National Planning Policy Framework consultation and next phase of planning reform

Our response

We welcome the Government’s National Planning Policy Framework reforms, particularly measures to support SMEs, increase densities, and deliver a broader mix of homes that reflect local needs, including for older people and rural communities.

• Removing the requirement for direct delivery of S106 homes on medium sites risks weakening these reforms. Delays in the current cash-in-lieu system, where funds often go unspent and are ultimately returned to developers, would slow the pace of social and affordable housing development.
• Our research shows that over one in ten S106 homes purchased by our members are on medium sites; for small and medium housing associations, this rises to one in four. Almost 10,000 affordable homes delivered nationally over the past three years wouldn’t exist if developers hadn’t been required to build them.
• In exceptional cases, where delivering affordable homes on-site is genuinely unviable, cash-in-lieu contributions must be swiftly converted into new affordable housing delivery by local authorities or Registered Providers. Where funds remain unspent within a set timeframe, they should be transferred to Homes England or the GLA to support grant-funded local delivery.
• Effective S106 delivery depends on early and consistent engagement between developers and housing associations and strong customer service throughout development and aftercare. Our research shows that when developers engage with housing associations early, they purchase twice as many S106 homes. DM1 should therefore explicitly name Registered Providers as bodies to engage at the pre-application stage.
• We also welcome the inclusion of a clearer policy on Rural Exception Sites (RES); but without a dedicated Permission in Principle (PiP), delays and risks will persist – particularly for smaller providers. We therefore recommend a bespoke RES PiP to streamline approvals and support stronger rural delivery.