Planning matters blog

Payback for build out: the PM’s case for social housing

Matthew Spry 14 Sept 2026

At Prime Minister’s Questions on Wednesday 9^th September, Andy Burnham argued that a major council housebuilding programme could save billions in Housing Benefit,[1] describing it as “the Labour way”.[2]

The PM referred to research from the National Housing Federation (NHF), which is seemingly the 2024 report by CEBR for NHF and Shelter.[3] It estimates that 90,000 Social Rent homes would generate £86.5bn of gross economic and social benefits over 30 years, including a net Exchequer benefit of £11.896 billion.

The report makes a strong strategic case for Social Rent. But its use in a debate about reducing welfare spending (to increase defence spending to 3.5% by 2035) raises three initial questions:

Do Housing Benefit savings pay for Social Rent homes?
How dependable are the other benefits? and
Where does the necessary funding come from?

There is also – as ever – a fundamental land and planning question about whether Section 106 can deliver the assumed cross subsidy the NHF/Shelter analysis requires of it.[4]

What the report says

The analysis covers a single annual cohort of 90,000 homes.[5] Although the wider proposition is a ten-year programme of 900,000 homes, CEBR does not model successive cohorts and notes that their operating environment and assumptions may differ. [6]

Table 1: The Report's Key Measures

Key Measure	Figure
Social Rent homes	90,000
Total development cost	£35.367bn
Government grant	£11.825bn
Provider and other funding	c.£23.5bn
Initial annual Housing Benefit saving	£243.8m
Housing Benefit saving, 30-year PV	£4.485bn
Gross Exchequer benefits	£23.721bn
Net Exchequer benefit	£11.896bn
Gross socioeconomics benefits	£86.5bn
Net socioeconomic value	£51.183bn

Source: CEBR

The £11.825bn grant required for one cohort is about three times the current programme’s average annual investment of £3.9bn, under which the Government expects 18,000 Social Rent homes a year.[7]

Do Housing Benefit savings pay for Social Rent homes?

No, and the NHF/Shelter report does not claim they would. The £4.485 billion saving is a discounted 30-year present value, compared with £11.825bn of government grant. The initial annual savings is £243.8 million.[8]

That estimate is based on a series of linked assumptions, for example, that 75% of occupants receive housing support and that vacancy chains ultimately release 65,292 homes to households otherwise living in the private rented sector, generating an annual rent-support saving of £3,735.5. Yet lettings data shows tenants come from a varied set of previous tenures and circumstances. Actual savings would depend on the circumstances and previous tenures of those housed.[9]

How dependable are the other benefits?

Of course, the potential savings for the Government are not limited to Housing Benefit (see Table 2), and the total (including housing benefit) is estimated at £23.8bn against a government grant for the programme of £11.8bn.

Table 2: Exchequer benefits from building 90,000 social rented homes

Exchequer benefit	30-year present value
Housing benefit saving	£4.485bn
Tax revenue from construction	£2.473bn
Universal credit saving	£3.289bn
Healthcare saving	£5.170bn
Homelessness-services saving	£4.512bn
Income Tax and NI from employment	£3.793bn
Gross Exchequer benefit	c.£23.7bn
Less government grant	£11.825bn
Claimed net Exchequer benefit	£11.896bn

Source: CEBR, Table 12

This wider fiscal case is credible in principle: secure housing can reduce homelessness and healthcare pressures and support employment.[10] But the estimates vary in robustness. Rent and temporary-accommodation savings follow relatively directly from lower housing costs. Healthcare, employment and tax benefits depend on longer causal chains, while construction taxes are net additional only to the extent that the programme does not displace other activity. The £23.7bn total should therefore be understood as a modelled estimate, not a guaranteed fiscal return.

Where does the necessary funding come from?

The NHF/Shelter report assumes £35.367bn of total development cost. Government provides £11.825bn of grant towards 60,000 homes; the remainder comes from provider resources, borrowing, rents and market activity, while 30,000 homes are assumed to be delivered without grant through cross-subsidy such as Section 106. The claimed fiscal return therefore depends not only on public grant but also on about £23.5bn from other sources.[11]

The funding ask is demanding:

The £11.825bn Government grant would need to be funded through borrowing, taxation, or savings. Given the current state of the public finances, it is reasonable to assume any programme of this kind would rely on borrowing. For all the long term benefits, it is not clear this uplift in funding would improve the Chancellor’s near-term fiscal headroom.[12]
Registered Providers face higher borrowing costs and increased spending on existing homes, while councils face construction-cost inflation, retrofit and safety obligations, and wider financial pressures.[13] The model treats the availability of this funding as an input rather than testing whether the sectors can provide it. In 2024/25, excluding s.106 homes, the sector itself delivered around 40,380 affordable homes, of which just 8,600 were Social Rent.[14] The Regulator of Social Housing reports on the 2025 Global Accounts of private Registered Providers says: “Providers continued to spend record amounts on improving the quality and safety of existing homes whilst also maintaining investment in new supply. When combined with higher rates of interest on new and refinanced debt, financial capacity remains constrained and some financial indicators have weakened at a sector level.”[15]
Meanwhile, 2024 research by UCL found whilst Council housebuilding is a mainstream activity, local authorities face a combination of obstacles, including construction-cost inflation, higher borrowing costs, housing-safety and retrofit obligations, wider local-government financial pressures and uncertainty over future planning and funding arrangements.[16]

Can the sector increase its total volume by 50% with a shift in its tenure towards a product with a lower revenue stream?[17] Obviously, the NPPF reforms and more Government funding as suggested by NHF/Shelter might help unblock latent capacity and address some of these issues.[18] But the report’s modelling still assumes a significant boost in investment from two sectors operating with financial pressures. The report treats funding flows as an input and does not test the realism of it being achieved.

Further, the above numbers relate to a single year. Repeated over ten years, the proposition would imply 900,000 Social Rent homes, £353.7bn of development cost, £118.3bn of grant and about £235bn of other funding. Stable procurement could improve productivity, but sustained demand might also increase land, labour and construction costs. A programme on this scale would therefore require explicit modelling of delivery trajectories, debt capacity, inflation and delivery lags.

Delivering the 60,000 grant-supported homes would also require councils and Registered Providers to act more extensively as developers: promoting and acquiring land, partnering with developers and progressing schemes ahead of plan allocations under NPPF Policies S45 and S5. Increased affordable housing funding can strengthen demand for consented land, but it does not create that land. Supply will take time to respond to the more permissive planning framework.

The big land and planning question

We come now to the third of Social Rent homes that the NHF/Shelter proposition says require no grant because they are funded through S.106.

Section 106 affordable housing is funded from development value after allowing for construction and finance costs, infrastructure, developer return and a competitive landowner return.[19] The CEBR results assume this mechanism can deliver 30,000 Social Rent homes each year without grant, but do not test whether that assumption is viable.[20]

Social Rent and Viability

Recent Section 106 delivery of around 20,000 to 26,500 affordable homes a year might make the 30,000-home assumption appear achievable.[21] However, this ignores two critical factors, as shown by Figure 1.

Figure 1: Affordable Housing delivered through s.106

Source: MHCLG / Lichfields Analysis

Firstly, s.106 affordable housing delivery is cyclical: it dropped 19% last year to about 23,400 homes, with more units funded by grant. This reflects the widely recognised squeeze in the housing market and difficulties experienced finding Registered Providers who want to take on new stock.[22]

Secondly, only 11–14% of s.106 homes are Social Rent, and annual delivery of those has never exceeded 4,000; the rest is Affordable Rent or intermediate products such as shared ownership.[23]

This reflects the underlying economics. Social Rent generates the greatest benefits through lower rents, but those same rents reduce the value available to fund construction. Without grant, delivery requires lower land values, few competing obligations, a strong sales market, a lower affordable housing percentage, or some combination.[24]

Overall housing delivery

The NHF/Shelter report does not calculate the total amount of market-led development needed to generate 30,000 cross-subsidised Social Rent homes. Our scenario testing below shows how quickly the denominator grows depending on the percentage of the total that is achievable reduces to respond to viability.

Effective affordable housing share	Total homes on market-led schemes	Other homes (i.e. market) within those schemes
20%	150,000	120,000
15%	200,000	170,000
10%	300,000	270,000
5%	600,000	570,000

Adding the 60,000 grant-supported homes produces total annual housing activity of 210,000 at a 20% Section 106 share, rising to 660,000 at 5%. Given the much lower value of Social Rent, achieving 30,000 units at 10% would be highly demanding; at 5%, it would require 570,000 associated market homes. The exercise underlines both the importance of meeting the Standard Method total of about 370,000 homes and the sensitivity of the proposition to viability.

Whatever the precise percentage, delivery depends on a planning system that releases sufficient land and a private market capable of generating the value needed for cross-subsidy. That requires buyer demand, mortgage availability, development finance and confidence that land pipelines can be replenished. Planning reform addresses only the supply side; some form of demand support may also be needed to increase build-out and Section 106 delivery.

Is the PM’s proposition sound?

The ‘housing theory of everything’ is a popular explanation for many societal ills.[25] The Prime Minister is clearly a subscriber. More genuinely additional Social Rent housing can reduce Housing Benefit, temporary-accommodation expenditure and other public-service costs, particularly in expensive housing markets.

The Prime Minister cited the NHF/Shelter research as the basis for his ‘Labour way’ approach to rebalancing public spending away from welfare. Yet the Government’s current grant funding programme for affordable housing – while a significant increase on what it replaced - is just a third of the scale that the NHF/Shelter report advocates. It will deliver some Exchequer benefits, but relative to the total size of the state (£1.29 trillion),[26] the scale will be modest.

What is the case for going further? Under the NHF/Shelter assumptions, one 90,000-home cohort initially saves £243.8 million a year in Housing Benefit and delivers a host of other benefits, including a net Exchequer saving of £11.896bn over 30 years.

The attractions to the PM of this argument are obvious. But there are nevertheless a series of challenges and unanswered questions:

The report does not show that Social Rent pays for itself through savings on Housing Benefit. The modelled 30-year saving is £4.485bn against £11.825bn of government grant
The claimed £11.896bn net Exchequer benefit depends on combining that saving with less direct and inherently less certain assumptions about health, employment, Universal Credit, homelessness and tax receipts. These benefits are plausible, but many are downstream of the direct intervention or subject to other assumptions.
Most importantly, the result depends on Government funding only one third of the £35.367bn development cost. Councils, Registered Providers, rental income and market activity must pick up the rest.
Councils and Registered Providers face financial pressures and their capacity to deliver at scale – at least in the short term - is uncertain.
30,000 Social Rent homes are assumed to be delivered without grant through cross-subsidy such as s.106. This is the report’s most demanding assumption:

a. Recent s.106 delivery has been below 25,000 affordable homes of all tenures, with only a small proportion provided as Social Rent;

b. Currently, around 10-13% of net additional homes each year are delivered through s.106, and this model is under viability pressure. If Social Rent represented 10% of homes on relevant market-led schemes, delivering 30,000 units would require 270,000 associated market homes. At 5%, it would require 570,000. The fiscal proposition therefore relies on land being released at least in line with the Government’s Standard Method target, schemes remaining viable and the private market absorbing homes at a sufficient rate, likely supported by some kind of demand-side assistance.

The significance of these points for the Government’s wider agenda for re-balancing spending is this:

a. The net Exchequer benefits depend on the Government achieving 90,000 Social Rent homes through directly funding only one third of the cost.

b. If cross-subsidised homes were not delivered, and the same £11.825bn grant produced only 60,000 Social Rent homes the modelled net Exchequer benefit would fall to about £4bn over 30 years; within the margin of error given the causal chain involved.

c. If Government instead had to double its grant investment to £23.65bn because of weaknesses in other funding from Local Authorities or Registered Providers, or viability of s.106, almost all the claimed Exchequer benefit would disappear.

The central point is that Social Rent does not sit apart from the wider housing market. Large-scale provision can create substantial public value, but the fiscal return is not axiomatic. In addition to huge questions over public spending, it depends on sufficient land supply, viable development, Section 106 delivery, council and Registered Provider capacity, and a functioning private sales market. Any attempt by Government to go further and faster on its affordable housing programme will need to address those dependencies if it wants to realise the benefits.

Footnotes

[1] He said: “We have set out plans for the biggest council house building programme this country has seen in a generation. If the right hon. Lady looks at research from the National Housing Federation, she will see that that is the route to save billions from housing benefit.” Hansard, 9th September, Column 1037
[2] See this BBC News Story National security can't come at expense of social security, Burnham says 9th September 2026, accessed 10th September 2026
[3] CEBR, The economic impact of building social housing report produced for NHF and Shelter, February 2024
[4] It wouldn’t be a Lichfields blog without one.
[5] Based on the need analysis in the Glen Bramley’s 2019 research on housing supply requirements
[6] See footnote 6 of the NHF/Shelter report.
[7] MHCLG Policy paper: Social and Affordable Homes Programme 2026-2036: MHCLG policy statement to accompany guidance to bidders from Homes England and the Greater London Authority, 7th November 2025. The 18,000 is out of a total of 30,000 Affordable Homes, with the balance made up by other tenures.
[8] See Sections 4.2 and 5, Tables 12–14, pp. 48–54. The discounted Housing Benefit saving recovers about 38% of the public contribution before financing or opportunity costs
[9] MHCLG, Social housing lettings in England, tenants: April 2024 to March 2025, 13th November 2025. The statistics show the variety of previous circumstances from which households enter social housing, including private renting, temporary accommodation, owner occupation, living with family and friends, and other routes, illustrating the uncertainty around assumptions concerning future vacancy chains and Housing Benefit savings
[10] See for example the analysis here (drawn from the Milburn Review on NEETS) and here (the Lichfields work for HBF on the impact of reducing housing supply)

[11] See the NHF/Shelter report - Section 2.1, pp. 16–17, and Section 4.5, p. 50.
[12] The Debt Management Office's own results show a Treasury Gilt maturing in 2054 priced at a yield of 4.5699% in January 2024, and as high as 5.8168% on 8th September 2026. See UK Debt Management Office Results of Syndicated Offerings
[13] See the NHF/Shelter report - Section 2.4, pp. 32–36.
[14] See MHCLG Table 1000 on affordable housing supply
[15] Regulator of Social Housing, 2025 Global Accounts of private registered providers, 15 January 2026
[16] UCL Local authority Direct Provision of Housing: Fourth Research Report January 2024
[17] Taking an illustrative example of a market rent of £1,500 per calendar month (ONS Private rent and house prices, UK: August 2026 shows average rents of £1,451 in England), affordable rent at 80% equates to £14,400 annually, whereas Social Rent at 50% would be £9,000. This would create a gross annual gap of up to £5,400 per home, which across 30,000 homes would amount to up to £162m before other costs. See this 2026 Policy Statement on rents for social housing
[18] Just as the Government’s boost in funding for affordable housing in 2025 has been welcomed by NHF for these reasons.
[19] My blogs on LVC (in the context of the debate on hope value) and the Green Belt Golden Rules explored this approach.
[20] See NHF/Shelter Report - Section 2.1, pp. 16–17, and Section 4.5, p. 50.
[21] See MHCLG Table 1000 on affordable housing supply
[22] Yielding this Government response Policy statement: a roadmap for Section 106 delivery in England, March 2026
[23] See MHCLG Table 1000 on affordable housing supply
[24] See the PPG on Viability. The number of affordable homes currently being delivered by s.106 are the product of Government viability guidance which requires plans to specify and test the amount and type of affordable housing, including minimum Social Rent requirements
[25] The housing theory of everything - Works in Progress Magazine
[26] HMT Public Spending Statistics, May 2026

Spatial development strategies and national policy

Edward Clarke, Dominic Bowers & Jennie Baker 02 Sept 2026

The roll-out of strategic planning has started, reflecting the last Government’s intention that there would be England-wide coverage by the end of this Parliament, expected to be in Summer 2029. Strategic planning will be via spatial development strategies (SDS), albeit there is a current separate consultation on Mayors of strategic authorities having development management powers ahead of an SDS being published[1].

The legislative basis for SDSs and the bodies that prepare them is in the Planning and Infrastructure Act 2025 and the English Devolution and Community Empowerment Act 2026.

Earlier Lichfields analysis of the legislation and of a consultation on SDS geographies provides a background to this blog.

The last Government consulted on the proposed geographies over which each SDS will apply, from February to March 2026, with the outcome awaited. The Lichfields blog Spatial Development Strategy Geographies: Will the map change the landscape? considered the make-up of the proposed new geographies and explored some metrics related to two of their key priorities: meeting housing needs and growing the economy. The findings of that blog remain relevant, so we do not delve into them here.

Bethan Haynes explained the intention and challenges for SDSs, including how they are administered, and reflected on the (then) Planning and Infrastructure Bill requirements, in her blog of March 2025 [2]. A follow up to that blog, ‘Big plan theory’, considered the progress that had been made on SDSs by the end of last year[3]. In that blog, Ed, Dom and Myles considered changes to the then English Devolution and Community Empowerment Bill as it had progressed through the Houses. This blog further considers some of the queries raised in the 'Big plan theory' blog, with reference to the NPPF as now published.

Beyond the legislation and the awaited consultation outcome on geographies, the National Planning Policy Framework (NPPF)[4] sets out the national policy for plan-making, including 17 specific plan-making policies. This blog focuses on plan-making policies particularly applicable to SDS preparation.

The NPPF defines a spatial development strategy in its glossary at Annex A:

“Spatial development strategy: A plan containing policies on the development and use of land on matters of strategic importance to the area prepared by strategic planning authorities and the Mayor of London”.

National plan-making policies

The NPPF’s introduction explains that there is some interpretation needed when applying national policy to Spatial Development Strategies (SDS), because whether SDS, local plans and/or supplementary plans address certain thematic plan-making policies will depend on the area to which the plan relates.

This is discussed further below, in the context of the need for collaboration across boundaries and between bodies.

It also reminds of an important point when considering the role of SDS in the development plan: “The relevant legislation does not allow spatial development strategies to allocate specific sites or designate specific areas of land”.

The NPPF also explains how SDS should be prepared and examined. Policy PM14 says that a sound SDS should satisfy tests of being “positive”, “appropriate”, "effective" and "consistent with national policy".

PM1: Spatial development strategies

Policy PM1 is the overarching national policy regarding the preparation of SDS. PM1(1) sets the tone:

“[An SDS should] set a positive vision for future growth and change at a sub-regional scale and provide a clear spatial framework for investment and growth, including for new housing”

Setting out the aims of an SDS, the NPPF is clear that its “Content should be genuinely strategic in nature”. Parliamentary debates during the passage of SDS related legislation made clear that the last Government and other politicians were keen to avoid future strategic plans having the length or detail of the London Plan.

The draft new London Plan is out for consultation at present. Sally Furminger and Ross Raftery's blog 'Assessing the draft London Plan's position on housing: does it make the grade?' observes that the emerging London Plan is likely to be the first SDS to be tested against the NPPF 2026. Sally and Ross give an initial verdict on the draft London Plan’s approach to housing matters against the tests of soundness in the then draft NPPF policy PM14, which is broadly unchanged in the final version. They conclude that "There is a positive shift in approach, but some policies and the new 'boxes' remain long and detailed". It will be interesting to see the extent to which the final published London Plan provides a model for strategic authorities outside of London, albeit that London has unique issues which mean that its SDSs are always likely to be somewhat different to others in England. The current will naturally be a trailblazer against the NPPF in any event.

The current Government has continued to seek to design the system to avoid unnecessary policy duplication or complication, including the ‘layering’ of policies. More detailed or locally specific issues should go into local or supplementary plans as “other parts of the development plan” or will have been picked up through National Decision Making Policies[5] .

The NPPF sets out nine ways that the positive vision, clear spatial framework and genuinely strategic content should be achieved, lettered a-i, which provides a list of minimum contents, evidence and analysis for SDSs (PM1(2)).

We review or provide a summary of each.

Plan period, monitoring and implementation – strategic means strategic

PM1(2) a. and b. set out timescales and the locations for growth that should be identified.

“a. Setting out a strategy for a sustainable pattern of growth covering a period of at least 25 years, including through the apportionment to local planning authorities in the strategy area of objectively assessed needs for housing and other uses that are best considered at a strategic scale for the duration of the plan period;”

And

“b. Identifying broad locations for growth and regeneration, including new settlements, major urban extensions, major cross-boundary development and other key locations with the potential for significant new homes, jobs and other development [which should extend over strategic site allocations in adopted plans]”;

The draft NPPF consultation document proposed a 20-year period. The Government has increased this to 25 years “To support long-term certainty for planning, infrastructure delivery and investment”, according to its response to the national policy consultation[6].

The 25-year period is a different timescale to the 10 years for which an LPA must consider housing needs via the local plan (the local plan period was to be 15 years in the consultation NPPF).

The SDS period should be read with the monitoring and implementation policy for SDSs, set out at i. This says that commencing preparation of a replacement or altered version should happen no later than seven years after the current version was adopted, or earlier, if certain criteria are met. The criteria are essentially where either the strategic planning authority or Mayor of London consider the SDS inconsistent with national policy, or changes are planned to infrastructure that might affect delivery or to respond to new evidence that show significant changes to needs, opportunities or development constraints.

Setting strategic development locations will be a key priority for SDSs; the ability to plan over 25 years will allow for medium to large sites to be planned for in this way along with enabling infrastructure. However, our research on planning and development timelines has shown, that for the largest of sites for example new settlements, this time frame will remain challenging.

Indeed, the last NPPF (2024) was clear that “Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery”. If, as directed by PM1, SDS should identify ‘broad locations’ for growth and if HO4 requires development plans to identify suitable locations for strategic sites for housing-led development – both of which includes new settlements – SDS should surely look ahead at least 30 years?

The interface of plan-making, between SDS and local plans, is explored in Matthew Spry’s recent blog Make more little Plans? The NPPF’s shift to ten-year local plan periods.

PM1 says SDSs should also be:

“c. Supporting economic growth by providing a spatial framework for strategic investments and giving spatial expression to strategic elements of Local Growth Plans and the Industrial Strategy[…];

d. Identifying the general extent of areas established as Green Belt and broad locations where changes to Green Belt boundaries may need to be considered through local plan preparation, if necessary to meet the development needs of the strategy area;

e. Identifying broad locations for nature conservation and habitat enhancement, restoration and creation; and addressing strategic issues relating to the protection and enhancement of the historic environment;

f. Setting out the type, extent and broad location of strategic infrastructure needed to enable development and serve existing communities […] [and make provision for certain committed infrastructure];

g. Using appropriate maps and diagrams to illustrate and communicate the strategy;

h. Providing a proportionate level of information on the mechanisms for delivering the strategy”

[…];”

The SDS will be expected to identify the broad locations for infrastructure investments, and other aspects (as above) with local plans covering the detail. The ‘general extent’ of Green Belt boundaries might be open to interpretation and will likely be contested locally in areas with Green Belt constraints, where the combined housing needs of an SDS area are high.

With regard to requirement g., appropriate maps and diagrams, policy S2(2) (Producing a spatial strategy) says:

“The spatial strategy should be illustrated on a key diagram forming part of a spatial development strategy and/or local plan (or minerals and waste plan, where relevant), with the boundaries of specific policy areas, land-use designations and allocations identified on a policies map”.

The policies map[7] is a map required by the new plan-making system, which identifies all the development plan allocations on an Ordnance Survey base. A spatial development strategy cannot allocate sites and so the key diagram will not be included on the policies map. The policies map allocations are the fine grained, follow up to the broad locations identified on the key diagram.

General principles – do not duplicate policy

In addition to the emphasis on SDSs planning at a strategic level in PM1, policy PM6 sets out plan-making principles that are applicable to all plan-makers, including SDS authors. Of note, plan-makers should:

a. Only address matters, and include policies, that are necessary and relevant to the plan being prepared, and that avoid unnecessary duplication of other parts of the development plan;

c. Not include policies which duplicate, substantively restate or are inconsistent with the content of national decision-making policies, unless directed by other policies in this Framework;

PM6(1)c. above reflects the "consistent with national policy" soundness test in PM14, as one would expect, albeit allowing for the NPPF itself to cause policy duplication, restatement or inconsistency. PM6(1)a. above indicates that duplication across a development plan might be acceptable in some instances, given that plan-makers should "avoid unnecessary duplication of other parts of the development plan" (our emphasis).

Overall, the NPPF seeks to establish a clear delineation between national, strategic and local policy in terms of policy formulation. However, establishing such policy boundaries will not be straightforward, as the NPPF itself acknowledges, because the NPPF leaves open to interpretation which level of policy making should address certain matters, as discussed below.

Local plan interface and cross-boundary cooperation

Policy PM10 sets the approach to maintaining cooperation on cross-boundary matters and PM11 on demonstrating cooperation.

PM10 requires plan-making authorities to engage “proactively and regularly with infrastructure providers, neighbouring and other relevant plan-making authorities (where there are strategic interdependencies across boundaries)”. It also requires similar engagement with “other relevant bodies” regarding the need to address cross-boundary matters, identifying additional infrastructure, identifying development needs extending beyond a plan area and determining optimal growth locations as needing such cooperation.

The Government’s response to the national policy consultation says that PM10 and PM11 “support flexible and proportionate approach” and that guidance will also be published to support authorities in meeting those policies.

Acknowledging the wide range of bodies that the need for cooperation applies to, the response also says, “The government will also continue to work with relevant government departments and infrastructure bodies to improve alignment between long-term infrastructure planning and development plan-making, including through wider infrastructure planning reforms”.

The vision and spatial strategy of a local plan should support the delivery of the spatial development strategy (PM2). Relating back to that important interface between local plans and SDS, and linked to PM6 regarding duplication, PM10(3) also states that:

“Where matters are already addressed by an adopted spatial development strategy, plan-making authorities within the strategy area do not need to revisit them when preparing their plans”.

The ‘matters already addressed’ referred to in the policy wording includes housing targets i.e. SDSs will be required to set out each constituent LPA’s housing need figures against which their local plans and housing delivery test measurements will be assessed.

PM10(4) refers to using ‘available information’ a term carried over from the superseded NPPF 2024:

“Where there is uncertainty about the future direction of other parts of the development plan or the plans of infrastructure providers, such as due to misaligned timings, plan-making authorities should make pragmatic decisions on the basis of available information rather than waiting for a full set of evidence from other bodies”.

In many areas this is likely to be crucial, given the potential lag between an SDS and a local plan being prepared, as it avoids the pitfall of the uncertainty of ‘unmet need’ numbers.

A potential challenge to this new system is how to deal with the unmet need in an SDS that cannot meet its own housing needs within its boundaries. For example, an urban combined authority that might have previously (under the duty to co-operate) shared need with neighbouring local authorities, that form part of the same housing market area but are now in a different SDS. Essentially, the challenge is how to deal with unmet need that remains at an SDS level across different SDS areas.

A further key issue to consider here, and as noted above, is that some making policies in the NPPF ask that a matter is addressed “at the most appropriate plan level”.

The NPPF’s introduction says:

“The plan-making policies should be read as a whole (including relevant footnotes and annexes), and applied in a way that is appropriate to the type of plan being produced, the area that it covers and the period it is intended to cover. Reflecting this, some of the plan making policies indicate actions that should be taken at the most appropriate level, which recognises that plan-making arrangements will vary across the country (for example in the geographic scale of spatial development strategies and local plans). Where policies relate to matters that are primarily local in scale, and/or are concerned with detailed implementation, they will not generally apply to spatial development strategies."

In some cases, particularly where an allocation is referenced, this will mean deciding whether or not the policy should be in the local plan or in a new, statutory, supplementary plan, rather than in an SDS. In other cases, such as looking at housing need for different groups, providing for economic growth and/or avoiding constraints on expansion of renewable and low carbon energy, particular collaboration between SDS plan-makers and local plan-makers will be needed. Alternatively, it seems possible that if evidence shows that a local plan would be justified in addressing a given matter via a new policy, notwithstanding that a similar SDS policy addressing the matter being in place (and vice versa), that new policy can be adopted/published. In such a case, the most recent policy will prevail if there is any inconsistency[8]. This alternative may also apply to the ‘matters already addressed’ in an SDS (PM2), discussed above.

The Government’s SDS geographies consultation said effective cooperation would be tested at examination and noted particular locations where such cooperation will be important:

“There are some large-scale growth areas that cross multiple SDSs, such as the Northern Growth Corridor, Oxford-Cambridge Growth Corridor or the Thames Estuary. The government will expect SDSs to be supportive of the growth ambitions of these areas and to have consistent approaches across SDS boundaries.

There are also several parts of the country where national park authorities straddle proposed SDS boundaries and are the local planning authorities. Engagement with these authorities will be particularly important for the relevant strategic planning authorities”.

In areas undergoing local government reorganisation and where there is some uncertainty over boundaries, there is an additional layer of matters to consider when SDS plan-makers and local plan-makers collaborate. The Government has said it will “publish transitional regulations in due course to deal with the various plan-making complexities arising because of local government reorganisation”[9].

Positive plan-making

The plan-making policies within the chapter on achieving sustainable development and policy PM14 (Examining spatial development strategies), emphasise the need for positive plan-making. Policy S1 says that planning positively means providing for new development and environmental improvements in a way that promotes a sustainable pattern of growth and seeks to mitigate climate change and adapt to its effects. It also means “providing for objectively assessed needs for housing, business and other uses (including supporting infrastructure), as well as any needs that cannot be met within neighbouring areas, unless:

i) The application of the policies in this Framework that protect areas or assets of particular importance [FN24][10] provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or

ii) Any adverse impacts of doing so would substantially outweigh the benefits, when assessed against the policies in this Framework taken as a whole”.

With regard to the “positive” test of soundness, PM14(2)(a) says:

“The strategy sets out a positive approach to delivering growth which, as a minimum, seeks to meet the area’s objectively assessed needs, and is based on effective joint working on cross-boundary strategic matters. A strategy which does not provide for objectively assessed needs should be considered an exception, and only where it is evidenced that stringent efforts have been taken to meet those needs through cooperation with other strategic planning authorities”

The explicit reference to a need for the SDS to be positive is helpful, with the emphasis on these plans meeting their needs except when there is evidence “that stringent efforts have been taken to meet those needs”. Positive planning means “meeting the development needs of an area” is described as a minimum, for both SDSs and local plans.

Under this framework, an SDS becomes the basis for the level of development in an area (including as PM10 notes, housing need). SDS are considered to address both the duty to cooperate issues that arose in the last plan-making system and to address broader land supply challenges.

Other plan-making policies

National plan-making policies that expressly guide SDS preparation and application include:

HO1/HO2 – SDS to assess the need for homes and establish a housing requirement
M1 – SDS to assess the provision needed for aggregate and industrial minerals, where appropriate
GB2 – assess the strategic role of Green Belt land within the strategy area and identify where boundaries may require further consideration in local plans
TR1 – SDS may set thresholds for what constitutes a significant amount of [transport] movement arising from new development.

In addition to policies that expressly state what an SDS should include, SDS plan-makers will need to consider how to address themes that might require agreement between the strategic authority and its constituent local authorities as to which is the ‘most appropriate plan level’ for a given policy, as discussed above. These include policy E1, which says that development plans should, at the most appropriate level, provide the conditions for long-term economic growth.

Final thoughts

As noted in earlier Lichfields analysis, strategic planning has the potential to overcome some of the most significant barriers to development that we have seen over the last decade and to unlock a genuine solution to cross-boundary issues like infrastructure and housing. The ongoing challenge of local government reorganisation and strategic authorities will be key to ‘getting the geography right’ in some of the most politically sensitive areas, as well as the capacity and institution building necessary to get effective plans means that we are still a way off from universal coverage. Political crosswinds, economic challenges and the ongoing stasis in much of the economy will continue to challenge development in many areas. However, for the strategic authorities that are already in a position to start preparing their SDS, there is the potential to provide effective integrated strategic plans that reflect local needs and cover the next twenty five years of development.

As the conclusion to the Lichfields ‘Spatial Development Strategy Geographies: Will the map change the landscape?’ blog says:

“It is early days and a mixed picture. The strategic planning landscape in some areas continues to look auspicious, notably the Combined Authorities with mayors who are keen to win the race to be first to adopt an SDS”.

Work has started on SDSs in Strategic Authorities outside of London that are run by elected mayors. See Table 1 for our understanding of current progress in these authorities.

Table 1

Strategic authority	Status	Target adoption year	Notes
Greater London	Published	Published 2021	Draft plan to replace existing plan released in July 2026, with adoption target of 2028.
Liverpool City Region	In development	2027	In preparation since 2019. Aiming to publish a draft version of the SDS for consultation in late 2026, with submission and possible adoption target of 2027.
East Midlands	Early in development	2028	Work formally approved in March 2026, with adoption target of 2028.
North East	Early in development	2028	Began preparation this summer. Aiming to be one of the first regions with an SDS in England, with submission target of late 2027 and adoption of 2028.
West of England and North Somerset	Early in development	2029	Begun preparation, with consultation target of autumn 2027 and adoption target of spring 2029.
Tees Valley	Early in development	Not yet announced	Appointed a consultant to begin preparing an SDS in August 2026.
Cambridgeshire and Peterborough	Early stage scoping	Not yet announced
Greater Manchester	Early stage scoping	Not yet announced
West Midlands	Early stage scoping	Not yet announced
South Yorkshire	Early stage scoping	Not yet announced
West Yorkshire	Early stage scoping	Not yet announced
York and North Yorkshire	Early stage scoping	Not yet announced
Greater Lincolnshire	Early stage scoping	Not yet announced
Hull and East Yorkshire	Early stage scoping	Not yet announced

Footnotes

[1] Planning powers for mayors in England, open consultation, closes 5 October 2026

[2] Spatial Development Strategies – a planning panacea?

[3] Big plan theory: how planning reform is shaping spatial development strategies

[4] The National Planning Policy Framework, August 2026

[5] National decision-making policies are a critical material consideration when determining planning applications, according to the NPPF

[6] National Planning Policy Framework consultation - government response

[7] How to present your policies map

[8] Section 38(5) of the Planning and Compulsory Purchase Act 2004

[9] Plan-making and local government reorganisation

[10] Footnote 24 says: The policies referred to are those in this Framework (rather than those in development plans) relating to: habitats sites and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, a National Landscape, a National Park (or within the Broads Authority) or defined as Heritage Coast; irreplaceable habitats; designated heritage assets; and areas at risk of flooding or coastal change.

Make more little Plans? The NPPF’s shift to ten-year local plan periods

Matthew Spry 27 Aug 2026

The Chicago urbanist Daniel Burnham made this famous injunction to planners:

"Make no little plans; they have no magic to stir men's blood."[1]

It creates a slightly awkward contrast with one part of the first planning policy issued under his Prime Ministerial namesake. The August 2026 National Planning Policy Framework (NPPF) reduces the minimum local plan horizon from 15 years to “no less than 10 years from the point of adoption.”[2]

The change most respondents didn’t ask for

The December 2025 draft did not start here. Draft Policy PM2 proposed retaining the 15-year horizon. It was the accompanying consultation that asked whether this should instead be ten years.^[3]

The Government response records 1,074 responses to Question 10a. 69% disagreed with reducing the period to ten years. The response summarised the main concerns: that a shorter horizon would undermine long-term planning and create difficulty for larger strategic sites. The Government nevertheless proceeded, citing the new 30-month timetable, the expectation that plans are commenced no later than five years after adoption, and the role of Spatial Development Strategies (SDSs) in setting a longer strategic framework.^[4]

Of course, it is for Government’s to decide: a consultation is not a referendum. But it does mean the shift should be seen for what it is: a deliberate choice rather than a product of consensus.

Back to the Future?

As ever, there is a historical benchmark.

PPG12 (1999) advised that the duration of local plans should normally extend for ten years from forecast adoption date.[5]

Back then - as now intended with SDSs - a local plan did not carry the strategic burden. In two-tier areas, the Structure Plan provided a county-wide framework. The local plan translated that into detailed allocations and policies. Above it was Regional Planning Guidance (RPG).

The 2004 reforms replaced RPG and Structure Plans with statutory Regional Spatial Strategies (RSSs). The 2004 update of PPS12 maintained the ten-year horizon, but with the aim to look ahead for the longer-term, set by RSS.[6]

So, is the case for moving back to ten years properly explained simply with reference to reintroduction of a strategic planning tier? Only up to a point.

The move to minimum 15-year period from adoption period for local plans actually came in the 2008 version of PPS12, when the then-Government’s vision for strategic planning was at its zenith.[7]

This was then carried through into the localism era; to the 2012 NPPF where a 15-year horizon was a ‘preference’.[8]Later NPPF editions converted this into a firmer ‘minimum’,[9] with a vision for longer periods (of up to 30 years) expected where plans included larger-scale development.[10]

The new shift to ten years is therefore a genuine reversal in approach, even if it revives a duration from a previous planning generation.

Why the effective plan period will be much shorter than ten years

Even if the nominal period for the plan is ten years from adoption, the period for which its new proposals can influence housing delivery is shorter, perhaps just half its period. This comes down to lead-in times and the inescapable facts of a trajectory.

Under Policy HO3, plans need to demonstrate a five year land supply of “specific deliverable sites” at adoption and developable sites for years six to ten.

Most of the supply treated as deliverable in years 1–5 will come from the inherited planning and development pipeline.[11]

A plan’s new proposals focus more on shaping supply in years 6–10 and beyond, as developable sites and broad locations come forward following applications prepared in the first phase. The window in which new allocations can move through consent and into delivery has been heavily concentrated from years six onwards.

A shorter plan period, might not matter if development was getting faster. The evidence points the other way.

Lichfields research - How long is a piece of string? - found that the average time taken to determine a major outline residential application had risen from eight months in 2014 to two years in 2024.[12]

Strategic sites: less reward for the same difficulty

The analysis in Start to Finish shows that for large strategic sites of 1,500 homes or more - the threshold the NPPF itself now uses to define one^[13] - the planning and pre-commencement periods can run well beyond five years before a single home completes.^[14] All things being equal, the strategic sites the NPPF now encourages (via Policy HO4) will contribute relatively little or nothing within the ten-year period against which the plan is tested.[15]

Strategic sites require the most difficult choices about the distribution of growth, settlement form, infrastructure funding, transport, landscape, Green Belt, education, health, utilities, viability and community impact. They are also most politically visible. The costs, controversy and technical work are front-loaded. A shorter plan period does not make any of these issues any easier. It simply reduces the proportion of the site’s eventual output that helps the plan meet its requirement. This changes the calculus for difficult choices and trade-offs – see Table 1. It is ironic[16] that the NPPF’s positive framework for strategic sites is accompanied by a measure that makes local planning authorities (LPAs) less incentivised to allocate them.

Table 1 Fifteen year and ten-year plan horizons: different incentives

Issue	15-year plan horizon	10-year plan horizon
New strategic allocations	More later-year delivery can count toward the plan period.	Earlier years dominate the development trajectory.
Infrastructure planning	More scope to plan for strategic infrastructure and phased delivery.	Greater temptation to rely on infrastructure already in the pipeline or capable of near-term delivery.
Political incentives	Difficult choices are harder to defer because more need must be planned for.	More difficult or strategic choices can be pushed into the next local plan.
Housing supply resilience	More capacity to create a rolling pipeline beyond existing permissions and hedge against uncertainties associated with supply.	Greater dependence on existing commitments, windfalls and residual allocations.

SDSs are the counterargument - but not a complete answer

The Government’s consultation response points to the fact that local plans site alongside SDSs which will set a positive vision for growth at a sub-regional scale. The December 2025 draft suggested they plan for at least 20 years; the 2026 NPPF increased it to 25.

Policy PM2(1)(a)(iii) requires local plans to reflect longer-term expectations extending beyond the plan period where appropriate, including for large-scale development proposals.

That provides a hook for local plans to engage with large-scale development that will not make its full contribution within the 10-year local plan period. It gives examining Inspectors and strategic plan-makers the basis to ask whether a local plan is genuinely aligned with the longer-term picture rather than simply meeting the housing needs of the first decade (See NPPF Policy PM2(1)(a)(iii) and PM2(1)(b). But that leaves three practical challenges:

Dependency on the SDS doing the hard yards of identifying broad locations for growth, rather than just distributing housing targets. The history of some RSSs shows such plans can also be vulnerable to political deferral.[17] Will all Mayors and combined authorities be up to the challenge of setting broad locations rather than delegating the difficult choices to LPAs, who can then use a shorter plan period to duck them?
Secondly, timing matters. Many SDSs will need to be prepared through new as yet untested governance arrangements. That creates uncertainty over sequencing; if the new plan making system is as effective as promised, many new-style local plans are likely to be well down the track before the SDS has laced its boots.
Thirdly, SDSs do not allocate specific sites or scrutinise deliverability in the way local plans do.[18] Experience suggests that LPAs ambivalent about growth can be adept at deferring the difficult question (for, example, an SDS broad location where the local evidence suggests barriers to implementation) to the next local plan cycle. They may have in mind a hope for a change in political weather that will see the SDS revoked or changed in the meantime.

Strategic planning is essential, but it is not magic; nor is its effectiveness automatic. It will need governance, evidence, discipline, scrutiny and diligent examining inspectors.

Ultimately, there is little evidence that 15-year local plans were an obstacle to strategic planning. Indeed, the 2008 PPS12 shift to 15-year plans suggests they are (were) an enabler of its effectiveness.

What problem is the ten-year plan designed to solve?

There is a legitimate concern that local plans have been too complex, take too long to prepare, and often failed to stay up to date. But it does not follow that a 15-year horizon was the cause. The evidence points to a broader set of problems: policy churn, resourcing constraints, statutory consultee delay and political risk.[19]

That being the case, the solutions are to simplify process, reduce duplication, improve evidence proportionality, align infrastructure bodies, maintain clear national policy and properly resource plan-making. That is what the LURA and new NPPF reforms have been about.[20]

Does a shorter period, thus with less housing to provide for, mean the local plan strategy easier to prepare? Counterintuitively, the answer is no; it may even make it more difficult. A study of most housing supply trajectories explains why. They typically show a total supply broadly equal to the plan’s total housing requirement (its target) with the delivery of pipeline supply in years 1-5, a bulge of developable sites for years 6-10 before it falls away in years 11-15.[21] Real world delivery is then spread out, some sites proceeding as planned, others taking longer.[22] Reduce the plan horizon to ten years and you concentrate the risk associated with delivery in years 6-10 onto a smaller pool of sites. This demands better evidence on deliverability or to allocate more land than the total housing requirement to act as a buffer.

The shorter horizon thus sits a little awkwardly with the Minister of State’s recent letter on pragmatism in local plan examinations.[23] The letter urges inspectors to assess allocations over the plan period as a whole and to distinguish fundamental barriers from matters that “could reasonably be expected to evolve over time as market conditions change”. Its central proposition depends on there being sufficient time for circumstances to evolve; ten years gives less of it.[24]

The change to ten year plans does not itself simplify; it just reduces how much future growth the plan must address. If a barrier to plan making was that they involve difficult choices over planning for growth, it is an curious response for a growth-orientated government to say the answer lies in asking them to do less.

More little plans?

Most of the policies in the new Framework seem likely to support the achievement of the Government’s ambitions for housing growth, but the shift to ten-year local plans is a material wrinkle.

The change was not asked for and the case for it is not proven. There are arguments to support how it might work that are coherent in theory.[25] But only if every plan maker behaves how the Government wants them to.

But history tells us not all participants in plan making do what Government expects, and minimum requirements shape behaviour. And any political instability at local, mayoral and national levels will make it more likely plan making is gamed or decisions are ducked, with growth falling between the cracks. The case for sticking to 15 years was (and is) unassailable.

Daniel Burnham’s maxim was not arguing for big plans at any cost. It was an argument for plans with enough ambition and permanence to shape the future. More frequent plans may be welcome, but if each local plan is encouraged to look only just far enough ahead to avoid the toughest choices, the system may produce more plans while doing less effective planning.

Footnotes

[1] Those interested in diving down rabbit holes can trace the etymology of that particular quotation here. The full quote, which came as the peroration of a longer speech, was: “Make no little plans; they have no magic to stir mens’ blood and probably themselves will not be realized. Make big plans; aim high in hope and work, remembering that a noble, logical diagram once recorded will never die, but long after we are gone will be a living thing, asserting itself with ever-growing insistency. Remember that our sons and grandsons are going to do things that would stagger us. Let your watchword be order and your beacon beauty.”

[2] Policy PM2(1)(b) of the new Framework says the local plan should set “out a spatial strategy, policies for the minimum amount of development to be provided, land allocations and broad locations for growth, and designations in accordance with policy S2, for a period of no less than 10 years from the point of adoption of the plan."

[3] MHCLG, National Planning Policy Framework: draft text for consultation, December 2025. Question 10.

[4] MHCLG, Government response to the proposed reforms to the National Planning Policy Framework and other changes to the planning system consultation, August 2026.

[5] ODPM, Planning Policy Guidance Note 12, 1999, para 6.8. It also applied to Part II of Unitary Development Plans.

[6] Para 2.14 of PPS12 stated: “The local planning authority should ensure that policies and proposals in the core strategy provide certainty for the future. The time horizon of the core strategy should be for a period of at least 10 years from the date of adoption. However the core strategy should aim to look ahead to any longer-term time horizon which is set out in the relevant regional spatial strategy. The core strategy should be kept under review and the horizon rolled forward in subsequent reviews of the document.”

[7] CLG, Planning Policy Statement 12: Local Spatial Planning, 2008 - Para 4.13

[8] MHCLG, NPPF, March 2012

[9] MHCLG, NPPF, July 2018

[10] DLUHC, NPPF, July 2021. The 30-year horizon was a response to issues raised in my blog on the failure of several new settlements in North Essex

[11] Sites under construction, benefiting from permission, subject to advanced applications or otherwise supported by clear evidence of near-term delivery.

[12] That is before taking into account the time beforehand preparing an application or the time afterwards discharging conditions, securing detailed approvals and resolving technical matters.

[13] NPPF, Annex B, defines a ‘Strategic site’ as “typically… at least 1,500 dwellings” for residential-led

development

[14] Larger sites' planning and pre-commencement periods extend well beyond five years from first application.

[15] Policy HO4 states that Local plans should “where appropriate, identify suitable locations for strategic sites for housing-led development (such as new settlements, new urban quarters or significant extensions to existing settlements).”

[16] At risk of falling into the trap that befell Alanis Morrisette

[17] Exhibit A being the infamous Caroline Spelman letter

[18] The test of effectiveness for SDS (PM14) is “and there is a reasonable prospect that local plans will be capable of identifying site allocations to implement its spatial strategy. Where spatial development strategies anticipate a change in market conditions which the strategy itself is intended to foster, a proportionate approach should be taken in assessing assumptions for the longer term, given the uncertainty which is likely to surround them.” For Local plans (PM15) it is: “the plan sets out effective policies for development, and there is a reasonable prospect that its site allocations are capable of being deliverable at the time envisioned.”

[19] See for example, the 2016 report of the Local plans Expert Group, to which the author of this blog was an inconsequential contributor

[20] As explained in this MHCLG Blog from December 2025. The NPPF policy statement says the reform will: “make development management more certain, consistent and streamlined; standardise policies that apply across the whole of England; reduce duplication and avoid unjustified local deviation from national policy in local plans.”

[21] The housing trajectory in the recently adopted Winchester local plan is an exemplar of this pattern – see page 220.

[22] Reflecting optimism bias in the assessment of sites; most developable sites are expected by their promoters (and the LPA) to come forward at the earliest opportunity. See this article in Nature – previously cited in my blog on land value capture. Its review of behavioural research on real‑estate investment finds that developers are subject to persistent optimism bias, overconfidence, anchoring and confirmation bias, leading them to overestimate their own ability to deliver while underestimating costs, risks and constraints. See also the analysis by Homes England on Optimism Bias

[23] Letter from Minister of State to PINS 10^th July 2026

[24] Sites in local plans are required to be deliverable or developable and where expected to contribute in years 6–10 “with a reasonable prospect that they will be available and could be viably developed at the point envisaged”. Decisive decisions over investment need to be made much earlier: land and infrastructure agreements, preparation of applications, utility commitments and funding decisions will likely need to be made in years 1–5. The shorter the plan horizon, the less room there is for a presently marginal but strategically important site to become deliverable by the time its contribution is required. A ten-year plan period does not give a site ten years for viability to recover.

[25] For example: The ten year period doesn’t stop local plans looking beyond ten years and they can – as now – allocate sites beyond the plan period. The NPPF has new encouragement to identify strategic sites of 1,500+ homes. If an SDS looking 25 years ahead identifies a broad location for long term growth in a plan area, then a local plan ought to have policies to facilitate it. Replacement local plans must commence within five years and new plan making intends them to be done quickly. It might be said that what a little plan doesn’t plan for this time, its rapidly produced successor can pick up next time round.

Catchment-22: The education planning paradox nobody is talking about

Robert Curtis-Haigh & Emma Hepplewhite 24 Aug 2026

England is facing a catch-22 within education planning: pupil numbers are falling sharply across the country, yet new places funded by housing development increase at pace.

This blog explores why this contradiction is emerging, what it means for the school network, and how planning can help respond.

Why pupil numbers are falling

Total fertility rates have been on a downward trajectory for several decades, reaching record lows in recent years[1]. These trends have a direct impact on school rolls. We saw how the temporary rise in births in the mid-2000s and early 2010s (coined the ‘mini baby boom’) created a short-lived ‘bulge’ in primary-age pupils. However, with the number of births falling since 2013, that bulge has now passed through the system and, with no equivalent cohort replacing it, the population attending primary school peaked in 2019, secondary school populations peaked in 2024/25, and recent projections suggest that the number of children in special educational needs (SEN) schools will peak in 2027/28[2].

Colleagues set out the early signals of this shift in London in their blog in late 2024 and, consistent with London often acting as a bellwether for wider demographic change, similar patterns are now emerging nationwide.

What the national pipeline shows

National pupil projections published last month confirm that pupil numbers are continuing to fall, with an estimated drop of 473,000 nursery and primary pupils and 249,000 secondary pupils by 2030[3]. This aligns with recently published regional forecasts[4], which show that seven out of nine regions are expected to see a reduction in total pupil numbers over the same period. At the same time, the number of new school places funded through the Housing Developer Contributions (HDC) mechanism rises.

Projections of Pupils and HDC Funded Places across all nine regions between 2025-2030

Source: DFE, Lichfields Analysis

Across the regions, London experiences the most pronounced pupil decline, with the North East, North West, Yorkshire and The Humber, South East and South West also seeing steady downward trends.

It is notable that, in last year’s projections, the East of England, East Midlands and West Midlands were expected to experience sustained growth in pupil numbers, a trend that appeared to reflect a combination of London out-migration and international net migration[5]. However, the latest projections suggest this uplift is beginning to weaken, with pupil numbers in the West Midlands and East of England expected to peak in 2026/27 before declining, while growth in the East Midlands is starting to level off. This is particularly significant given that the latest national projections identify the recent 50% fall in long-term net migration as a key factor behind lower pupil forecasts[6], suggesting that migration-driven growth may prove more temporary than previously anticipated.

Taken together, the data shows a clear disconnect between demographic projections and planned education provision. Pupil numbers are declining across most of England, yet investment in new school places through Housing Developer Contributions (HDC) continues to grow. But if this isn’t driven by demographic need, what is it driven by?

The influence of housing delivery

Across England, local authorities are bringing forward significant numbers of large, strategic housing allocations to respond to the UK government’s target to tackle the housing crisis through the delivery of 1.5m homes by 2029[7]. While the location of these sites varies, a prominent number comprise edge of settlement locations (often referred to as ‘urban extensions’), where land availability makes large-scale delivery easier.

At these strategic sites, local authorities generate a pupil yield based on the size of homes provided. A proportion of these children will be of primary school age, and local policy generally requires that primary-aged pupils can access a school within a walkable distance. In many cases, the nearest existing schools (even where they have spare capacity) are either too far away or not safely accessible on foot. As a result, developers are required to help fund new provision through the Housing Developer Contributions (HDC) mechanism.

The effect of this is visible everywhere in the national dataset. Despite pupil numbers falling in every region, HDC-funded places are set to increase steadily in all nine English regions, including the ones with the steepest demographic decline (for example, the North East is seeing pupil numbers fall by 2.9% while HDC funded places grow 300%).

How might this impact the school network?

Creating new school places in anticipation of emerging communities is not always an issue. For example, the government’s proposed ‘New Towns’, projected to deliver a minimum of 10,000 homes each[8], will undoubtedly need to deliver new schools to accommodate such a vast pupil yield. There are also strong opportunities here to plan well in advance to ensure that schools remain centrally located and easily accessible for residents from the outset. The challenge lies in how new provision interacts with the existing school network.

One such challenge relates to the long-term sustainability of new schools that are heavily reliant on the pupil yield generated by a single development or growth area. While the risk might not be present early on as rolls are filled by pent-up demand and the first phases of occupation, there is risk further into the future once those pupils have moved through the system. At that point, the school’s reliance on a relatively localised catchment makes it more vulnerable to ageing population and the wider housing lifecycle, and with limited pupils in surrounding areas to draw from, they can potentially become under-occupied over the longer term.

Conversely, as a large proportion of new family housing is now delivered on edge of settlement sites, the new schools in these locations can capture a large proportion of the settlement’s incoming pupils. This creates the risk that existing schools (which typically serve established villages and neighbourhoods with fewer young families and limited housing turnover) no longer receive the intake that has historically sustained their rolls. This reduction in demand can make them increasingly vulnerable to reduced admissions which lead to reduced funding and, in turn, potential closure. We are already seeing early signs of this emerging across authorities in the North East, and colleagues will be able to report similar pressures elsewhere in the country.

Rethinking how we plan school places

Newly appointed Prime Minister Andy Burnham has called for a "complete rethink" of how young people are supported through the education system. While the detail of any reforms remain to be seen, the challenges outlined in this blog suggest that school place planning may be one area in need of such a rethink. We have identified the following key opportunities:

Recognise that housing growth can be used to support existing schools: Housing growth should be viewed as part of the solution to falling school rolls. Supporting new family housing in settlements with underutilised school capacity, including many villages and smaller towns, can help sustain pupil numbers and support local facilities.
Make better use of existing school capacity: Councils should explore how the capacity of existing schools can be used before considering new provision. For instance, some mainstream schools have successfully introduced Special Educational Needs and Disabilities (SEND) units to respond to rising demand while reducing the need for separate new‑build facilities. This is a more sustainable solution to building new SEND schools when considering that SEN pupil forecasts are also set to drop later this decade. Equally, the Department for Education’s School Rebuilding Programme already delivers new and replacement schools, usually on a like-for-like basis in terms of pupil roll, and could be applied more flexibly.
Improve access to existing schools: Leverage S106/HDC funding for walking/cycling routes, crossings and improved bus routes to unlock existing capacity for those in edge of centre locations. This would complement wider sustainable travel objectives.
Assess net pupil demand at a system level, not site level: Replace site-based pupil yield formulas and focus on assessing net additional demand across the network. This should consider existing school capacity, active travel opportunities and longer-term demographic trends, while recognising that not every child living in a new development generates demand for an additional school place, particularly where households are relocating within the same local area and children continue to attend their existing schools.
Ensure new schools are justified by demonstrable need: New schools should be provided where assessments show that existing capacity and accessibility improvements cannot accommodate projected demand.

Closing thoughts

The current trajectory is concerning, and we need to seriously consider whether the school network we’re planning now will still make sense over the long term.

Housebuilding will play a vital role in boosting pupil yield, but we need to ensure that growth is supported in the right locations so it supports existing capacity and only delivers new schools where they’re genuinely needed.