Checklist problems

While traditional housing is a fundamentally important component of housing delivery, this approach often results in the unit mix being derived from a policy check-list. This itself is derived from needs based on traditional family-centric living patterns, rather than being informed by up-to-date evidence and the site characteristics – including whether the site is suitable for traditional housing. This can result in inefficient use of sites, housing products which do not align with market demand, undeliverable or unviable schemes, or poor quality family homes close to busy roads or without proper garden space.

Similarly, securing planning permission for other housing typologies, such as co-living, PBSA or retirement living, can be challenging to achieve in LPAs where there is a clear preference for (or an acute shortage of) traditional housing.

However these products are all key to a functioning housing market. They help to free up existing large homes and HMOs for those that need them the most by encouraging students and older people to move out of these homes into PBSA which better meets their needs. They also build communities with a blend of people from different backgrounds and age profiles that better reflect our society as a whole.

These diverse housing products can also help to unlock sites where there are viability challenges with traditional C3 housing, particularly in the current market. There will be inevitable fluctuations in the market, so policies need to allow for flexibility for developments to adapt to a changing market to avoid delays in sites being delivered.

The NPPF Reform

Encouraging and supporting a broad mix of housing typologies and is therefore key to an active housing market. Policies need to move away from promoting a traditional sense of what constitutes housing and should be flexible in welcoming a diverse range of housing products which reflect real need.

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Housing completions in England have been falling over the last 3 years, with 208,600 net additional homes delivered in 2024-25; a 6% decrease from the previous year. The government recognises that significant changes are required to achieve 1.5 million homes, with the draft NPPF proposing a series of measures to speed up housing delivery. These include:
 
· Policy HO5 requires development plans to address the housing needs of different groups, such as PBSA, self/custom built housing and specialist older persons accommodation
· Policy HO7 states that substantial weight should be given to the benefits of providing accommodation that will contribute towards meeting the needs of the local community
· Policy HO9 sets out development management requirements for housing for older people, specialist community-based accommodation, PBSA and large-scale shared living accommodation
 
These draft policies are a positive and encouraging indication of the government’s recognition of the importance of supporting diverse types of residential accommodation. They should hopefully result in more flexibly worded Local Plan policies which enable mix to be determined by up-to-date evidence which could be from the applicant, rather than relying on out of date Local Plan evidence.

It is also positive to see that specialist housing products are specifically supported and referenced. Encouraging and supporting these products therefore benefits the wider housing market by enabling more family homes to become available for those that need them the most.

Further considerations

There are aspects of the draft NPPF which could be improved upon, such supporting other forms of specialist housing including BTR – both co-living and single family housing.

Furthermore, requiring LPAs to identify sites suitable for specialist forms of accommodation (as proposed in Policy HO5) is likely to be too restrictive. A better approach would be to identify sites suitable for development, but to adopt a more flexible approach on the types of residential development that could be provided rather than restricting this to specific types of accommodation.

However, it is certainly a step in the right direction and it is clear that supporting a diverse range of housing typologies is going to be crucial in achieving an active housing market and speeding up housing delivery, which is key if the government is to come anywhere close to meeting the 1.5 million homes target.