from the tunnels out to waiting trains. – Building Design

Government launches consultation into statutory consultee process In what looks to be a further bid to streamline planning and speed up approvals, the government has launched an eight-week consultation on reforms to the statutory consultee system in England. According to the official announcement, the consultation will look at: • removing statutory consultee status from certain

Planning in London

New headquarters for JP Morgan at Canary Wharf At three million sq ft, the docklands scheme is being hailed as largest office in London Announcing plans by Foster + Partners to design a new headquarters building at Canary Wharf, JP Morgan said the tower will be sited at Canary Wharf’s Riverside development and will run across three million sq ft. It said 12,000 employees will be able to work there when it is completed. The bank said it expected construction to take six years. Fosters was behind JP Morgan’s new headquarters at 270 Park Avenue in New York which was featured in the last issue of Planning in London.

bodies • reviewing the scope of what statutory consultees advise on • improving performance management across existing statutory consultees in the planning system The ministerial foreword accompanying the announcement on the government’s website is blunt in its critique of current performance: “Few would argue that the statutory consultee system is currently working effectively. In far too many instances, statutory consultee engagement with planning applications is not proactive or proportionate, and advice and information provided is not timely… In turn, local planning authorities and developers too frequently provide inadequate or poor-quality information or make blanket and inappropriate referrals to statutory consultees.” Headline proposals include: • Removing statutory consultee status from Sport England, The Gardens Trust and Theatres Trust, with new notification arrangements and guidance to mitigate impacts on playing fields, historic parks and gardens, and theatres. • Refocusing major consultees such as National Highways, Active Travel England, Natural England, the Environment Agency, Historic England and the Mining Remediation Authority on higher-impact cases, supported by clearer referral criteria, more standing advice and better use of digital tools. • Introducing a new performance framework, with annual ministerial meetings and agreed metrics to monitor timeliness and effectiveness. • Reinforcing the role of local planning authorities, emphasising that consultee input is advisory and that

LPAs should be resourced and trained to make confident decisions, including where advice is delayed or not forthcoming. The consultation runs from 18 November 2025 to 13 January 2026, with responses invited via an online survey, email or post. – Planning Portal

AI-nimbyism AI-powered nimbyism could grind UK planning system to a halt. You’ve probably heard whispers about AI transforming industries, but here’s a twist in the planning sector that might just affect your next project. A newly launched service, Objector, is arming residents with “policy-backed objections in minutes.” Yes, you read that right. Minutes. Imagine any planning application you submit, now facing instant AI-powered scrutiny. This tool isn’t just scanning applications; it’s preparing battle-ready objection letters, speeches and even videos, all aimed at swaying planning committees. Where does this leave us? Here’s the reality: AI could slow your projects down. It could even halt them if we’re not prepared. But, as challenges rise, so do solutions. With the right strategy, we can navigate through these AI-infused waters. What about leveraging AI to advance rather than obstruct? Could we counteract, playing the game at its own level? – matt@roavr-group.co.uk . n

¡PILLO!

¡ PILLO!

Where is ‘The Environment’? Here's another thing I don't like: ‘the environment’. People have been going on about this for decades - and it all seems so abstract. Reality is business, the economy and things to do with pensions. By way of contrast, ‘the environment’ is something pious people go on about; to do with, like, trees in Greenland or something. When am I actually needing ‘the environment’? I'm pretty sure I've never even been to ‘the environment’. Where is it? – Caitlin Moran The Times

When will the ONS data debacle end? The number of Britons who left the UK last year is more than three times higher than previously thought, revised figures from the Office for National Statistics show. – The Spectator

Pedestrianising the public realm “Tottenham Court Road, once a destination for furniture, then hi-fi, then computers is now London’s foremost Street market for class A drugs. It is sad really” says Stephen Heath following up the discussion at the LP&D Forum on pedestrianising Camden High Street. “Now Keir also has his own ‘jungle’ to rival that in Calais. I also agree with trams on Oxford Street, or at least something that moves. I do not agree with a MDC for the area because that disfranchises those who live there. I attended the ‘test’ pedestrianisation one Sunday in September and was horrified to find

Third runway: government backs Heathrow The government has given the green light to the expansion scheme designed by Grimshaw and backed by Heathrow Airport Holdings, the airport’s operator. The plans, which will cost nearly £50 billion, include two new buildings connected to the west of Terminal 5, a satellite terminal to the north, and a new runway built over the M25. They were submitted in August in response to a government invitation. The other proposal on the table was submitted by Arora Group, a major landowner at the airport which featured a shorter runway and avoided bridging the M25 motorway, and a new terminal west of Terminal 5. Transport secretary Heidi Alexander said the Grimshaw scheme offered ‘the most credible and deliverable option, principally due to the relative maturity of its proposal’, adding that while Heathrow’s own scheme would require more disruption to the M25, the other plan ‘would also have a considerable impact on the M25’. The government will now update the Airports National Policy Statement (ANPS), which is needed for any plans to progress further.

the freed-up road space being used for stalls, cafes and event spaces. Pedestrians were constrained to the pavements either side and I was left with the distinct impression that the Mayoral intent was not pedestrianisation but generating an income stream by rentalising public space.”

A bit of self-indulgence Not the epitome of global cool Japan's Mori Memorial Foundation, a research insti-

The Tottenham Court Road ‘Jungle’

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tute, has ranked London top of its Global Power City Index, which evaluates the urban competitiveness of major cities, for the 14th straight year. The UK capital may not be considered right now the epitome of global cool. But it has an awful lot going for it. – FT

Planning in London is rarely self-conscious but with this issue’s tribute to Louis Hellman, ¡Pillo! can’t help but mention joint publishing editor Paul Finch’s award in the King’s New Year’s Honours of a CBE for ‘Services to architecture’. And while I’m at it, a long standing member of the London Planning & Development Forum added this to her new year’s greeting: “Many thanks for … the LP&DF where so many useful ideas are presented, discussed and developed. This is particularly important considering the universities seem to become increasingly reluctant to produce public lectures for such a purpose. It is able to bring together a great range of professionals, academics and practitioners to make these events very stimulating. I feel happy to be among them.” – JR n

pil136 January-March 2026

BRIEFING | PLANNING PERFORMANCE

The number of applications made and decided continues to slide from the same quarter last year Latest planning performance by English districts and London boroughs: planning applications in England during July to September 2025 OVERVIEW

Between July to September 2025, district level planning authorities in England: • received 78,800 applications for planning permission, down 3% from the same quarter a year earlier; • decided 76,200 applications for planning permission, down 4% from the same quarter a year earlier; • granted 66,400 decisions, down 4% from the same quarter a year earlier; this is equivalent to 87% of decisions, unchanged from the same quarter a year earlier; • decided 90% of major applications within 13 weeks or the agreed time, unchanged from the same quarter a year earlier; and decided 19% of major applications within the statutory period of 13 weeks, down 1 percentage point from the same quarter a year earlier; • granted 7,100 residential applications, down 3% from the same quarter a year earlier; • granted 1,400 applications for commercial developments, down 9% from the same quarter a year earlier; and • decided 38,700 householder development applications, down 7% from the same quarter a year earlier. This accounted for 51% of all decisions, down from 52% a year earlier. In the year ending September 2025, district level planning authorities: • granted 263,600 decisions, down 4% from the year ending September 2024; and • granted 28,500 residential applications, down 8% from year ending September 2024.

Planning applications received During July to September 2025, authorities undertaking district level planning in England received 78,800 applications for planning permission, down 3% from the same quarter a year earlier. In the year ending September 2025, authorities received 327,000 planning applications, down 3% from the year ending September 2024 (Live Table P134, PS1 Dashboard). Planning decisions Authorities reported 76,200 decisions on planning applications in July to September 2025, down 4% from the same quarter a year earlier. In the year ending September 2025, authorities decided 303,200 planning applications, down 6% from the year ending September 2024 (Live Tables P120/P133/P134, PS1/PS2 Dashboard). Applications granted During July to September 2025, authorities granted 66,400 decisions, down 4% from the same quarter a year earlier. This represented 87% of all decisions, unchanged from the same quarter a year earlier. In the year ending September 2025, authorities granted 263,600 decisions, down 4% from the year ending September 2024. Authorities granted 87% of all decisions, up 1 percentage point from the year ending September 2024 (Live Tables P120/P133, PS2 Dashboard). Applications on hand Authorities reported that they had 109,900 applications on hand as at 1 July 2025, down 4% from the same quarter a year earlier. This is 44% above the number of decisions made during the quarter. The corresponding figure for the same quarter a year earlier was also 44%. Taking account of numbers of applications received, decisions made and applications withdrawn during the quarter gives a total of 108,100 as at the end of September 2025, down 2% from the same quarter a year earlier (Live Table P133, PS1 dashboard). Historical context Figure 1 shows that, since about 2009-10, the numbers of applications received, decisions made

Planning in London

and applications granted have each followed a similar pattern. As well as the usual within-year pattern of peaks in the Summer (July to September quarter) and troughs in the Autumn and Winter (October to December and January to March quarters), there was a clear downward trend during the 2008 economic downturn, followed by a period of stability. There was a large dip in 2020 following the start of the pandemic and a subsequent recovery in early 2021, including a particular peak in applications received, but since the peak there has been a steep downward trend. Regional breakdowns Table 1 shows how numbers of applications received, decisions made and decisions granted varied by region. It also shows how the percentage of decisions granted varies widely by region, from 82% in London to 91% in National Parks and the North East (Live Table P133, PS1/PS2 Dashboard). Table 2 like Table 1 shows how numbers of applications received, and planning decisions made, varied by region. It also shows the percentage change in number of applications received and decided compared to the same quarter a year earlier. The percentage change in the number of applications received varies widely by region, from -12% in National Parks to 5% in North East (PS1 Dashboard). Decisions granted Figure 2 summarises the distribution of the percentage of decisions granted across authorities for major, minor and other developments using box and whisker plots. The ends of the box are the upper and lower quartiles, meaning that 50% of local authorities fall within this range, with the horizontal line in the centre of the box representing the median. The whiskers are the two lines above and below the box that are 1.5 times the size of the box (the interquartile range) with the dots representing outliers. Figure 2 shows that the range between the whiskers for the percentage of applications granted is widest between authorities for major developments (60% to 100%), followed by minor developments (60% to 100%) and other developments (77% to 100%) (PS2 Dashboard).

Planning decisions by development type, speed of decision and local planning authority. All tables and figures can be found here:

https://tinyurl.com/5by4envd Source: DLUHC/ONS Speed of decisions In July to September 2025, 90% of major applications were decided within 13 weeks or within the agreed time, unchanged from the same quarter a year earlier. 19% of major applications were decided within the statutory time period of 13 weeks, down 1 percentage point from the same quarter a year earlier. In the same quarter, 88% of minor applications were decided within 8 weeks or within the agreed time, up 1 percentage point from the same quarter a year earlier. 41% of minor applications were decided within the statutory time period of 8 weeks, unchanged from the same quarter a year earlier. Also in the same quarter, 91% of other applications were decided within 8 weeks or within the agreed time, unchanged from the same quarter a year earlier. 59% of other applications were decided within the statutory time period of 8 weeks, down 1 percentage point from the same quarter a year earlier. Use of performance agreements ‘Performance agreement’ (PA) is an umbrella term used here to refer to Planning Performance Agreements, Extensions of Time and Environmental Impact Assessments (EIAs). The EIA process is undertaken to assess whether a project will have a substantial impact on the environment, with applications having an accompanying Environmental Statement[footnote 3] (see Technical Notes for further definitions of PAs). Between July to September 2025, 41% of all planning application decisions involved a performance agreement. Major developments were more likely to involve a performance agreement compared to minor and other developments with 78% of major decisions involving a planning agreement, compared with 52% of minor decisions and 35% of other decisions (Reference Table 2, PS2 Dashboard). Figure 4 shows, from April 2010, the numbers of decisions on major, minor and other developments made involving a performance agreement, compared with numbers without a performance agreement. Notwithstanding definition changes, there has been a marked increase in the use of agree-

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ments since early 2013 (see Technical Notes for more information). This longer upward trend has been driven by both the additional scope for recording them and their additional use (Live Table P120, PS2 Dashboard). Performance of individual district level local planning authorities The existing approach to measuring the performance of authorities was introduced by the Growth and Infrastructure Act 2013 and is based on assessing local planning authorities’ performance on the speed and quality of their decisions on applications for major and non-major development. Where an authority is formally designated by the Secretary of State as underperforming, applicants have had the option of submitting their applications for major and non-major development (and connected applications) directly to the Planning Inspectorate (who act on behalf of the Secretary of State) for determination. See Improving planning performance: criteria for designation for more information. Speed of decisions The designation thresholds, below which a local planning authority is eligible for designation are: For applications for major development: less than 60% of an authority’s decisions made within the statutory determination period or such

extended period as has been agreed in writing with the applicant; For applications for non-major development: less than 70% of an authority’s decisions made within the statutory determination period or such extended period as has been agreed in writing with the applicant. See Live Tables P151/P153 Quality of decisions The threshold for designation on applications for both major and non-major development, above which a local planning authority is at risk of designation, is 10% of an authority’s total number of decisions on applications made during the assessment period being overturned at appeal. Once the figures for the relevant period have been published in Live Table P152 or P154, which identify local planning authorities are at risk of designation by exceeding the threshold, they are invited to contact Departmental officials with any data corrections, and information on any exceptional circumstances applying to the authority that might be used as reasons why the Secretary of State should not designate them. The Secretary of State then takes this evidence into account when making decisions on which authorities should be designated. See Live Tables P152/P154 Two local planning authorities are currently designated by the Secretary of State in relation to >>>

pil136 January-March 2026

BRIEFING | PLANNING PERFORMANCE

>>> their planning performance. These are Lewes District Council (on 8th May 2024) in relation to quality of decision-making for major applications; and Bristol City Council (on 6th March 2024) in relation to speed of decision-making for non-major applications. Residential decisions In July to September 2025, 9,400 decisions were made on applications for residential developments[footnote 4], of which 7,100 (76%) were granted. The number of residential decisions made was down 5% from the same quarter a year earlier, with the number granted down 3% from the same quarter a year earlier. 900 major residential decisions were granted, down 2% from the same quarter a year earlier and 6,200 minor residential decisions were granted, down 3% from the same quarter a year earlier (Live Table P120A, PS2 Dashboard). In the year ending September 2025, 37,700 decisions were made on applications for residential developments, of which 28,500 (76%) were granted. The number of residential decisions made was down 13% from the previous year, with the number granted down 8% from the year ending September 2024. 3,700 major residential decisions were granted, down 3% from the previous year and 24,800 minor residential decisions were granted, down 9% from the previous year. Residential units The figures collected by the Department are the numbers of decisions on planning applications submitted to local planning authorities, rather than the number of units included in each application, such as the number of homes in the case of housing developments. The Department supplements this information by obtaining statistics on housing permissions from a contractor, Glenigan. The latest provisional figures show that permission for 208,000 homes was given in the year to September 2025, down 15% from the 245,000 homes granted permission in the year to September 2024. On an ongoing basis, figures are revised to ensure that any duplicates are removed as far as possible, and also to include any projects that local planning authorities may not have processed: they are therefore subject to change, and the latest quarter’s provisional figures (represented by the dotted line in Figure 6) tend to be revised upwards. For the previous eight quarters, the year to figures have been revised 0.8% on average. These figures are provided here to give contextual information to users and have not been designated as National Statistics. Commercial decisions In July to September 2025, 1,600 decisions were

Planning in London

made on applications for commercial developments[footnote 6], of which 1,400 (89%) were granted. The number of commercial decisions made was down 9% from the same quarter a year earlier, with the number granted down 9% from the same quarter a year earlier. 300 major commercial decisions were granted, down 10% from the same quarter a year earlier and 1,100 minor commercial decisions were granted, down 9% from the same quarter a year earlier (Live Table P120B, PS2 Dashboard). In the year ending September 2025, 6,600 decisions were made on applications for commercial developments, of which 5,900 (89%) were granted. The number of commercial decisions made was down 11% from the previous year, with the number granted down 10% from the year ending September 2024. 1,200 major commercial decisions were granted, down 14% from the previous year and 4,600 minor commercial decisions were granted, down 9% from the previous year.

Trends in the percentage of residential and commercial decisions granted SEE Fig 7 BELOW Householder developments Householder developments are those developments to a residence which require planning permission such as extensions, loft conversions and conservatories (see Definitions section of the Technical Notes). The number of decisions made on householder developments was 38,700 in the quarter ending September 2025, accounting for 51% of all decisions, down from 52% of all decisions made in the quarter ending September 2024. Authorities granted 90% of these applications and decided 93% within eight weeks or the agreed time (Reference Table 2, PS2 Dashboard) In the year ending September 2025, 156,700 decisions were made on applications for householder developments, accounting for 52% of all decisions, up from 51% of all decisions made in

Figure 7: Applications decided by district authorities, by type of development

the year ending September 2024. Authorities granted 90% of these applications and decided 93% within eight weeks or the agreed time. Major public service infrastructure development decisions Since August 2021, major public service infrastructure developments broadly defined as major developments for schools, hospitals and criminal justice accommodation have been subject to an accelerated decision-making timetable. Separate figures on major public service infrastructure development decisions have been collected on the quarterly PS2 return with effect from October 2021. During July to September 2025 there were 18 decisions, of which all 16 were granted and 16 were decided in time (Live Table MJPSI, PS2 Dashboard). Please note that figures are not collected on the CPS1/2 return and so don’t include education developments by county councils. Permission in Principle/Technical Details consent decisions Since April 2017, local planning authorities have had the ability to grant permission in principle (PiP) to sites which have been entered on their brownfield land registers. Where sites have a grant of permission in principle, applicants have been able to submit an application for Technical Details Consent (TDC) for development on these sites. In addition, since June 2018, it has also been possible to make an application for PiP for minor housingled development as a separate application, independently of the brownfield register. Where a site has been granted PiP following an application, it is possible to apply for a TDC. Figures on PiP/TDC decisions have been collected on the quarterly PS2 return from January 2020. During July to September 2025, local planning authorities reported 393 PiP (minor housing-led developments) decisions, 22 TDC (minor housingled developments) decisions and 1 TDC (major developments) decisions. The totals for the previous quarters since 2020 have generally been similar, although there has been a large increase in the number of PiP decisions in recent quarters, with the number increasing from 144 in July to September 2024 to the 393 decisions in July to September 2025 quoted above, an increase of 173%. (Live Table PiP/TDC1, PS2 dashboard). Permitted development rights Planning permission for some types of development has been granted nationally through legislation, and the resulting rights are known as ‘permitted development rights’ (PDRs). For certain permitted development rights, if the legislation is complied with, developments can go ahead without the requirement to notify the local planning

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authority. Hence no way of capturing this data exists and these are not accounted for in this report. In other cases, the permitted development right legislation requires an application to the local planning authority to determine whether or not prior approval is required and to determine as appropriate (see the Definitions section of the Technical Notes). Between July to September 2025, 6,200 applications were reported, of which prior approval was not required for 3,100, permission was granted for 1,700, and 1,300 were refused. This resulted in an overall acceptance rate[footnote 7] of 78%. Large householder extension accounted for 51% of all PDR applications reported, with 29% relating to All others, 10% relating to Agricultural to residential, and 7% relating to Commercial Business and service to residential (Live Tables PDR1/PDR2). In the quarter to September 2025, 1,100 permitted development right applications were made for changes to residential use, of which 700 (65%) were given the go-ahead without having to go through the full planning process.

Overall during the 46 quarters ending September 2025, district planning authorities reported 369,400 applications for prior approvals for permitted developments. For 204,200 of them prior approval was not required, 88,600 were granted and 76,600 were refused (Live Table PDR2). n

pil136 January-March 2026

BRIEFING | LONDON PLANNING & DEVELOPMENT FORUM

Placemaking not plotting, Measures to jumpstart house building and SME delivery in the capital, Camden High Street upgrade & Update from parliamentary select committee Account of the London Planning and Development Forum meeting on Tuesday 2 December 2025 at HTA Design Discussion items 1 Placemaking not plotting Ben Derbyshire, HTA Chair, to present their Placemaking not Plotting report which is the culmination of work done by him and Andy von Bradsky to feed into placemaking principles for new towns 2 Measures to jumpstart house building and SME delivery in the capital James Cogan of Boyer, Colin Wilson of L B Southwark Hugo Owen, Policy manager, Pocket Living 3 Camden High Street upgrade Speakers: from the designers Edgy Collective: Daniella Levene and Susanna Grant 4 Update from parliamentary select committee National Development Management Policies confirmed as non-statutory (a major shift from earlier expectations) Updated NPPF due before Christmas, to land alongside NDMPs Nik Smith director Nexus Planning Thanks to HTA Design for their hospitality Report by Riette Oousthuizen, Michaela Oberhuber and Arjun Singh of HTA Design also at www.planninginlondon.com >LPDF

Planning in London

BRIEFING | LP&DF: PLACEMAKING NOT PLOTTING

Placemaking not Plotting Ben Derbyshire, HTA Chair and Andy von Bradsky presented their Placemaking not Plotting report which is the culmination of work done by them to feed into placemaking principles aimed at improving development on green field sites. BD explained the origin of the Placemaking not Plotting publication, referring to the need to provide clear, robust advice on housing delivery and quality, and the built environment to the House of Lords. The brief was to provide a document which had a meaningful chance to improve housing quality through the current planning system, and not undermine housebuilders productivity/profitability. Feedback from the Government is awaited. BD added that there have been several roundtables to discuss the publication and its recommendations. AvB summarised the main points from the publication, including the feeling that there need to be action taken to improve housing quality particularly in green fiels locations in order to inspire a new generation of sustainable suburban living. This extends to improving the quality of design and enable developers to be more confident about the planning process, including support from LPAs and communities, thus improving housing supply. MHCLG will produce

a revised suite of design coding information which is to be be published after the updated NPPF. AvB summarised the main recommendations for the National Model Design Code, including • Greenfield development design code template • Embracing the standards early in the planning/design process • Setting out key parameters (e.g. for density, height/scale/massing) • Designing streets, whilst Manual for Streets 3 is awaited. • Suitable design review processes for schemes of 50+ units. • Rewarding compliance with certain design code requirements with an expedited planning determination process, including at Planning Committee – a limit on the grounds which Members can intervene in relevant planning applications. AvB noted that the publication (which can be read and downloaded here https://www.hta.co.uk/ publications-post/placemaking-not-plottingtowards-a-new-generation-of-sustainable-suburbs/) outlines these recommendations in more detail, with one of the key goals being an increase in suburban density. Information is included about car parking strategies, street design/pattern, property boundaries, green infrastructure, place character/identity, and private amenity. The outcome of the template will be to improve design quality and improve the speed at which planning decisions are made. AvB confirmed that this is a route towards design

codes through local-level planning, which includes procedures to obtain democratic support and engagement. Peter noted that there is no guidance on tall buildings in the report, and asked how these could be taken into account as well as if this would be considered by the Government. BD responded that the focus of this work is on green field development, and that the worst housing conditions tend to be found in new urban extensions – not brownfield development, therefore this hasn’t been addressed. BD added that a large proportion of new homes will come from urban extensions and greenfield sites >>>

ATTENDANCE Meeting held on Tuesday 2 December 2025 at HTA Design LP&DF TEAM, HOSTS AND SPEAKERS: Brian Waters LP&DF Chairman Riette Oosterhuizen HTA Design Lee Mallett Planning in London Colin Wilson LB Southwark Andy Von Bradsky Ben.derbyshire HTA Design (host) Suzanne Grant Edgy Collective + Linda James Cogan Boyer Nick Smith Nexus Hugo Owen Pocket Living Mark Willingale Willingale Associates MEMBERS & GUESTS: Prof Ian Gordon, LSE Philip Freeman Bently hgh consulting

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Mike Burnell Hopkins Architects/ Burnell Studio Judith Ryser Urban Thinker Stephen Heath Bloomsbury Society Prof M Edwards UCL Ian Butcher am-plan Desire Oaz proximity, Duncan Bowie UCL Peter Eversden London Forum Michael Bach London Forum Dr Harry Charrington University of Westminster APOLOGIES: Brian Whiteley RTPI Paul Cheshire LSE Paul Finch EMAP/Planning in London David Bloy British Land Company Steve Quartermain

pil136 January-March 2026

BRIEFING | LP&DF: MEASURES TO JUMPSTART HOUSE BUILDING

>>> despite the Government noting that its priority is brownfield sites. AvB added that the document will respond to some barriers to development, but not all of them. BD explained that this document has been design-led, and there is a connection with new Government guidance. BD explained their recommendation is for a medium density on new greenfield sites which responds to other requirements including BNG and drainage, and car parking. MW noted their concern with the land take from needing to cater to onerous car parking standards. LM noted that one of the challenges is achieving required density, and asked if it could be demonstrated to laypeople as politicians that the uplift in density is possible. AvB acknowledged this, and responded that a design code needs to set out the approach to this, and referred to the contribution that flats over houses can make. Architects should be able to design new housetypes which improve density. BD added that this was a point for further discussion and development. Michael referred to the need for planning policies to encourage greater density, but also different density in different places. Density and car parking depend on location, and therefore existing infrastructure/amenities/accessibility is important to consider. AvB noted that taking the pressure of LPAs would help them to assist with this balance and provide greater certainty. Brian referred to the recent Government announcement to develop sites close to railway stations. BD explained that there are not enough railway stations nor capacity - therefore this is not the fix. Peter explained that there are supermarkets in London which have car parking at ground, supermarket at first floor, and flats above where the supermarket and flats share car parking without significant issues. Brian noted that upstairs supermarket shopping was not feasible even 10-15 years ago. Michael explained that this isn’t addressed in the publication – BD acknowledged this. AvB described the relationship between these sites and dealing with notions of the Grey Belt. LM added that LPAs won’t allocate sites in time - BD and AvB agreed. Brian explained how Planning Inspectors are beginning to create a precedent of the Grey Belt, which is beginning to influence policy. Mark W mentioned that the cars will be there somewhere and should be accommodated for. SG added that maintenance is a key aspect of landscape/green space strategies, and is not budgeted in – asking if this was included in the report. BD responded that there needs to be a national scheme for commuted sums, and the National Model Design Code covers this. Brian explained that consultation on an updated NPPF is expected (and now announced) before Christmas with design guidance to follow. n

Planning in London

Jumpstarting house building and SME delivery in London James Cogan of Boyer, Colin Wilson of L B Southwark and Hugo Owen, policy manager at Pocket Living JC referred to the commencement of consultation by the GLA on the emergency planning measures. JC spoke through the collapse in annual house building starts in London in 2024-25, which is significant compared to previous years – a fraction of previous delivery, and that something dramatic is needed to improve the situation. JC referred to the stakeholders delivering housing in London, noting that all sectors/homebuilders are struggling to deliver new housing starts. At the same time, the house building target for London has increased since the London Plan was first published. Annual targets have never been met, with the resulting shortfall affecting affordability. JC referred to the wider economic challenges influencing the drop in housing starts alongside planning challenges. There are five main changes being introduced, 3 being consulted on by the Mayor and 2 being consulted on by the Government. Those being consulted on by the Mayor: • Changes to cycle parking requirements – formalising advice given to LPAs by the GLA. This has been broadly welcomed. • Changes to housing design guidance, including the position on dual aspect homes – formalising advice given to LPAs by the GLA. • Changes to threshold approach to affordable housing provision. Those being consulted on by the Government: • Additional CIL relief if affordable housing targets are met in a scheme. • Increasing Mayoral powers to intervene in planning applications. LM noted that City of London are considering

relaxing cycle parking requirements as well. He explained that the changes to the threshold approach are time-limited, and therefore permission needs to be secured by March 2028 – there will be a 1.5-2 year benefit period. Brian noted that applying this retrospectively would result in even more homes coming forward. The procedure of benefitting from these measures was explained, including potential revisions to S106 agreements and Building Safety Regulator approval. HO noted that these measures may result in developers delaying submission of their applications in order to help their schemes benefitting from the measures – meaning there may be a gulf of new applications. It was noted that the late-stage review mechanism has also dampened investor markets and that consultation on changes to CIL is fairly lengthy and there is a significant burden – financial and information – on developers. It also puts burdens on LPAs when they may receive less CIL anyway due to the uplift in affordable housing. HO indicated that the gravity of the issue has been acknowledged by the Mayor and the Government given their intervention, but overall – these changes aren’t likely to get housebuilding levels to where they should be. It puts a burden on developers and LPAs. Nothing announced which will speed up the decision-making process, nor to get consented schemes which are now unviable, viable again. CW explained that the issue started in the late 1970s where housebuilding in England began to lose their funding to subsidise public housing. Putting this down to private developers has become unquestionably the process by which affordable housing is delivered – but publicly funded housing has decreased. Housing should be seen as national infrastructure – it used to be around 6% of national GDP, now it is around 2.5%. The funding allocation for affordable housing has increased under the current Government, but this still represents significant underfunding. £3.8bn is allocated to affordable housing by this Government

Annual housing starts in-77;2./<=;467>/012314/?@=7A=7B London have fallen off a cliff compared to soaring targets

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but this won’t allow the 1.5m homes target to be achieved. CW queried how affordable housing is to be funded, as the Government’s aims don’t align with the budget it has. CW referred to the rise of affordable rent over social rent, and how this did not help affordable housing provision as a whole. The growth of demand for temporary accommodation has dovetailed with the fall of social housing provision, alongside associated issues for education, healthcare, and policing. The changes to the threshold for affordable housing won’t assist addressing these other issues nor will they reduce the need for temporary accommoda-

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tion. CW noted that these measures represents a sticking plaster for these wider issues, and that overall build costs have increase exponentially compared to sale values. Changes to foreign taxation have driven foreign buyers away, and greater housing requirements for housing associations have driven them away. CW agreed that right to buy reduced the number of social rent properties available; to accelerate housing delivery in London the GLA grants should be 100-110% of total cost. Michael noted that these measures represent tinkering around the edges. The current measures should have focused on speeding up delivery as well, and to address the fact that only around a third of tall Pulling lots of levers buildings have been built. -3,,0$%5,)('5)>5 ,&@&.'C HC explained that the rise of housing benefit more • !"#$%&' () !*+,& -#./0$% 1&230.&4&$(' that outstrips the challenges • !"#$%&'5()56)3'0$%57&'0%$58309#$+& • !"#$%&'5()5("&5:".&'"),95;<<.)#+" of delivery. Housing benefit • ;990(0)$#,5!)443$0(*5=$>.#'(.3+(3.&5?&@*51&,0&> is now £40bn a year – this • =$+.&#'&9 A#*).#,5-)B&.' was much lower in the late 1970s. More is spent on housing benefit now, than Changes to thresholds K%<,4+*-.' on housebuilding at the L*25*)*:> peak of housing delivery. It !"#$%&'()*()"&(+",&'"*-.(/00,*#1" represents a huge shift in • !"#$%$&'($)*+$,*-. /01 2334,(25)$ #46&*-. 7801'!4"*2) 9$-:; "2-'<,4"$$(' income to landlords and =*:#46:'6<3,4-:'+*25*)*:>'2&&$&&%$-: most people would want • ?)2--*-.'?$,%*&&*4-'%6&:'5$'&$"6,$('5>'@A&: B2,"#'/0/C • !"#$%$& %6&: ,$2"# 3*D$( %*)$&:4-$ 73*,&: 3)44, )$+$); 5> @A&: B2,"# /0@0 this to be corrected. • ED")6($&'F,$$-'G$):'H'F,$>'G$):'2-('E&:2:$'9$.$-$,2:*4-'!"#$%$& MW suggested that the • F,2-:'36-(*-.'%2($'2+2*)25)$'254+$'A01'2334,(25)$'#46&*-. Government should spend • I?J&'"2-',$(6"$')$-.:#'43'<)2--*-.'<$,%*&&*4-'5$)4=':#,$$'>$2,& more on planning for the future in terms of housing and infrastructure. K>,-2%7#&< Increased Mayoral powers IG explained that the 9%2'( :%(#$#2. housing system has inadver!"#$%&'%()*&+,$&-).,/%$' tently worsened inequality. • !""#$#%&'()*%+,-.)$%)'((%+)/'0%-)$% ‘call1in’ '**(#2'$#%&. 3%-)45)6%7,. %- 7%-, Measures could also address • 8,+)*%+,-.)+#(()%&(0)'**(0)+6,-,)$6,)9:!)#&$,&".)$%)-,3;.,)*('&&#&<) *,-7#..#%& demand-side issues includ• =6,)/'0%-)+#(()6'>,)?@)"'0. $% ",2#", +6,$6,- $% ‘call in’ $6, '**(#2'$#%& ing leasehold homes, the • 9:!)+#(()&%$#30)/'0%-)%3)'(()-,(,>'&$)'**(#2'$#%&.A)B;$)$6,-, +#(( B, no ‘Stage 1’ quality of new homes and *-%2,.. associated building safety • Applicants will not be able to request that the Mayor ‘calls in’ an application • Mayor’s ,C#.$#&<)*%+,-.)'-,)$%)B,),C*'&",")$%)'(()7'D%-)'**(#2'$#%&.) issues, and the slow emerE@A555.FA7)%-)7%-,G)%&).#$,.)#&)$6,)H-,,& I,($ J /K9 gence of commonhold. The

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entire housing system requires rethinking. Greater housing supply is needed in order to reverse the inflation experienced which has dampened demand. These measures need to be longerterm. IG noted this was pursued, unsuccessfully, in 2019 through the London Plan – these were not taken forward. People need to believe that he land won’t be worth more in 20 years than right now. HO explained that the 1970s and 80s were good for SMEs, with current-day large builders including Berkeley, Redrow, and Persimmon starting as small companies which were able to scale. Land was cheaper and the planning process was simpler. SMEs now delivery 10% of housing output, where it was 40% previously, and half of SMEs are due to be insolvent by the end of the parliament. It costs £60k more for a SME to build a 1-bed flat in London than a PLC. The 1990s brought a fundamental shift to move the requirement to provide affordable housing from the public to private sector. Measures to reduce profits have had consequences and would not be tolerated in other industries. HO set out a series of actions to improve the situation, including a presumption in favour of small sites policy in the London Plan, exemptions to affordable housing provision for schemes of 10 homes or fewer and explore raising the threshold to 50 homes, and creating a proportionate planning system for SMEs – scaling planning fees to size and complexity, standardised S106 agreements, and expanding the New Homes Accelerator to unlock SME sites. HO noted that the Housebuilders Federation could do more to aid development in London. CW added that affordable housing thresholds used to be higher. LM queried if London Councils should take these concerns to the Government. CW added that challenges in securing granting funding stall delivery, alongside the 5-year grant programme run by the GLA, and the rules on what Right to Buy receipts can be used for. See Hugo’s presentation overpage n

>>>

pil136 January-March 2026

BRIEFING | LP&DF: MEASURES TO JUMPSTART HOUSE BUILDING AND SME DELIVERY IN THE CAPITAL: HUGO OWEN

>>>

Planning in London

>>>

www.planninginlondon.com

pil136 January-March 2026

BRIEFING | LP&DF: CAMDEN HIGH STREET UPGRADE

>>>

Camden High Street upgrade Speakers: from the designers Edgy Collective: Susanna Grant presented the scheme SG introduced the principles of ensuring that funding is secured for the maintenance of green spaces in new development/public realm. SG spoke through an example where a new square was created in Camden incorporating a forest garden, which was used as soon as it was opened. Recycled materials and landscaping was used. It has encouraged people to look after it. The project included the local community, diverse planting, recycled material, and local makers. SG spoke through examples/precedents of drought-tolerant planting, edible planting, and the process of creating the planters. Smaller plants should be used. The team worked with a local community association. The planting is maintained by two locals who are paid to maintain them. SG explained that safeguarding an amount of money for ongoing maintenance is key. SG added that the planters have encouraged local businesses to help maintain them, they have had input and help from Boxpark, and outlined the year-round programme to engage the community. The Brewery Logistic Group responded to this agenda item by saying that the launch of this scheme caused beer delivery issues. Planning policy and urban design changes often don’t acknowledge the impact on logistics for hospitality particularly regarding traffic management.

Music Walk of Fame (Mark Willingale) 52

Planning in London

MW introduced the Music Walk of Fame, a trail along Camden High Street of up to 400 commemorative stones dedicated to icons of the music industry starting with the Foundation Stone laid in November 2019. Camden High Street is incredibly well visited and has huge potential as a visitor attraction but has yet to be designed as a place. See the Camden High Street array plan overpage.

National Development

YeAr-RoUnD pRogRAmMe fRAmeWOrK Led by Edgy Collective: ● Four flagship events, each aligned with the seasons — Spring, Summer, Autumn, Winter (starting with Autumn as our launch event) ● Curated and delivered by Edgy Collective and partners, these larger-scale events will activate the space with bold, creative programming

Led by the Community: ● Four smaller community-sourced events, initiated by local individuals or groups ● Delivered through an open application process run by Edgy Collective, supporting grassroots ideas and local voices, and ensuring payment for talent and time

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LEFT TO RIGHT ABOVE: Woody Woodmansey-Original Bowie Drummer of The Spiders from Mars Lee Aaron-Bennett Kevin Armstrong- Bowie Guitarist and Producer Nick Moran- Actor/Director and mate of Bowie Clifford Slapper- Keyboardist. - Last Musician to play with Bowie >>>

pil136 January-March 2026

BRIEFING | LONDON PLANNING & DEVELOPMENT FORUM | UPDATE FROM PARLIAMENTARY SELECT COMMITTEE

>>>

The Camden High Street array plan Willingale Associates

Update from the parliamentary select committee Management Policies confirmed as non-statutory. Updated NPPF due before Christmas, to land alongside NDMPs Nik Smith director, Nexus Planning opened the discussion No major policy shift expected compared to Angela Rayner. The commitment to delivering 1.5 million homes remains. An NPPF update consultation is expected around Christmas. Government discussing new towns; key issue is how their housing numbers contribute to overall housing need/targets of the local authorities. There is also an upcoming consultation on the statutory consultee regime. The Chinese Embassy application is likely to be approved on 10 December. National Development Management Policies (NDMPs): Legislation is already in place giving national policies the same weight as local policies. NDMPs could

Planning in London

speed up local plan making, provided local plans are in place. Local plans will still include their own DM policies, and there may be some initial complexity in decision-making until local policies align with national ones. Potential for national policies to more closely reflect the current government’s objectives. NDMPs would remain non-statutory, similar to the NPPF. Some concerns raised about whether this retains a plan-led system, given the increased national influence. As with the NPPF, NDMPs are expected to have a significant impact on decision-making, particularly on issues such as Green Belt and heritage. A new NPPF 2025 policy may introduce a default approval for proposals near well-connected stations within walking distance, alongside minimum density requirements. Which stations would qualify is yet to be defined. Green Belt/grey belt policy will be affected, including potential policies relating to station car parks. The policy direction mirrors the London Plan

2016 focus on development within a 10-minute walk of stations or town centres. This represents a reintroduction of spatial/strategic planning, which has weakened in recent years. A more proactive, area-based approach to development around stations is anticipated. Some stations still lack development frameworks; a stronger requirement to complete development plans could help. Skipping the site allocation step may further speed up delivery. Government has stepped back from area-wide design codes. The “placemaking not plotting” approach is intended to move the system towards clearer, more consistent principles for new development, but it does not yet reduce the level of discretionary decision-making needed. Over time, national DM policies may help streamline processes, freeing up more local plan space for site allocations and improving engagement with local communities. n

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,7%4N%EC98;<8>*%79;<679:%E6:<8G%<5%9:C>9DG%<7B:K>7;<9:%<7%9C>95%L<;M6K;%KER;6RD9;>%E:975P%)6%767R 5;9;K;6CG%$4N05%L<::%:<H>:G%M9?>%59=>%>BB>8;P They will ‘work through’ the system, likely forming parts of new local plans as they are adopted.

!""#$%&%' 5 !"#$%&'%&6789:;<9%$00=%>?@9AB:<:8?@C 5 4D:<8B9%B8;8:DE*%FA:%EDG<AB:%‘yes’$$G?7%6?;D9%@D<7%‘well connected’ :7<8@%9:<:8?@9% H8@:7?EA>8@I%0B<:G?7;JKC

5 (DGD7D@>D9%:?%‘reasonable walking distance’. 5 ()*)+,+%ED@98:8D9C 5 !?%<LLBM%@<:8?@N8ED*%8@>BAE8@I%N8:68@%-.//*$0/123

5 +@E%then…major%>6<@ID9%:?%-?><B%0B<@9%:?%O8>O%8@%G7?;%P<@A<7MC

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pil136 January-March 2026

ANDY ROGERS: PLANNING QUIZ FOR 2026

ROGERS

Planning quiz for 2026 Andy Rogers asks: Would you like to have a multiple choice? (a) No; (b) Yes; (c) Don’t know Question 1. When a beekeeper in the Northamptonshire countryside was served with an enforcement notice alleging his use of a mobile home as a carpentry workshop for the manufacture of beehives to cease amounted to a change of use of the land, was it (a) because beekeeping is not an agricultural use for planning purposes; (b) because making multiple beehives is not an essential part of the use; or (c) because the mobile home was harmful to the character of the area.

Question 4. Why can a small two-storey block of five flats not be extended by the addition of three flats in an extra floor under current permitted development rules? Is it (a) because it’s in a conservation area; (b) because the new flats would not comply with minimum space standards; or (c) because such extensions have never been allowed under permitted development rules.

Question 2

Question 2. Why did the council refuse prior approval for the addition of twelve flats in two storeys on a detached block at a busy crossroads in Kingston upon Thames that was later allowed by an appeal inspector? Was it (a) because of the effect on the traffic; (b) because of the effect on the external appearance of the building; or (c) because of the effect on the surrounding area. Question 3. Why did the London Borough of Hillingdon wrongly refuse a Certificate of Lawful Development for the conversion of a storage annexe into a granny flat? Was it (a) because it did not comply with the provisions of Schedule 2, Part 1, Class E of the GDPO; (b) because it created a separate planning unit; or (c) because the insertion of a toilet/shower room is not permitted development .

Planning in London

Question 5. Why did Magnus Hanson-Heine, owner of the house in Oxford that has a giant shark embedded in its roof, consider the complete removal of the shark? Was it (a) as a protest against the council’s decision to list it on a local heritage register; (b) because the roof is leaking and cannot easily be repaired; or (c) to sell for export to an American art dealer. Question 6. Why did an appeal inspector find an enforcement notice requiring the removal of fences that had been erected in place of a hedgerow to be a nullity? Was it (a) it did not specify exactly what was required to be done; (b) it failed to set out a reasonable period of time for compliance; or (c) it wrongly described the fences as being more than two metres high.

Andy Rogers is a planning consultant and former director in architects

Question 7. Sotheby’s reportedly sold this at auction last year for just over six million dollars? Is it (a) the model for an entrance to New York’s Central Park by Philip Johnson; (b) a rare early work by Alexander Calder; or (c) a lamp designed by Frank Lloyd Wright.

Question 5.

ANSWERS: Question 1. (c) The appeal inspector upheld the notice because, although he did not agree that the area was a “valued landscape”, the mobile home harmed the character of the area due to its poor condition and prominent position. Question 2. (b) The appeal Inspector recorded that external appearance is not defined in the GDPO, so a planning judgement had to be made. He distinguished between the local appearance of the building and its wider context, deciding the latter went beyond the scope of the prior approval assessment. He concluded that surrounding visual relationships would not be harmed while the proposed extension would have acceptable effects on the external appearance of the building itself. Question 3. (a) The appeal inspector found that the annexe was existing but Class E of the GDPO refers to new buildings. The internal works did not require planning approval while the

annexe would have living facilities shared with the main house and no separate curtilage, so was ancillary to and remained part of the dwelling.

Question 4. (c) The General Permitted Development Order that allows upward extension of blocks of flats subject only to the prior notification procedure for some reason was limited to blocks that are three or more storeys high. The pd right does not apply in conservation areas and prior approval would rule out any new flats that don’t comply with minimum space standards even when the existing flats do not comply.

Question 7 Question 5. (a) Magnus said any official protection would go against everything his father, who erected the shark in 1986, stood for. “We’ve got this iconic sculpture that stands in opposition to the planning laws and against the idea that planners get to decide for the public what kind of art you are or aren’t allowed to see. The council is seeking to preserve this by doing exactly that - by again making that determination themselves”. Question 6. (a) The council made the mistake of requiring approval of the type and details for replacement hedges as part of the enforcement notice, rendering it invalid because the appellants could not know on receipt of the notice what details might be approved by the council and therefore what they had to do to comply with it. Question 7. (c) Known as the double-pedestal lamp (1902), it’s a small version of the horizontal prairie style used by the architect’s building projects and more than doubled the previous record for a Lloyd Wright piece. n

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pil136 January-March 2026

NICHOLAS BOYS SMITH | CAN WE CREATE A BEDROOM BONANZA?

Can we create a bedroom bonanza? Nicholas Boys Smith argues that the London Mayor and councils need to start thinking about housing differently to unlock hidden bedrooms

Nicholas Boys Smith is the founder and chairman of Create Streets

Planning in London

When it comes to building sufficient homes in London, the only thing people can agree upon is that it’s not working. Everything else is up for debate. It is no secret that London and the Southeast does not have enough homes. The ratio of average house prices to income has doubled since 1998. This reduces disposable income as wages are squandered in rent or mortgages. It gums up the labour market as people are unable to move. It even hinders marriage and childbirth as the right homes with sufficient bedrooms are just not available. The consequences for our standard of living and economic prosperity are catastrophic. However, conventional brownfield and greenfield sites can be slow and pricey. They need new infrastructure, new streets and a complex mesh of utility connections and pipelines. With high imposed taxes in cash and kind, right now many developments end up requiring financial assistance from Homes England. This creates an absurd paradox: paying suppliers to create homes in a supply constrained market. Historically, one important way that towns increased their supply was by ‘growing up’, with their streets evolving over the decades and centuries from two to three to five or to even more storeys as demand increased. Well into the eighteenth century for example, the north side of the Strand was two

storey cottages. It now towers at nine or ten storeys. This ‘growing up’ on existing streets has the huge advantage of not requiring new infrastructure or, at worst, only modest improvements to existing infrastructure. The pipes are already there. We need to escape from our near total reliance on large, complex sites by making it much easier once more for streets to ‘grow up’ and intensify in ways that local residents find acceptable. All research into the nature of regulation and risks teaches that achieving that will involve de-risking development so that what is buildable and what is not buildable is much, much clearer. Here’s one example of how to do it using existing legislation which the next London mayor should promulgate and which any council in high demand parts of the country could and should adopt tomorrow. It allows us to create new bedrooms for almost no public cost whilst improving existing streets and generating value for homeowners. Sound too good to be true? Well, Create Streets’s latest report, Lessons from London: how legalising housing can give birth to a bedroom bonanza, shows that this is not theory. It is fact. It is actually happening on the ground right now as I write and as you read. Mansard roof extensions offer a modest but useful low-cost,

New code and new mansards in Tower Hamlets. The code is part of a Supplementary Planning Document which de-risks but which does not pre-permit mansards1

way to increase living space on some streets. They can add around a quarter to a third more floorspace to Victorian and Georgian houses, often in central, well-connected locations, without harming neighbourhood character. Most create two new bedrooms and can be tucked elegantly and unobtrusively behind the parapet, with the construction cost being a fraction of the value of the space created. In 2017, Tower Hamlets Council encouraged carefully designcoded mansard extensions in one neighbourhood just south of Victoria Park as part of updated Conservation Area character appraisal and management guidelines. The revised guidelines strongly encouraged mansard uplift and included a short visual design code setting out how to execute them well. Planning permission is still required though it is hard for the council to say no as long as the design code is followed. The success is dramatic. Average annual applications rose by 688% and success rates at planning leapt from 27% to 93%. There are now in consequence around 300 extra bedrooms in Tower Hamlets which would not otherwise exist. And, never forget, bedrooms matter as well as new ‘units’. More bedrooms in cities are associated with reduced homelessness. It is not hard to see why. Consider a household with a spare room. They could choose to bring in a lodger, increasing the supply of accommodation within the formal system. Or they could provide a home for a family member on a short- or long-term basis helping them access opportunities for work and study. They could help a friend who is in a difficult situation, a parent who needs care, a cousin who is on a placement. Maybe a friend whose new job requires them to be in town a couple of days a week needs a place to stay on the occasional evening. We can imagine many such scenarios beyond the formal housing ‘system’. Researchers have termed this ‘decommodified’ housing

In 2023, thanks to Create Streets, the last government amended national policy to back upward extensions where appearance harmonises with the original. It said that authorities should not require simultaneous development across a terrace. This has not yet had a huge effect on applications. Not many people know about it. But it has had a significant effect on success rates at appeal. Successful appeal to the Planning Inspectorate increased from 17% in period before the policy change to 42% afterwards. This will surely start to feed through to applications over time. But councils can speed it up if they wish and ensure that new mansards fit in. Local councils can set clearer local policy in the spirit of the national guidance. The first of these of which I am aware is the Redcliffe Road Local Development Order (so-called LDO) in Kensington and Chelsea. This pre-grants planning approval as long as the mansard follows a set pattern thus totally eliminating planning risk. Literally nothing stops you as long as you follow the code. The additional storey further alongside the homes with preconsented mansards has justified the LDO The design guide specifies the pitch of the new slope, the setback from parapets, the alignment of ridges across the terrace and the detailing of dormers and balustrades. Solar panels are required as part of the roof build-up, increasing energy efficiency. Remarkably, within 18 months, five of the twelve eligible homes on Redcliffe Road have begun building mansards, confirming high latent demand when planning risk is removed. A sixth is starting imminently. Redcliffe Road shows the value in listening to the demand of residents. Within 18 months of a LDO, nearly half the eligible houses are already building mansards. Even a less powerful local policy, as in Tower Hamlets, has increased successful applications LEFT: More bedrooms appear to correlate with less homelessness in US. Source: Salim Furth, Works in Progress, December 2024.

>>>

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pil136 January-March 2026

NICHOLAS BOYS SMITH | CAN WE CREATE A BEDROOM BONANZA?

>>> by 2,470 per cent and probably created about 300 bedrooms. This is a major success. London councils could and should act tomorrow by copying this model: adopt LDO’s or simple design codes that preapprove well-designed mansards across whole streets. The GLA could go further by embedding supportive policies into the London Plan, keeping the look consistent. Nationally, the government could back councils by producing a template design code and model LDO, so no council needs to reinvent the wheel. Although some work is required up-front for LDOs increasingly this will be replicable from one location to another and will not need re-drafting. As far as possible all aspects of the process and permission should be pre-prepared as replicable

‘cookie-cutters’. Councils categorically should not place onerous risks, processes or costs on the permission. For example, traffic management plans can be ‘cookie-cutter.’ Local, London and national Government’s housing targets should take account of new bedrooms as well as just new homes. The Tower Hamlets and Redcliffe experiences show that that clear, pre–set rules unluck immediate uptake. With the right policies, the potential of mansards to create living spaces in an economically and energy efficient manner is transformative. There’s nothing stopping councils from rolling this out across thousands of streets in England. A bedroom bonanza could and should follow. There are no real ‘easy wins’ in life but this is as near as you can reasonably expect. n

Heightened homes along the road from houses subject to the Redcliffe Road Local Development Order

FOOTNOTES 1

Design guidelines for mansard

roof extensions, London Borough of Tower Hamlets, 18 June 2025, [Accessed 30 Sep 2025] 2

Royal Borough of Kensington &

Chelsea. (2024). Local Development Order for Roof Extensions on Redcliffe Road. 3

Royal Borough of Kensington &

Chelsea. (2024). Local Development Order for Roof Extensions on Redcliffe Road.

Planning in London

The additional storey further alongside the homes with pre-consented mansards has justified the LDO

LDO’s Street facing mansard elevation and solar panel requirement2

Before and after mansards with reinstallation of cornice balustrade3

Latent demand in bricks and slate: mansard construction on Redcliffe Road is already underway on five of twelve houses in just over a year

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pil136 January-March 2026

ADRIAN PLANT | HELPING FIRST TIME BUYERS

What should the government do to benefit shared ownership? Helping first time buyers and others to get on to the property ladder is vital – but more needs to be done to fully realise this potential, says Adrian Plant

Adrian Plant is a director of SOWN (part of Leaders Romans Group)

Planning in London

While housebuilders are increasingly looking for novel and engaging means of marketing to achieve the necessary supply:demand balance in a challenging market, providers of shared ownership have the opposite problem. In the world of shared ownership, demand consistency exceeds supply, and the gap is continuing to grow. This is not so much good news for our sector as a very real concern on a social level. And the reasons are multifarious. The impact of the housebuilding slowdown In the last year housebuilding has slowed down considerably: more than half a million new developments have been put on hold during the past five years and official data shows that only 19% of planning applications are processed within the recommended 13 weeks, compared with 57% a decade ago. Because around half of new affordable housing (which includes shared ownership) is delivered through conditions imposed on development through ‘planning gain’, the reduction in housebuilding (through lack of demand) results directly in a reduction in shared ownership properties (the demand for which increases in a challenging market). And as the already acute need for affordable housing increases, the planning system alone cannot keep up with the volume of new homes required. This may be exacerbated if the proposed Infrastructure Levy is introduced, because it would result in planning gain revenue becoming available for local authorities to spend on the many wide-ranging financial demands that they face in addition to housing. Furthermore, the supply of shared ownership housing was further threatened when it was announced in early January that housing associations in England are due to have planned spending on new affordable homes cut in 2024. Following research by Centrus it is anticipated that funding for 2024 will be reduced by 9 per cent (£1.5bn) compared with the previous year’s forecast. Growing demand Constraints in the economy generally have substantially increased demand for shared ownership and, against the odds, the sector has made considerable progress in meeting this demand. 19,386 new shared ownership properties were delivered in 2021-22 according to the English Housing Survey. This is the highest number since records began in 2014-15, a 14% increase on the previous year.

Shortly after what is now commonly known as the ‘disastrous mini budget’ of 2022, the Commons Public Accounts Committee commented that targets for building affordable homes were ‘depressingly unattainable’. An additional 340,000 homes were needed to keep up with growing demand, it said, with a large proportion of these properties being affordable. Inevitably, given the economic downturn, demand for affordable housing, and shared ownership specifically, is extending to a wider demographic. Today first-time buyers in the UK today are paying almost a third more to get on the property ladder than they were five years ago and in the last decade the number of private renters moving into home ownership fell by 23%. Traditionally shared ownership is most popular among those aged between 25-35 (32-37 in London) but, as salaries fail to increase in line with inflation, the upper age is increasing. In fact we are seeing a significant increase in the 65s plus demographic - those can’t afford to stay in their homes due to reduced incomes and higher mortgage rates; those who pass equity to younger family members, and those who are downsizing to reduce bills. In the five years 2018 to 2023 the average house price rose by as much as 40% in some regions, while the average income rose by just 11.6% in the same period. Although shared ownership remains limited to those with a maximum household income of £80K (£90K in London), many people are finding that due to the impact of interest rates rises on mortgages, car and credit card loans together with the cost of food and utility bills, they can no longer afford to buy outright, and shared ownership is a good alternative. In many parts of the country, specifically the Thames Valley, where the head office of SOWN and its parent group Leaders Romans Group are based, the issue is reaching crisis point as the affordability of homes, both to buy and to rent, is inaccessible to many. In addition to forcing people to relocate away from families and friends, the resultant shortage of key workers in the area affects us all.

No more Help to Buy Perhaps the greatest impact on the demand for shared ownership housing was the cessation of the Government’s Help to Buy scheme last year. Although various initiatives aimed at first time buyers

remain, the absence of Help to Buy is very strongly felt. The scheme, which enabled buyers to buy with a 5% deposit using an equity loan worth 20% of the price of a new build home (40% in London), aided the purchase of almost 390,000 new build homes. During this time, £24.7bn of government loans were advanced to support home buyers, allowing sales of houses worth £109.2bn to go ahead. Just under 85% of homes sold under the scheme were sold to first time buyers. It was inevitable therefore that in July 2023 the UK’s largest housebuilder Barratt said the number of first-time buyers acquiring its homes had fallen by 49% in the past year as Help to Buy was wound down, and predicted a drop of 23% in build volume over period July 2023-24.

Alternative Help to Buy? In the wake of Help to Buy, the Government has put in place a range of means through which first time buyers (and in some cases others) can purchase a property with financial support. These include First Homes, Deposit Unlock, Discount Market Sale, Discount Full Ownership, Intermediate Rent, Lifetime ISAs, London Living Rent and Rent to Buy. Non-government supported initiatives are largely limited to privately available financial products, including first time buyer mortgages at 95% or even 100%, guarantor mortgages, joint mortgages and of course the nice-to-have (but not readily available) Bank of Mum and Dad. But there are clear downsides to each. Potential for the expansion of shared ownership And so it’s no surprise that the most popular initiative by far is shared ownership, which allows eligible purchasers to buy a share of a new build or resale home, paying a mortgage on the part being purchased and a below-market-value rent on the remainder. The supply of shared ownership homes has increased in recent years. Around 4,080 units were completed in 2015/16, rising to a peak of around 18,220 in 2019/20 and falling slightly to 17,100 in 2020/21. In total, approximately 76,500 new shared ownership homes were delivered between 2015 and 2021. But, as I explained earlier, shared ownership is not as a widespread tenure as is required. There are approximately 202,000 households living in shared ownership homes in

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England, which represents less than 1% of all households. Demand varies across the regions, with demand highest in areas where affordability is most stretched – largely in the south of England. Our schemes in London include Clarendon on Hornsey High Street in the heart of north London and Ferry Island North Heart of Hale, located just moments from Tottenham Hale station. Both have proved extremely popular, attracting a wide demographic.

Government support needed So what needs to change to replicate this success elsewhere? The government’s Affordable Homes Programme is an important foundation to build from but so far fails to comprehensibly address increased demand. My view is that the government needs to get behind shared ownership in the same way it did Help to Buy. Help to Buy benefited from a dedicated, widely recognised brand with an effective information campaign and website which pointed would-be purchasers in the direction of suitable products. There many myths around shared ownership which need to be addressed (for example that shared ownership is that it's only available to people with low incomes or those on social housing lists; that you can never fully own a property through shared ownership; that shared ownership properties are of inferior quality compared to properties sold on the open market; that It's difficult to sell a shared ownership property, or that shared ownership is only available for flats… the list goes on) – but doing so comes at a cost. There is also a need to reconsider how funding for shared ownership is derived, especially in the context of a potential recession and changes to the planning gain system. Helping first time buyers and others to get on to the property ladder is vital not only for the individuals involved but for the country’s social and financial prospects. We have a great product and great demand for it – but more needs to be done to fully realise this potential. n

pil136 January-March 2026

BOOKS: THE MANIFESTO HOUSE | OWEN HOPKINS

The Manifesto House Most houses are the product of multiple layers of norms and expectations built up over time, whether methods, materials and technologies, or social, cultural, economic and political pressures. Yet, at various moments in history, houses have been built that stand outside of these expectations and instead are conceived to embody whole new theories or agendas. We call these 'manifesto houses'. The Manifesto House looks in detail at the ideas and ambitions embodied in each house, the contexts that shaped them and their subsequent impact and influence on the future of architecture. Manifesto houses reflect new visions for how we can live. Often extreme and uncompromising, they are vehicles for innovation, new ideas, and new ways of doing things. Most houses are the product of multiple layers of norms and expectations built up over time, whether methods, materials, and technologies or social, cultural, economic, and political pressures. Hardcover £30 Yet at various moments houses have been built that break with YALE UNIVERSITY PRESS the past and do something different–houses that stand outside of

Owen Hopkins, Director of the Farrell Centre at Newcastle University, has published a survey of houses that have influenced architectural design

these expectations and instead are conceived to embody whole new theories or agendas. We call these ‘manifesto houses’. For the first time, this compelling thread in the history of architecture is surveyed by Owen Hopkins. He brings together a collection of twenty-one such manifesto houses, exploring the visions for architecture conjured by Andrea Palladio, Eileen Gray, Frank Lloyd Wright, Harry Seidler, Lina Bo Bardi, Anupama Kundoo, and Sou Fujimoto, among others. The Manifesto House looks in detail at the ideas and ambitions embodied in each house, the contexts that shaped them, and their impact and influence on the future of architecture. “The Manifesto House captures how secular buildings of any size can be so much more than just being good, bad, ugly, beautiful or fitting, but can be almost magical embodiments of entire identities, philosophies, ways of being and seeing. Owen Hopkins takes us on beautifully enriching journey that weaves together personal histories, political beliefs, economic forces, social expectations, material geographies, and, yes, aesthetics and tastes, across the world and throughout time, all told through the incomparably fecund vessels of architect-designed houses.” – Adam Nathaniel Furman, co-author of Postmodernism

Fallingwater, Mill Run, Frank Lloyd Wright, Pennsylvania USA, 1936-8

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“At a time when housing - and the lack of it - is an urgent challenge worldwide, The Manifesto House gives us hope by describing how gifted and resourceful architects have devised new solutions to past housing crises by responding to cultural changes and the availability of new technologies in the design of innovative and ingenious homes.” – Alice Rawsthorn, author of Design as an Attitude >>>

pil136 January-March 2026

BOOKS: THE MANIFESTO HOUSE: BUILDINGS THAT CHANGED THE FUTURE OF ARCHITECTURE | OWEN HOPKINS >>>

LEFT: Casa Barragán, staircase from library, Luis Barragán, Mexico City, 1948, BELOW: E-1027, Eileen Gray, Cap-Martin France, 1929 RIGHT: Richard and Su Rogers, the Zip-Up House, 1967-9 BELOW RIGHT: Villa Mairea, front elevation, Alvar Aalto, Noormarkku, Finland 1938-9

Planning in London

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pil136 January-March 2026

Planning in London