Planning matters

In his blog at the beginning of the year on the potential changes for retail and town centre planning on the horizon from the draft 2025 NPPF consultation[1], my colleague James Cox referenced “… the way we use, experience and value our town centres has changed fundamentally”.

This got us thinking about the data behind town centres, and the wider narrative of ‘the death of the high street’ that has grown around the data to forecast the health of a centre (or otherwise).

 

From the early 1980s through to the mid‑2000s, the phrase ‘death of the high street’ barely registered, appearing only in small, irregular spikes[2]. Usage began to rise steadily after 2010 (likely coinciding with a wave of closures following the 2008 financial crisis[3]), before accelerating sharply from around 2017. By the early 2020s, it had reached its highest level on record. 

The idea has well and truly taken on a life of its own, well beyond planning circles.

In fact, the phrase has become so culturally embedded that it has even been adopted as the name of an indie punk band from the Midlands…

 

But whilst the narrative of the “death” of the high street is both recent and populist, it has grown precisely as town centres have been challenged to diversify, in most cases as a response to the structural and economic changes in retail. So, what does the data actually show when we look at the evolving mix of uses on the high street?

There are different ways of approaching this subject, one of which is to look at the total quantum of floorspace and how this has changed over time. Experian data suggests that all retail floorspace totalled 626 million sq ft in 2015 (58 million sq m), which rose to 641 million sq ft (60 million sq m) in 2024, the last full year in which total floorspace figures are available.

Of this, convenience goods[4] floorspace has grown from 153 million sq ft in 2015 (14 million sq m) to 176 million sq ft (16 million sq m) in 2024, whilst comparison goods[5] floorspace has fallen from 472 million sq ft in 2015 (44 million sq m) to 466 million sq ft (43 million sq m) in 2024.

 

However, the broad quantum of floorspace can only tell so much and is potentially tied to larger macro-economic factors that will influence the amount a population is willing to spend, particularly for comparison goods retailing.

We are, of course, not the first to broach this topic. It is interesting to note academic[6] analysis of five UK cities that suggested a greater level of diversity of uses as the proportion of comparison goods retailing fell between 2000 and 2017, with notable variations across the centres.

National average data from Experian[7] allows us to track changes across the mix and composition of town centre uses since 2015, shown in the graph below. This is, of course, a 'zoomed out' view of town centres over the time, and a notable caveat to the following analysis of national averages is that there have undoubtedly been centres that have experience more drastic changes over the last few years (both for the better, and for the worse). Ultimately, not all locations, regions or types of centres will have fared the same. There is, however, merit in taking a closer look at the headline changes and what this means for how we talk about town centres as an industry.

Rather than wholesale disruption, the data shows a far more balanced series of small adjustments that point to a gradual rebalancing of town centre economies. 

The clearest trend is the decline of comparison goods retail, dropping from around 36% in 2015 to just under 30% today. There is no single reason for this, which is likely to have resulted from a combination of structural pressures including:

 

• changes in disposable income
• disruptions to the visitor economy, which will have recovered at different rates across the regions following COVID-19
• growing economic pressures from both rents and business rates on retailers with larger portfolios, contributing to a number of high-profile closures (Debenhams, Arcadia, BHS etc.)
• increases in online spending
• complications and rising costs across storage, transportation, and logistics networks
• competing pressures from larger regional centres and retail parks

However disruptive the loss of large comparison goods retailers may be for individual town centres, the data suggests that this decline is not sudden or chaotic. It is a gentle reduction of less than one percentage point per year and, importantly, these vacancies have generally been filled with alternative uses.

 

In contrast to comparison retailers, other uses have however shown consistent increases:

 

• Restaurants and cafés have grown modestly since 2015, supporting their role as a key draw of social activity across town centres.
   
• Pubs and bars have remained remarkably stable and the proportion has even grown slightly, countering another common narrative about the loss of pubs. However, we would note that the Experian data covers around 3,000 centres and does not include isolated or out-of-centre facilities where the majority of closures[8] may have occurred.
   
• Fast and hot food takeaways in centres have effectively plateaued at just over 6%.
   
• Convenience retail has grown steadily from 8% to 10%, highlighting its ongoing resilience.
   
• Other non‑retail services have grown from 12% to 16%, making them one of the strongest upward trends, driven by a consistent surge of health and beauty openings.
   
• Financial and professional services are the only other category of uses to have shown a consistent decline across centres from 12% to less than 8% over the last decade. This is an example of a broader narrative that does hold true, with last years’ House of Lords Library briefing clearly setting out the key considerations. Hope, however, is on the horizon with the growth of banking hubs[9] providing an innovative model for communities that are no longer able to support multiple dedicated banking branches.

Together, these patterns illustrate a shift towards town centres as social and service hubs, not purely shopping destinations. Places to spend time, meet and socialise, rather than a sole raison d’être to shop.

 

Perhaps the most interesting aspect of the data is the relative stability of vacancies. Despite COVID‑19 and the associated social lockdowns, disruptions to global supply chains, macro-economic uncertainty, the introduction of Class E, and a decade of media stories about widespread closures, vacancies have only moved within a narrow band of about 12-15%, broadly plateauing since 2020. 

Of course, the experience of individual centres may vary across regions and different types of centres reflecting their mix and composition, reliance on specific anchor tenants, and the resilience of their local catchment to wider economic shocks. To a certain extent, the national average somewhat disguises the winners and losers with higher performing centres potentially propping up those that are struggling (maybe the topic for another blog).

Nonetheless, the data suggests that many centres have adjusted effectively to the reduction in comparison goods retailers. This challenges one of the most persistent myths of the high street, that vacancies are spiralling out of control. In reality, there is no sign of the dramatic vacancy spike that dominates media narratives.

 

Now, for a moment of personal reflection. I was one of the chorus of planners aghast at the chutzpah (look it up) of the Government driving a horse and cart through decades of carefully crafted retail and town centre policy with the introduction of Use Class E. 

Surely, we thought as one, this would mean the end of Local Planning Authorities’ ability to control the mix of uses in their centres, inevitably leading to the widespread loss of town centre retail stores to bubble tea cafes, and the mass conversion of out-of-centre office blocks with dedicated car parking to multi-storey supermarkets.

To my credit, the introduction of Class E in 2020 does mark the only point in the last decade where the proportion of main town centre uses shift at once. Frustratingly, from a data analysis perspective, this coincides with the introduction of nationwide social lockdowns, which somewhat muddies the water.

And what did we see? The proportion of services ticked up (0.8 percentage points), as did vacancies (2.5). The number of retailers fell at a slightly greater rate (-3.6 points from 2020-2026, compared to -2.7 points over 2015-2020), and hospitality uses began a pattern of gentle growth (2.5). But even here the change is an evolution, not a revolution. The world did not end, and all these trends were largely already in play.

Town centres may not therefore be dying, but potentially evolving to market, structural and social changes. Retail is still central to town centres with convenience and comparison retails collectively making up around 38% of units, albeit this has fallen from 44% a decade ago. As the proportion of comparison retail stores and financial and professional services across centres has fallen, non-retail services and hospitality uses are quietly and sustainably filling the gaps.

Whilst you can always find examples at the extremes of the average, and this is certainly an area for further research given the broad nature of the analysis[10], the national average data over the last decade tells a story of subtle shifts and places adapting at their own pace.

For planners, the task ahead is not to panic and not to rush to reinvent town centres in response to perceived trends, but to work with the market to refine centres. Given the incremental nature of change, our priorities should focus on managing transitions, shaping the balance of uses across centres, improving the overarching town centre environment, and supporting the underlying social and economic role of town centres.

The Planning and Infrastructure Act 2025[1] (the Act) has introduced a proposed system for environmental mitigation, via pooled funds, as an alternative to mitigating via s106 agreements, in England. 

Part 3 of the Act ‘Development and Nature Recovery’ provides for Environmental Delivery Plans (EDPs), which are a new strategy central to this proposed model.

An EDP will establish a mechanism for addressing specified environmental impacts through coordinated mitigation, which will be orchestrated through a Nature Restoration Fund (NRF) created by a Nature Restoration Levy (NRL).

The primary legislation for EDPs has been introduced by the Government to provide an alternative to site-specific environmental mitigation, usually secured by a s106 agreement. EDPs are intended to create a route to mitigating a defined set of potential area-based environmental impacts. The first set of EDPs are to focus on nutrient pollution, with preparation of a subsequent set of EDPs concerning great crested newts also in progress, as described below. EDPs will be introduced with the intention of improving the efficiency and certainty of making planning contributions towards mitigation of impacts on these matters.

The Act also provides that certain statutorily required project-level assessments or procedures do need to be carried out where impacts fall with the scope of an EDP, as also discussed in this blog. The levy-based approach introduces new considerations in relation to governance, delivery, funding and risk.

We set out below some of the key principles of this new approach to mitigation, including what is set out in the primary legislation and what has been announced in terms of likely detail. After setting out the context we look at:

The Planning and Infrastructure Act 2025 seeks to streamline housing and infrastructure delivery. Part 3 of the Act introduced a new statutory framework for Environmental Delivery Plans (EDPs) and the associated Nature Restoration Fund (NRF) and Nature Restoration Levy (NRL) as mechanisms to streamline environmental mitigation within the planning system[2]. 

Environmental Delivery Plan (EDPs) are frameworks prepared by Natural England to manage environmental impacts of development on protected habitats or species, having regard to the development plan, the current environmental improvement plan, any Environment Act strategies, and any other strategies or plans consider relevant.

The Nature Restoration Fund (NRF) is a capital fund designed to deliver large-scale projects designed  mitigate impacts on environmental features, caused by development.

The Nature Restoration Levy (NRL) allows developers to pay in to the NRF instead of delivering site-specific environmental mitigation. It creates the NRF.

Subject to Regulations, the Act has authorised Natural England to prepare EDPs for defined geographic areas and classes of development, in order to deliver conservation measures aimed at addressing specific environmental pressures and setting a corresponding levy payable by developers to fund those measures.

EDPs will cover specific environmental features and comprise area-based strategies which will be outlined by a map of the development area. Participation and the choice to take forward an EDP lies with the developer, who is able to decide if it is most appropriate for its circumstances.  If the developer decides to proceed with the EDP, they will pay the levy in lieu of undertaking project-specific mitigation and cash in lieu payments. The amount paid will be determined with reference, for example to the kind of development and the scale of potential impact of the development.

The EDP will outline the maximum amount of the development the plan accounts for, which may include the area covered by the development, the maximum floorspace, the number of units or buildings, the expected values and for Nationally Significant Infrastructure Projects, any measurement of scale of the project. 

 

In practice, EDPs are intended to reallocate responsibility for environmental mitigation from individual schemes to an area-wide delivery model. Once EDPs are published by Natural England, the required mitigation measures are specified and implemented centrally, and delivery will be funded by the NRF.

Natural England will be able to prepare the EDPs for various environmental issues using best available scientific evidence and informed by a 28-day consultation period with the public and relevant bodies. All EDPs will include[3]:

• Definition of the environmental feature
• Environmental impacts of development
• The scale and type of development the EDP can support
• Clear maps to set out the area covered by the EDP
• Conservation measures to be deployed to address the impact of development
• A charging schedule that will include costs of the conservation measures, per scheme and mitigation type

The Secretary of State will then consider the EDP and if the conservation measures will correctly mitigate the detrimental effects of development on the conservation status of the environmental feature(s) concerned. Not only must the EDP mitigate the detrimental impacts but the Secretary of State must also be satisfied that the EDP passes the Overall Improvement Test which is designed to secure a net benefit to the environmental feature concerned. The Act stipulates[4]:

Following this, the Secretary of State will approve the EDP, and it will then come into effect. Natural England will then continue to report on the EDP until its endpoint.

Local planning authorities and other public authorities have a duty of co-operation with Natural England to give it such reasonable assistance as it requests in connection with the preparation and implementation of an EDP.  Such things that a public authority may be required to do include:

• provision of information to Natural England;
• the imposition or variation of a condition of development;
• assistance with the implementation of conservation measures.

In some cases, conservation measure maintenance will need to continue beyond the EDP’s end date, and monitoring may remain in place. Only the Secretary of State can amend the EDP once approved, and a statement would be published in this regard.

EDPs should in turn provide a legally based evidential basis on which to conclude that specific environmental effects will be appropriately addressed, enabling reliance on the plan’s mitigation strategy when determining applications.

Most EDPs are expected to be voluntary and will set out a programme of conservation measures, typically covering up to a maximum of 10 years. They must be based on the best available scientific evidence and can only be used where the measures are capable of meeting the statutory Overall Improvement Test, delivering an overall improvement in the conservation status of the environmental feature concerned.

Where an EDP identifies a protected species, it must set out the terms of the licence that will be treated as having been granted. Under Section 63 the Act, an EDP must specify the terms that are to be treated as included in licences under:

• regulation 55 of the Habitats Regulations 2017;
• section 16 of the Wildlife and Countryside Act 1981; and
• section 10 of the Protection of Badgers Act 1992,

that may be granted to Natural England to facilitate the carrying out of any conservation measures.

As provided by and Schedule 3 of the Act[5], where a development type falls within the scope of an approved EDP and the developer commits to pay the levy, the effects on the environmental features covered by the plan are to be disregarded and therefore addressed through that framework. In those circumstances, separate project-by-project assessment or individual species licences are not required for impacts fully dealt with by the EDP. Instead, the relevant licensing provisions are treated as having been granted, or are granted to Natural England, in line with the terms set out in the plan.

Essentially, Schedule 3 of the Act expressly disapplies the need for a habitats assessment or species licence in certain circumstances where an EDP is in place.

The Habitats Regulations 2017, the Wildlife and Countryside Act 1981 and the Protection of Badgers Act 1992 will continue to apply where:

• no EDP is in place;
• a developer chooses not to use an EDP;
• impacts fall outside the scope of an EDP; or
• the site includes irreplaceable habitats or other features not suitable for the EDP framework.

In those cases, the usual assessment and licensing requirements remain in force.

EDPs will be geographically targeted, aligned with wider strategies such as Local Nature Recovery Strategies, and designed to secure strategic, measurable environmental improvement over time.

Impacts not expressly included within the EDP will remain subject to the assessments/licensing legally required, and LPAs must still be satisfied that the development does not give rise to unmitigated effects outside the EDP’s parameters.

Once implemented, Natural England are required to publish annual reports, and EDP specific reports will be published at the mid-point and end-point of the EDP. 

 

In 'Implementing the Nature Restoration Fund'[6] the Government says “the first EDPs will cover developers’ obligations related to nutrient neutrality”. It goes on to explain the catchment areas being prioritised for an EDP where Natural England is “currently exploring the benefits of developing EDPs” and due to “significant pressure from development”. 

The efficient addressing of potential nutrient neutrality impacts has been an ongoing concern for housebuilders in particular, previously discussed by Lichfields, here.

The catchments are shown on the map below and listed here, with reference to the type of nutrient pollution

EDPs for great crested newts are also being explored “for development (including infrastructure) in England where GCN are materially present”, according to Natural England. The preparatory work for these EDPs is to utilise District Level Licensing (DLL), with a view to transferring “the strategic approach taken under DLL” into the NRF. The EDP areas for great crested newts are very broad at present and listed here.

Natural England is required to notify the Government of its intention to prepare EDPs and has done so for 23 potential EDPs; 16 for nutrient neutrality and 7 for great crested newts[7], notwithstanding that the secondary legislation required to operate the system has not yet been laid (see below).

In its notification, Natural England said that the first EDPs to be consulted on and submitted as final draft EDPs will relate to nutrient pollution only. While it is preparing “a number of EDPs in parallel", Natural England confirms that it has noted “that the Government has committed to not making any EDPs beyond nutrient pollution before making a statement to Parliament setting out the initial learnings from the development and implementation of the first EDPs. This will allow for a test and learn approach to be taken” (see also this written answer).

 

The Government has said that once EDPs are published, developers will be able to use an online platform to obtain an estimate of the levy they will need to pay if they use an EDP for the site. Section 75(1) stipulates that the levy required by developers should not make the site unviable. 

For developers, a key consideration is that EDPs are optional alternatives rather than an automatic requirement. Where a proposal falls within the scope of an adopted EDP, the applicant may elect to rely on the EDP for the covered issues, triggering payment of the Nature Restoration Levy at the points set out in the EDP, replacing the need for equivalent S106 obligations (whether financial or physical). The levy can be paid for in instalments if agreed prior to the approval of the EDP. The levy will then deliver mitigation projects at a scale intended to address cumulative impacts more effectively than dispersed, site-level measures. Once the application is approved, developers can rely on the EDP in place of habitats assessment and/or species licence that would otherwise be required for the environmental feature included in the EDP.

The table below compares the EDP and NRF route with negotiating contributions made by s106 agreement, for the same impacts, ahead of Regulations providing further details:

Developers should be mindful of whether their site sits within the geographical extent of adopted EDPs as and when they are published, and if the anticipated impacts of their scheme are among the issues expressly covered. Where impacts fall outside the defined scope, the current project-level assessments legally required (e.g. Habitat Regulations Assessment) and the mitigation identified as part of that assessment process, will still be required, potentially alongside EDP participation.

The process for putting an EDP in place, and the process for setting and charging the NRL is similar to the process for putting in place a Community Infrastructure Levy charging schedule. Indeed, in its Memorandum to Delegated Powers and Regulatory Reform Committee (on moving to the House of Lords), the Ministry of Housing, Communities and Local Government said[8]:

EDPs must be consulted upon, therefore early appraisal of the Nature Restoration Levy is essential. Levy liability should be modelled against the cost, timing and risk profile of delivering mitigation through S106 obligations or conditions, particularly where hybrid approaches may be required. Developers should also anticipate that mitigation projects will be delivered through the Nature Restoration Fund, making transparency around levy calculation, spend assumptions and delivery timescales a key consideration. Developers should be aware that project viability is a consideration in setting levy rates and payment triggers and therefore should discuss options with the LPA early if this is an issue likely to arise in the development process.

EDPS may be amended on request of Natural England or by the Secretary of State, however the EDP cannot be amended so that it no longer applies to a development in which the developer has agreed to pay the NRL. If an EDP is amended, it will go through the consultation process again.

EDPs may not capture all relevant environmental receptors or pathways. Developers should expect planning permissions to retain fallback conditions or S106 clauses where impacts sit partially or wholly outside the EDP’s scope.

Clarity around monitoring, reporting and adaptive management arrangements is essential, particularly where environmental outcomes are dependent on longer-term delivery of strategic mitigation projects.

  

Part 3 of the Act is in force, with the exception of one section (s91, which requires annual reporting by Natural England on all EDPs in force). This means that the Government is able to draft the necessary Regulations and it has indicated that it is doing so:

'Implementing the Nature Restoration Fund' sets out the Government and Natural England’s intended implementation timescales, including for secondary legislation:

Since its first publication in 2012, the National Planning Policy Framework (NPPF) has encouraged local authorities to establish the need, size, type and tenure of housing for different groups, including older people. As set out in Martin Taylor’s blog, the 2025 NPPF consultation (16 December 2025[1]) does not waver from this core principle, which seeks to secure a diverse mix of homes to meet the needs of different groups through the planning system.

Despite this longstanding approach, Lichfields’ Solutions to Age Old Problem Insight identified both in 2019 and the 2024 update that whilst many local plan policies refer in general terms to the needs of older people, few set out a specific requirement for the level of older person’s housing that could be provided or contain allocations for the development of such accommodation. Similarly, only a few local authorities have tended to monitor the delivery of specialist housing for older people. As of 2019, just 14% of development plans in England had policies that identified a requirement for housing for older people and just 8% of English development plans included allocations for housing for older people. The 2024 update showed an improvement in identified specialist housing requirements within development plans to 48% but the number of plans with allocations for specialist housing remained largely static at 9%. 

The ageing population has been a longstanding and significant contributor to household growth. The 2022-based Household Projections shows that the number of over-65 households in England is anticipated to grow by over 3 million between 2022 and 2047, equivalent to 57% of all household growth over this period.

Importantly, older people generally live in smaller households (single or couples) so the housing implications of the population increase will be disproportionately significant. The provision of specialist accommodation for older people can provide social and economic benefits by increasing social interaction, providing safety and security, and helping to meet care needs, whilst also helping to free up general needs housing. It therefore represents an important part of the puzzle to solving the housing crisis.   

This blog considers whether the suite of new Plan-making and Decision-Making Policies within Section 6 of the draft NPPF will require local authorities to properly plan for older person’s housing and, in turn, deliver the step-change in delivery that is required to meet needs. 

There are four key policies within the draft NPPF which consider housing for older people; three of these are plan-making policies which seek to provide greater clarity to local planning authorities over what is expected at the plan-making stage. The fourth is a National Decision-Making Policy (NDMP) which should be used by local planning authorities in the determination of planning applications. 

The draft policies are not substantially different to the current approach within the NPPF, but the restructuring helps provide greater clarity for plan-making and decision-taking. 

 

Draft Plan-making policy HO1 “Assessing the Need for Homes” largely reflects the approach set out in paragraph 63 of the current NPPF (2024), which requires development plans to assess the size, type and tenure of housing or other accommodation to meet the needs of different groups, including older people. 

Whilst the overall number of homes needed is to be addressed through Spatial Development Strategies (SDSs) (part 1 of HO1), part 2 of Policy HO1 states that size, type and tenure requirements should be determined “at the most appropriate level”. This will allow plan-making authorities to adjust their policies to encourage a particular housing mix to respond to local needs. Taking the West of England SDS authorities as an example, it would seem inappropriate for the same approach to be taken to older person’s housing delivery in Bristol, where less than 13% of people are aged over 65, and North Somerset, where almost a quarter of residents (23.9%) are aged 65 or over.

This element of flexibility within Policy HO1 is welcomed but care must be taken to ensure that planning for specialist forms of accommodation does not ‘fall through the cracks’ with the SDS deferring to the local plan and then for local authorities to fail to pick up the mantle.

As recommended in Lichfields’ Insight, clear guidance will need to be published on how housing for older people is calculated when assessing local housing need, with the current 2019 guidance pre-dating the standard method. 

It is important to note that the standard method identifies a minimum housing annual need figure for residential in Use Class C3 and therefore an assessment of need for any older person’s housing falling within Use Class C2, such as care homes, should be in addition to the standard method figure.

It will be important for site promoters and developers to evidence the need for development at both SDS and local plan preparation and examination and make the case for care, retirement and sheltered housing. Lichfields’ Carepacity product can provide up-to-date evidence to assess the need for housing for older people. This will ensure that local authorities prepare development plan policies and identify suitable allocations that are robust in accordance with draft policy HO1. 

 

The draft NPPF’s Plan-making policies HO4 “Land for large scale residential and mixed-use development” and HO5 “Meeting the needs of different groups” both set out specific requirements to identify sites or parts of sites capable of supporting delivery of housing for specific groups, such as older people. 

This is a positive step as it arguably provides the greatest certainty of delivery, ensuring that there are clear expectations for the land use on a given site. The delivery of older person’s housing should be embedded into the allocation policies for large-scale residential sites and this will ensure that development is located in the most sustainable and suitable locations for older person’s housing. Given the low proportion of local plans that currently contain such allocations, this policy could present a step-change in the identification of sites appropriate for older person’s housing.

Policies HO4 and HO5 both set out that policies for a mix of tenures, and therefore consideration of specialist forms of housing, need to be provided on sites for 150 homes or more. Reflecting the housing needs for older people within strategic allocations is important for a number of reasons, including that strategic allocations offer the economies of scale which can often support a mix of different housing types (which might not be viable elsewhere) and thereby contribute to more diverse and sustainable local communities.

However, given the prevalence of viability issues within the residential sector and potential complexities of delivering specialist forms of accommodation alongside general market and affordable housing, the 150-home threshold is unlikely to be appropriate as a national benchmark. Instead, it should be set at a local level to reflect local circumstances and the outcomes of plan-making authorities’ viability assessments to inform local plan preparation. 

 

Policy HO9 is a new NDMP which would provide greater clarity on requirements for different specialist forms of accommodation, including older person’s housing. The draft Policy HO9 part 1a) sets out two key aspects for housing for older people:

• Part i requires a sustainable location with access to frequently used services via sustainable transport; and,
• Part ii requires delivery of housing to M4(2) or M4(3) accessibility standards. 

It should be noted that within the supporting text to the consultation, the government proposes a national minimum target of 40% of new housing over the course of the Plan period to be delivered to M4(2) standards (Policy HO5). It should be confirmed whether this minimum applies to the local authority need or at site level. Once confirmed, this should be explicit within wording of Policy HO9 or deferred to plan-making authorities to determine an appropriate level based on local requirements. 

Policy HO9 part 1b) also provides helpful guidance which will be of relevance to developers of older person’s housing. It suggests that “specialist community-based accommodation”, which could include Integrated Retirement Communities, should be supported by a management plan which will provide a “safe and secure environment for residents”. Whilst there is merit in securing the safety of residents, there is a lack of clarity on how this is would be assessed at application stage and what criteria might need to be met. Specialist community-based accommodation is not defined within the draft NPPF and some clarity on this would be helpful.

As a non-statutory NDMP, Policy HO9 would act as guidance and must be read alongside any policies of the adopted development plan, which would be the basis for decision-making[2] . The consultation asks whether NDMPs could be introduced as statutory in “the most effective manner”, so it will be important to monitor this and other NDMPs going forward.

 

The NPPF consultation takes positive steps to address the lack of clear policy direction at a national and local level for older person’s housing, however this does not feel like the significant change needed to considerably boost the supply of specialist accommodation for old people. 

It is vital that a positive policy landscape is shaped to address the significant needs of the older population and to help free up family housing. In the light of the new policy context, Carepacity will play an even greater role in supporting developers by providing evidence for a robust needs case when assessing housing need in accordance with draft policies HO1 and HO5.

Policies HO4 and HO5 encourage plan-making authorities to allocate sites for specialist forms of accommodation. Lichfields’ evidence shows this is severely lacking in adopted local plans and so that change in approach is welcomed. These policies will help to provide greater certainty of delivery and clearer expectations for the land use, type, mix and tenure on a given site.

The Government should implement Lichfields’ three recommendations to help boost the supply of older person's housing:

1. Planning Practice Guidance (PPG) “Housing for older and disabled people” was last updated in 2019. It is vital that this is revised alongside the publication the NPPF to provide clear guidance on how housing for older people should be considered when assessing housing need, making clear where it forms part of, and where needs are in addition to, the standard method.
    
2. Greater certainty of delivery should be provided by requiring plan-making authorities to allocate sites for specialist accommodation where there is an identified need. This should include updating PPG which currently states “It is up to the plan-making body to decide whether to allocate sites for specialist housing for older people”. 
    
3. The PPG should be updated to clarify how older people’s housing should be considered within CIL Charging Schedules and whether other obligations such as affordable housing should be sought.

Please get in touch if you would like to understand more about the draft NPPF and how the proposed changes could affect your residential developments, or if you would like assistance in preparing representations to the consultation.

The consultation closes to representations on 10 March 2026.

 

The Government has begun a consultation on the usability of the proposed consolidation of the Design and Placemaking Planning Practice Guidance (DPPPG). The draft DPPPG is intended to support the application of policies in the draft National Planning Policy Framework (NPPF) 2025, which is currently being consulted upon – see Lichfields blogs on this here.

 

It is not standard practice for MHCLG to consult on planning guidance updates; however, on this occasion the Government wants to “seek views on whether this consolidated approach improves usability and supports preparation of effective design and placemaking policies, tools and processes”. The consultation will last for 7 weeks from 21 January 2026 to 11:45pm on 10 March 2026.

 

Edward Clarke, Dominic Bowers and Matthew Spry’s blog here analyses how proposed NPPF policy L3 could unlock development potential equivalent to 632,600 homes on land at rail stations outside settlement boundaries. The blog also reminds us that whilst 632,600 homes might seem a lot, not all land will turn out to be available for development and there may be site-specific reasons that make development unfeasible in particular places.

 

In relation to density, 50 dwellings per hectare (dph) on the net developable area is the minimum density set in the proposed NPPF policy L3 for most scenarios[1]. The aim of building at increased densities to make better use of constrained land supply is not new and is promoted by the NPPF. However, this specific requirement raises questions about how sites coming forward would successfully achieve 50 dph, especially outside of urban areas and when site constraints come into play such as local context and character, Green Belt and landscape sensitivity. This blog therefore comments on how the draft DPPPG would support draft NPPF policy L3 in relation to achieving 50 dph.

 

 

Firstly, the draft DPPPG uses and amends a paragraph in the National Design Guide (2021) – see Table 1 Below showing new additions and amendments in bold to paragraph 59 of the National Design Guide in the draft DPPPG. The tone of this draft paragraph is perhaps more optimistic and supportive than the National Design Guide’s paragraph by emphasising that there can be benefits to reap when new development is “very different” to an existing place. The new references to “innovative” and “exceptional” development could show support for proposals that would respond to modern construction methods, changing 21st Century lifestyles and more sustainable ways of living; indeed, page 11 states that “new development can introduce elements that reflect how we live today, to include innovation or change such as increased densities and incorporate new sustainable features or systems”.

 

 

Secondly, reference to the appropriateness of scaling up the character of an existing place is removed presumably so as not restrict or hinder the manifestation of difference. The emergence of courtyard housing typologies is an example what departure from existing character might look like. Courtyard housing typologies create outward facing homes to animate streets and more private individual and communal gardens and courtyards to the rear. These typologies are popular amongst individuals, couples and families, especially because outdoor spaces and play spaces are conveniently nearby. There is a growing catalogue of exemplary medium density developments with innovative housing models that we should be looking at that feature modern townhouse typologies and reimagined mews house typologies – if you edit the filter to search for exemplary schemes at 50 dph on the Housing Design Award’s online catalogue[2] numerous entries appear…

 

Of course, difference is not always inappropriate or wrong and new development can draw influences on local character in numerous complementary ways such as through materiality, landscaping and local forms of architecture. Reference is also made to garden ‘towns’ instead of garden ‘villages’ in the draft DPPPG which appears to be a subtle shift towards supporting larger developments containing distinctive neighbourhoods with varying characters and densities to meet an average of 50 dph – Alkerden Gateway, part of Ebbsfleet Garden City, features as an example of this in the draft DPPPG.

 

Some view building at higher densities as a problem rather than an opportunity. Ultimately, higher densities can create popular, liveable and sustainable neighbourhoods that are well connected, walkable and contribute positively to wellbeing and placemaking. Indeed, Ebenezer Howard’s garden city movement in 1898 aimed to create communities at around 45 dph[3]. Successfully proposing higher densities requires a carefully coordinated and thought-out masterplan that has a strong vision and embeds placemaking principles – which is possible and should be the aim. A great example of this in the draft DPPPG is The Chocolate Quarter in Somerdale, Keynsham which includes up to 430 dwellings, a 60 bed care home, primary school, a local centre, community facilities and open space. Located approximately 50m from the Bath-Bristol railway line and Keynsham station, the scheme successfully shows how density is an output of good placemaking and responding to the site’s context to create a high quality garden neighbourhood. The site features six distinct character areas that vary in density to feature different housing typologies and there are a large number of terraced units with 36% of dwellings being flats. The lowest density areas are along the edges of the development to create a suitable transition with the open countryside – but overall – the scheme achieves a net density of 82 dph.

 

 

It is evident that optimising housing densities will remain central to meeting future housing and sustainability challenges. Turning to innovative and reimagined housing typologies should be promoted when considering density as we are seeing growing examples of how such an approach does not compromise the ability to successfully deliver community-oriented, sustainable, green, characterful and high-quality places that meet diverse housing needs.