Planning matters blog

A pedestrian renaissance for Oxford Street? Pulling the Mayoral Development Corporation lever

Alice Wibberley 07 Jan 2026

2026 is set to mark the beginning of Oxford Street’s potential transformation, with plans to pedestrianise part of Europe’s busiest shopping street passing a significant milestone last week - via the enactment of the Oxford Street Development Corporation (1st January 2026).

Against a backdrop of high national retail vacancy rates and a widely reported Boxing Day sales slump, this brings renewed faith in enhancing Oxford Street’s vitality through implementation of a decades-touted lifeline for the congested street. Although clearly one of the key shopping destinations in London, evidence that improving the pedestrian experience will generate more tourist and shopping trips is cause for optimism. If successful, pulling the Mayoral Development Corporation lever may broaden support for similar models within London to broaden the Capital’s growth agenda, and possibly set a benchmark outside of London for the enhancement of high streets.

Oxford Street Transformation – the proposals

The pedestrianisation of Oxford Street has its history in early traffic-free days between 2005 and 2012, with proposals to permanently expand the scheme to varying spatial extents gaining significant public backing in the subsequent years. This public support was consistently co-opted by several cohorts of Mayoral candidates, culminating in the 2016 election of Sadiq Khan, who consulted on the first concrete plans for implementation in 2017. Westminster City Council initially blocked the proposals before proposing a series of scaled-back schemes in 2021 and 2023 to placate resident backlash. The 2023 proposals included public realm improvements and pavement widening, but only proposed pedestrianising minor side streets.

The elections of 2024 created conditions for the revival of Oxford Street’s pedestrianisation as Mayor Sadiq Khan, re-elected, was able to draw on central government support to establish the Mayoral Development Corporation (MDC), which needed to be sanctioned by the Secretary of State.

Extensive consultation was completed, with engagement in May 2025 returning high levels of public support: 69% supported proposals to establish an MDC, and 66% were in support of pedestrianisation in principle. Westminster City Council expressed some reservations but is now working proactively with the MDC.

The established MDC is the Oxford Street Development Corporation (OSDC) which spatially covers Oxford Street and immediate surrounding side streets, extending from Marble Arch to St Giles Square, with a northern extension to Mortimer Street to the east. The OSDC is proposed to be chaired by Scott Parsons, and it will act as planning authority for the area, developing a new local plan and taking responsibility for planning decisions at all scales.

Oxford Street Development Corporation Boundary

Source: London Assembly

Pedestrianisation is at the core of the transformation, proposed (initially) along ‘Oxford Street West’ between Orchard Street and Great Portland Street. Traffic will be closed to all vehicles and cycles, bus routes will be diverted, and some north-south streets will be made one-way. Transport for London is consulting on highways proposals until 16th January.

Oxford Street: Challenges and Opportunities

The establishment of the OSDC lends certainty that action will follow, which is cause for optimism. Oxford Street has not been immune to economic pressures on England’s shopping streets, and it suffered a stalled recovery from the COVID-19 pandemic with vacancy rates climbing from 12.25% in 2017 to 14.5% in 2022. Visitor numbers remained stubbornly low, at 52% of the pre-pandemic levels by 2022, and the American candy shop scandal possibly marked the lowest point of the iconic street, prompting mournful predictions of its extinction. The quality of the pedestrian experience has also suffered, with media attention focusing on phone snatching amongst reports of overcrowding and pickpocketing. Calls for drastic action have only compounded, which may have cemented the creation of the OSDC, but this also gifts it a wide-ranging brief.

Recently there have been signs that Oxford Street is bouncing back. The arrival of Elizabeth Line stations has boosted demand for retail space, particularly at its eastern end. CoStar has reported an eight-year low in retail availability, and prime rents are also on the rise following drops of 30% in previous years. Footfall is however a mixed picture. Compared to historic levels, Oxford Street is lagging behind: in November 2024, it had only 57% of 2006 footfall levels, compared to 98% for Bond Street, and 83% on Regent Street. It still however boasts the highest footfall of any shopping street in Europe, and overcrowding of the street is evident to anyone who visits at peak times.

Evidence from the GLA suggests that high footfall has conversely limited expenditure by creating an environment inconducive to dwelling, browsing, and spending. Oxford Street is operating at capacity, and it is expected that creating a slower-paced environment will improve the footfall to expenditure conversion rate, as well as accommodating further footfall. The proposals have received strong support from the London Chamber of Commerce and Oxford Street operators, and GLA Economics estimates that pedestrianisation will increase the GVA by almost £82 million per year, supporting a further 781 jobs. Positive reporting from September 2025’s traffic-free day included 67% of stores reporting higher sales, alongside more than 75% of visitors having an improved experience of Oxford Street. Half of these respondents attributed this to increased pedestrian space.

Tools for Revitalisation

Increasing footfall and importantly, expenditure, to revitalise town centres can be achieved by turning a variety of dials, including diversification by office or residential development. Like many other shopping streets, Oxford Street is also burdened by a weighty stock of large units which carry risks of long refurbishment timescales and often require bespoke repurposing solutions. Topshop’s departure left a four-year vacancy before IKEA’s delayed opening, but Nike punctuated its two-year refurbishment of the flagship NikeTown by temporarily occupying the former Microsoft store at Oxford Circus. Both demonstrate the importance of adapting to a new retail climate, where experiential, showroom, and events-based enticements are of increasing importance.

For Oxford Street, pedestrianisation proposals can be complemented by diversification of activities to encourage longer dwell time. Nearby Outernet, an LED art installation opposite Tottenham Court Road station demonstrates the concept in action, and Oxford Street itself already benefits from a calendar of live performances within stores and pop-ups and emerging operator tactics to prolong visits such as John Lewis’ new member’s lounge.

London’s tourist numbers are beginning to recover from the pandemic, with the Capital attracting 20.9 million overnight visitors in 2024, close to the 21.7 million of 2019. Capturing tourist as well as Londoner interest will therefore be essential to Oxford Street’s future success. The last traffic-free day in September 2025 illustrated how live music, exhibits, and food stands could become regular fixtures post-pedestrianisation. By complementing its existing retail allure, continued diversification will help to maintain Londoner and tourist favour for Oxford Street, which may then foot the bill for its new infrastructure thanks to new tourist tax powers.

Mayoral Development Corporations

MDCs establish a statutory body for the delivery of regeneration schemes, often acting as planning authorities and benefitting from a ringfenced budget exempt from the usual pressures of Local Authority spending. MDCs can be established by Metropolitan Mayors across England and have been employed within a range of contexts; including its first use in 2011 at the Queen Elizabeth Olympic Park. More recently, MDCs have been used to deliver town centre improvements in Stockport and help re-industrialise the Tees Valley.

Not all existing DCs have received positive press coverage, with the Old Oak & Park Royal DC facing criticism for making slow progress, but the high-profile implementation at Oxford Street may help to encourage further uptake in other key town centres. As explored in Lichfield’s earlier blogs, this would also align with the Government’s ambitions for devolution, and may complement emerging regional initiatives such as the High Streets Commission or some of the more community-based solutions which have been put forward in the last 2 years, such as high street rental auctions. The evolution of MDCs may therefore represent another available tool in the renewal of politically-driven Mayoral and/or local entrepreneurial initiatives.

The success of the scheme may be further aided by Government pressure to evidence the efficacy of the DC model. Considering the New Towns Taskforce’s recent recommendation to revive Development Corporations for this purpose, securing public and political support for similar models will be essential to the Government’s growth ambitions, beyond the beacon that may be lit by an Oxford Street renaissance.

Conclusion

Once implemented, Oxford Street will join a venerable list of pedestrianised shopping streets, with the long-term success of Vienna’s Kärtner Strasse (pedestrianised 1974), Dublin’s Grafton Street (1982), Madrid’s Calle Preciados (1973) and Milan’s Corso Vittorio Emanuele II (mid-1980s) evident from their lofty positions in footfall rankings, embedded value to city economies, and consistent tourist appeal.

2026 signals the renewal of hope that Oxford Street will not fall victim to its popularity, with the creation of the OSDC bringing significant opportunities for renewal - beyond pedestrianisation. Following years of stymied schemes, the issue has been promoted to city-scale importance with central Government backing. It also positions a spotlight on the principle of the MDC, with any reputational fallout having implications for the delivery of broader Government growth ambitions.

Draft NPPF: Minimum Density, Maximum Impact?

Alan Hughes 05 Jan 2026

I’ve previously penned my thoughts on how tall buildings and greater density can help alleviate the housing crisis in an urban context, so one might think that I ought to be supportive of the Government’s proposed move to introduce minimum density standards. However, helpful they may seem, with a laudable intent, experience tells me that density standards do need to be treated with a degree of caution.

Density might be a dirty word in some NIMBY outposts, but it’s just a number at the end of a design process. Whether density is low, high, somewhere in the middle, good or bad, it is all relative and it shouldn’t really matter provided a site’s development potential has been optimised. To optimise development on a site naturally follows a robust assessment of its capacity taking into account development management considerations (such as heritage, townscape, daylight/sunlight), surrounding context and character and transport accessibility.

As far back as PPG3: Housing (2000) local planning authorities have been urged to avoid housing developments at low densities (below about 30 dwellings per hectare net) and to encourage housing that makes ‘more efficient’ use of urban land, including achieving 30–50 dwellings per hectare net on suitable sites. Twenty-five years on, here we are with a newly proposed NPPF advocating minimum densities of 40dph or a higher figure of 50dph around train stations. If we are serious about solving the housing crisis then perhaps we ought to be more aspirational, certainly on urban sites where there is clear potential to optimise density. The same approach to optimising density can be applied in other locational contexts, for example suburban or rural (including Green Belt), as we need to develop such land responsibly. There is, however, a need to acknowledge and respond to market indicators and evidence of housing need in a specific area – this inherently has an influence on development typology and therefore density. What we cannot risk is the NPPF approach to density culminating in half-measures that fail to make a dent in the housing emergency.

The consultation paper does elude to a wider debate on the issue, stating that “For development around well-connected stations, we are proposing a minimum density requirement of 50 dwellings per hectare within the net developable area of the site. We consider this will be sufficiently ambitious in some locations, particularly locations outside of settlements, and will act as the minimum requirement for other locations. For more urban locations, we would expect higher densities to be achieved, and are interested in how we could set clear expectations for more ambitious minimum density requirements in our urban cores – including how these locations should be defined. We also acknowledge that other public transport modes, beyond trains and trams, could support minimum residential density standards.”

In the Capital, the GLA has previously used a density matrix, first seen in 2004 London Plan. Originally known as the Sustainable Residential Quality Matrix, it was a tool that linked density targets to a site location and transport accessibility. Makes sense, right, but the matrix was often criticised for being inflexible (colleagues here raised such concerns ten years ago), and when it came to higher density schemes, it was used by objectors and some officers to seek moderations in height (as each range had a cap) which drove down housing numbers. It was subsequently discarded in the 2021 iteration.

Table 3.2, London Plan 2015

In place of the density matrix, the GLA adopted a design-led approach to site optimisation. Following a design-led approach often adds more subjectivity and negotiation into the pre-app process, but I would speculate that whilst there was already a growing trend for taller buildings coming forward in London each year (see NLA’s tall building survey data since 2014), the design-led approach results in better outcomes – higher quality contextual design and more homes. Our recent work at Borough Triangle for Berkeley is a great example of what can be achieved. In urban and some suburban areas, a minimum density is rarely required from a developer perspective, as the market is incentivised to deliver as much development as possible, often in flatted typologies, notwithstanding the recent Building Safety Act and increasing construction cost implications as you reach a certain height.

Borough Triangle, London

Image credit: Berkeley Group Plc

It’s not only London that has tested the use of a density matrix – Salford’s adopted local plan (LP H3) Housing Density has a matrix with minimum requirements based on locations in a designated centre or the distance from a transport node (for example, 200 dph (net) in city centres or within 400m of certain stations). Bristol was recently consulting on a new plan containing a minimum net 50dph target with higher minimums in inner and city areas (100 and 200 dph respectively).

However, as mentioned, the approach in suburban or rural areas may differ where saleability of the right product often drives developers development typology – why would you build higher density townhouses or apartments in areas where the demand is for detached homes? The application of a minimum density standard that uses locational criteria, for example within a railway station in the countryside, does run the risk of dictating what typologies come forward in certain locations, and by association, the future demographic of that specific area. Policy intervention is one thing, but we need to ensure it reflects the ability and will of the market to deliver.

So, the question is, if we are to solve the housing crisis is a minimum density threshold the answer and whether, in reality, would it really deliver more homes? I’m not so sure. A minimum density may help guard against objections to applications, but the various professional design teams, advisors and agents, developers and officers ought to be capable of arriving at a suitable density for each site or area, having regard to a multitude of factors which, when put together, would deliver an ‘optimised’ development for that site. From my experience, it is rare that we walk away from a planning process feeling that much was left on the table. We should, therefore, have a national policy presumption that all development proposals should be ‘optimised’ for housing delivery, unless exceptional circumstances apply. This could form a widened definition or explanation of what ‘making efficient use’ of land really means.

Turning to the draft NPPF itself, draft policy L1 1a iii. proposes setting minimum residential density standards for town centres and for locations that have a high level of connectivity, where this can support more effective land use, but it does not chime with the requirements of policy L3 (achieving appropriate densities, see below). Higher density in town centres is a no-brainer, but what about regeneration or opportunity areas which should aspire to higher densities in the interests of sustainability, or other parts of a settlement that have planned infrastructure investment? What about the new towns – should they set a new benchmark? If the ‘catch-all’ of this policy is anywhere with a “high level of connectivity” then that should be clearly defined, and include areas that will have high connectivity in the future. The Department for Transport launched a Connectivity Tool in June 2025 so why not adopt its scoring system on a national basis?

In fairness, the draft NPPF consultation paper does start to ask the right questions, reminding us that it’s not all a question of density, but often an intricate patchwork of considerations before reaching a point of sustainable development: “identifying whether minimum density standards should be set for other parts of the plan area, especially where there are opportunities for intensification. It may be appropriate to set out a range of densities that reflect the identified need for different types of housing, local market conditions, the availability of infrastructure and its scope for improvement, the importance of securing well-designed, attractive and healthy places, and the desirability of maintaining an area’s prevailing character or of promoting regeneration and change.”

Conversely, draft policy DP3 (Key principles for well-designed places), at 1a, seems to suggest that we shouldn’t be too concerned about context at all as it should not preclude innovation and change, especially where an increase in scale or density of development is justified.

So back to draft Policy L3: Achieving appropriate densities (my comments in bold):

Development proposals should make efficient use of land, taking into account the identified need for different types of housing and other development, local market conditions, the availability of infrastructure (including sustainable transport options) and its scope for improvement, a site’s connectivity and the importance of securing well designed, attractive and healthy places. Nothing new here so why not replace ‘efficient use of land’ with a more definitive requirement to ‘optimise development capacity’ of land for identified needs as this appears to work in London?
Within this context development proposals for residential and mixed-use development within settlements should contribute to an increase in the density of the area in which they are situated. The existing character of an area should be taken into account, in accordance with policy DP3, but should not preclude development which makes the most of an area's potential. This is a positive step forward – increasing density in every settlement (not just town centres or areas with high levels of connectivity), and take account of context but don’t be restrained by it.
Minimum densities for residential development proposals are appropriate in locations which provide high levels of connectivity to jobs and services. Where development proposals for housing or mixed-use schemes are within reasonable walking distance of a railway station, a density of at least 40 dwellings per hectare should be achieved within the net developable area of the site, or 50 dwellings per hectare where the station or stop is defined as ‘well-connected’. So it’s minimum densities in town centres and locations that have high levels of connectivity (set locally through local plans), its increasing densities in settlements (again set locally), but it’s a specific minimum density (set nationally) for sites within walking distance of a station? That station should be well-connected, (which has its own definition linked to frequency of rail services), which is a different thing to a site with high levels of connectivity (as that doesn’t have a definition at all). It’s starting to get complicated, which is exactly the opposite of what we need from a national policy.
Development proposals that do not make efficient use of land in accordance with this policy should be refused. There aren’t many refusal directions in the draft NPPF, so this one is quite serious – meet the minimum density requirements set at a local level, or the station-specific requirement set nationally, or be refused, effectively. It again begs the question whether using minimum densities is too blunt a tool.

In summary, a well-intentioned proposal, but there are some further issues to consider and plenty of constructive debate to be had. From my perspective, whether minimum density standards are the right approach and whether they will ultimately deliver all the extra homes we need is questionable. As we now know, the NPPF changes often enough to enable us to alight and change track, but the housing crisis means we cannot take a wrong turn. If we are going down this track then we could give lofty density ambitions a try in certain contexts and see whether it has the desired effect. To my mind, if we are going to use density as the parameter, be brave. Set aspirational minimum targets (with an exceptional circumstances caveat to avoid refusals), be really clear on locational and connectivity criteria, and avoid any ambiguity over what the priority is – homes for all, quickly.

Courtesy of ChatGPT, the image below epitomises optimised residential development density (not bad, eh):

Cutting Down to Size: How the New NPPF Proposes to Ease the Burden for Small Sites

Edward Clarke & Lincoln Cheung 22 Dec 2025

As part of Lichfields analysis of the draft NPPF (published for consultation on 16 December 2025[1]) this blog focuses on the changes for development of small-to-medium (StoM) sized housing sites and considers the implications for housing delivery.

Plan-making and Development Management: a proportionate approach that reduces documentation requirements

The government highlights delivery of homes on StoM sized sites as one of its “twelve key policy changes”, intending to provide clearer support for the principle of development across a wider range of locations in plan-making.

L1: Planning for an effective use of land

This promotes the allocation of sites of different scales, including StoM-sized sites, and the use of design guides and design codes to establish common design principles and highlight development opportunities of sites of StoM-sized sites.

This would replace the paragraph 73 of the 2024 NPPF, which requires at least 10% of a housing requirement be met on sites no larger than one hectare.

DM1: Preparing development proposals and DM2: Information requirements.

The draft NPPF emphasises that planning requirements should be proportionate to site size, introducing a new “medium development” category in Annex C for schemes of 10–49 homes on sites of up to 2.5 hectares, supported by policy and regulatory easements intended to streamline development on sites of this scale.

The consultation states that the “medium development” category should not be subject to information requirements designed for larger developments (at pre-app or application stage), where these would be disproportionate to the scale of the proposal:

Pre-application engagement: Draft Policy DM1 states that pre-application engagement should be proportionate to the nature of the scheme and those likely to be affected.
Local validation lists: Draft Policy DM2 states local validation lists should only require additional information above what is required by the national decision-making policies when they are supported by local policies. Validation requirements should also distinguish between major, medium and other forms of development, to ensure they are proportionate to scale and potential impacts.

What do these changes mean? The shortage of suitable land for smaller sites and builders has contributed to the decline in SME-led housing delivery in recent years.[2] The Federation of Master Builders has estimated that, given the right conditions, the SME housing building sector could increase housing output by up to fivefold.[3] The changes in the new NPPF might go some way to help address this.

According to Lichfields’ research for the HBF’s Planning for Small Sites (2025), negotiating matters such as design and residential amenity is among the top three issues debated for urban small-site applications. [4] The draft NPPF seeks to address this - at least in part - through the extended use of design guides and design codes on smaller sites. The aim is for greater clarity on local authority expectations, reducing the scope for negotiation.

Furthermore, a greater emphasis on allocation StoM-sized sites would reduce the need for applicants to establish the principle of development on a site-by-site basis. Our research for the LPDF - Small builders, big burdens (2023) - indicates that SME developers are often required to go beyond proportionate validation and policy requirements, leading to increased financial risk and delays.[5] Reducing documentation requirements to proportionate levels would help lower upfront development costs, minimise delays, and accelerate housing delivery overall.

Our research (ibid) also concluded that a medium sized category could help “LPAs and National Development Management Policies to set more proportionate policies and evidence thresholds that are better suited to sites that are [medium sized]”. We also concluded requirement for some evidence should be a product of discussion, rather than be automatically demanded at the outset – “this should lead to case officers being more confident in deferring some of the evidence required to conditions and the reserved matters stage when funding is more readily available [for developers]”.

Affordable housing: Greater flexibility for Payment in Lieu and size standards

The draft NPPF places a strong emphasis on certainty and proportionality for StoM-sized housing sites, particularly for SME developers. Central to this are policies HO8, DM5 and PM12, which together seek to reduce risk, negotiation and delay.

HO8: Providing Affordable Housing

HO8 introduces flexibility whereby, if a proposal meets or exceeds up-to-date development plan requirements for the proportion and mix of affordable housing tenures (including the minimum proportion of Social Rent homes) a more flexible approach may be taken to the mix requirements for market homes. This flexibility could be particularly beneficial for StoM sized sites in urban London locations, allowing unit sizes to be adjusted to support development viability.

While HO8 retains the preference for on-site affordable housing, the government understands the difficulties experienced finding buyers for those properties, with uncertainty and negotiations disproportionately affecting SMEs. In the consultation document, the government is considering allowing developers of “medium development” sites to meet affordable housing requirements entirely through payments in lieu. This was a recommendation of our research for Pocket Living[6] back in 2020. This could be significant, especially on urban sites, and in London where the Government/GLA emergency measures have already highlighted affordable housing as a viability issue holding back delivery.[7]

The disposal of affordable housing to Registered Providers (RPs) has been a persistent and growing challenge on StoM-sized sites. [8] RPs are often reluctant to acquire small numbers of homes within developments, as these can be inefficient to manage and require similar staffing and management inputs without the benefits of scale.[9] This can affect developer cashflow, creating market barriers to entry and delivery.

The HBF Bid Farewell (2024) notes many RPs require at least 20 affordable homes on their sites, with larger providers often rejecting schemes with under 100 homes. This may continue to present challenges for developments of approximately 50–300 homes, which exceed the 49 homes ceiling on the proposed definition of “medium development” but may still deliver fewer than 100 affordable units. This suggests the proposed definition may still not capture the current range of viability and delivery challenges.

Development Viability: A Standardised methodology and obligations

DM5: Development Viability and PM12: Developer Contributions

The policy introduces the presumption that developments complying with up-to-date plan policies should be considered viable. Where a viability assessment is required to demonstrate that a policy-compliant level of affordable housing is not achievable, this has to be specific circumstances, such as:

The development is significantly different from any typology assumed in the development plan viability assessment;
Site characteristics differ substantially from the assumptions used to assess viability when the relevant development plan policies were prepared;
The development is demonstrably burdened by costs which were unforeseeable when the development plan was prepared; and
Site or economic circumstances have changed significantly since the development plan was prepared.

The policy also sets out a more standardised method for assessment, namely to:

Refer back to the viability assessment(s) that informed the relevant development plan policies;
Fully evidence all inputs and assumptions used, explaining any departures from the viability assessment(s); and
Utilise standard inputs set out in the Annex (to be added subject to the result of this consultation).

PM12 adds to this by requiring local plans to set clear, fixed expectations for affordable housing and developer contributions. Collectively, through these two policies, the government aims to standardise the planning process by reduce the time spent negotiating viability and planning obligations at the decision-making stage.

This approach could in due course benefit SME developers delivering StoM-sized sites, particularly in London, where the research by Lichfields for Pocket Living identified affordable housing and viability as key causes of delay in London, with around a third of cases affected by protracted land value and viability debates, and Section 106 negotiations often doubling determination times.[10] Greater standardisation of viability assessments and Section 106 could reduce delays and mitigate financial risk.

However, it remains unclear to what extent the viability process can be standardised, particularly as the exceptional circumstances identified in Policy DM5 may not be uncommon. In the absence of a stepped approach to affordable housing requirements for StoM sized sites, the number of viability assessments is unlikely to decrease, at least in the short term. This approach may be more effective once new-style local plans implement Policy L1 with a greater supply of StoM sized site allocations through local plans.

Standardisation of Planning conditions and obligations

Policy DM6: Use of planning condition and obligations

DM6 states that national model conditions and obligations should be used, unless there are strong reasons not to. The consultation highlights the aim to encourage consistency and simply the planning process.

As with attempts to standardise viability, this proposal could also reduce delays and financial risks for StoM sites. This was similarly highlighted in our research for Pocket Living, with smaller developers often restricted from realising returns on capital due to onerous pre-commencement conditions.

Biodiversity Net Gain (BNG): Exemptions for StoM-sized sites and supporting off-site contributions

The Government’s consultation document has set out the intention for BNG exemptions for certain site categories. The Housing Secretary pledged to introduce an area-based exemption for smaller sites that are up to 0.2 hectares and residential brownfield developments of up to 2.5 hectares. This could reduce the cost of development and slim the evidential burden required to support applications. A full consultation on this is expected in the new year.

This move could help address issues we highlighted in the HBF’s Planning for Small Sites (2025) research, which found that 94% of SMEs had experienced delays with applications due to BNG.[11] For slightly larger sites, simpler and more accessible mechanisms for delivering BNG off-site could also support SME developers, subject to the details proposed in the forthcoming consultation.

Summary and Conclusions

Overall, the draft NPPF and accompanying consultation signal clear efforts towards a more proportionate, standardised and delivery-focused planning framework for StoM-sized housing sites.

Through clearer policy expectations, reduced documentation requirements and a set of more flexible approaches to affordable housing, viability, planning obligations and BNG, the proposed reforms have the potential to address many of the structural barriers that have constrained SME-led housing delivery in recent decades.

If implemented effectively and supported through local plan allocations under Policy L1, these changes could reduce uncertainty, negotiation and delay, lower risk and improving the viability of development on StoM sized sites, particularly in challenging markets such as London. However, the extent to which these benefits are realised will depend on how consistently the policies are applied in practice, the scope of any exemptions or flexibilities ultimately adopted, and whether exceptional circumstances continue to drive site-specific negotiations. This consultation and the forthcoming consultation on BNG early next year presents an important opportunity to ensure that the final framework fully supports the role of StoM-sized sites in accelerating housing delivery.

Footnotes

[1] National Planning Policy Framework: proposed reforms and other changes to the planning system

[2] Lichfields (2023), Small builders, big burdens, Source: Link

[3] Written Evidence of the Federation of Master Builders (2023), Source: Link

[4] HBF (2025), Planning for small sites, Source: Link

[5] Lichfields (2023), Small builders, big burdens, Source: Link

[6] Lichfields (2020), Small sites: Unlocking housing delivery, Source: Link

[7] Lichfields (2025), Two penn'orth invited: the London emergency housing measures consultations, Source: Link

[8] Knight Frank found 80% of developers are struggling to find buyers for Section 106 affordable homes, including more than 40% who say they are unable to find a single Registered Provider (RP) buyer. Source: Link [9] HBF (2024), Bid Farewell, Source Link

[10] Lichfields (2020), Small sites: Unlocking housing delivery, Source: Link

[11] HBF (2025), Planning for small sites, Source: Link

It’s all in the mix

Martin Taylor 19 Dec 2025

The NPPF has long championed the need to deliver an appropriate mix of homes; the right balance of sizes, types and tenures, ensuring planning policies and decisions meet the diverse housing needs that exist from the many different groups present within local communities. The NPPF consultation doesn’t waver from that core thread, seeking to ‘secure a diverse mix of homes’ by better supporting the needs of different groups through the planning system, though in some sense goes further than ever before on seeking to achieve this through the planning system. It does this with several key proposals thrown into the mix:

Stronger support for rural social and affordable housing, by widening the previous narrow definition of ‘designated rural areas’ to include Parishes with a population of less than 3,000 and population density of two persons or less per hectare, allowing affordable housing contributions to be sought on minor developments in those areas. Although this is a minor definition change, it could generate more affordable housing funding in such rural areas, but equally may make the viability of such schemes in some areas more challenging.
Mandating that LPAs set out policies for the proportion of housing to be delivered to building regulations optional standards part M4(2) ‘accessible and adaptable dwellings’ and M4(3) ‘wheelchair user dwellings’, with a set minimum of 40% of homes delivered to one or other of the standards. As the consultation recognises, many LPAs already require such standards, but the change is seen as formalising best practice.
Requiring authorities to allocate sites to provide for specific types of housing such as older persons housing, purpose-built student accommodation, and self-build plots. Such a change would require a wider consideration of site selection through Local Plans to meet those needs. Carving out specific allocations for those accommodation uses will ensure they are not competing for limited space with general housing.
More flexibility on the housing unit mix, where local requirements on the mix of affordable homes are met or exceeded. In practice this is brought through in policy wording which indicates that where such affordable housing stipulations on tenure and mix are met, including a minimum proportion of social rent, “a flexible approach should be taken to taken to the application of any development plan requirements relating to the size of market homes, taking into account prevailing market conditions” (Policy HO8(3)). Meet your affordable housing obligations and the quid pro quo is that you can deliver (more of) what you want for the market housing element.

It is perhaps this last change that is the biggest departure from current practice, and represents a significant opportunity for rebalancing and optimising viability within individual schemes. Policies guiding – and in some cases dictating – the appropriate mix of unit sizes for market homes are abound in local planning documents, taking many forms. Some are development plan policies, some are not instead simply pointing to evidence or relevant material considerations (albeit that in some cases open market housing mix targets set out in SHMAs and other evidence are being applied as if they did carry the same weight as development plan policy). Some policies and proposals relating to housing mix have in-built flexibility, reflecting that different sites will be suitable for different mixes and lots of considerations may apply. Others rigidly and narrowly seek to apply the findings from local housing need assessments in a prescriptive manner; often even though those assessments build in assumptions around how households will occupy homes and bear no reflection on what a housebuilder can best sell in a local market (e.g. is it that households only ‘need’ 2-bedrooms, or is it that work-from-home, frequent visitors or a desire for more space means those same households might ‘demand’ and be able to afford 4-bedrooms?). And is it for the planning system to intervene in this way?

Market mix is important stuff to housebuilders – it impacts viability and bottom lines. This was most forthrightly highlighted when one such policy, set out within an SPD and contended to be overly prescriptive, was challenged by a collective of housebuilders and quashed by the high court.[1] On occasion, it can be hotly contested at application stage too.

The introduction of flexibility on market mix could achieve interlinked outcomes of driving schemes to achieve their affordable housing obligations, whilst simultaneously improving the viability of schemes (and enhancing sales rates) and delivering the type of housing that best reflects market demand. It’s also worth remembering that new homes don’t operate in isolation, but as part of a wider housing ladder, where someone buying a new home of a certain size might free up their existing home (of a different type or size) to meet a different market demand – and set off a wider chain of movements. Flexibility doesn’t inherently imply local needs and demands will go unfulfilled. Indeed, flexibility might mean that local needs can be better served as developers are not required to deliver a mix derived from a ’borough-wide’ position (and one that might be drawn from somewhat dated housing market evidence), but instead can focus on what local needs and market demands are within the immediate locality of the site.

That leads to one question of why similar flexibility should not apply to viability tested affordable housing provision, where development plan expectations cannot be met, but a shift in market housing mix (beyond the parameters of policy) might deliver more affordable housing than is otherwise viable. It might seem odd to only afford that freedom where affordable housing requirements are already met, but not necessarily to instances where such flexibility could actually deliver better affordable housing outcomes. Therefore, we might see that market pressure results in this flexibility being used less than we might like, particularly in areas where circumstances mean existing affordable housing targets are becoming difficult to deliver.

The remaining key question is what does a flexible approach to market mix look like in practice – is it carte-blanche to pursue a market mix of solely the highly profitable elements (that might be large ‘executive homes’ in some markets, or might be smaller flats optimising unit numbers in others) or is it an invitation to shift only slightly outside any set policy parameters? Ultimately that appears to be at the discretion of the decision taker, the proposed ‘flexible approach to the application of development plan requirements’, after all, does not and cannot disapply those development plan requirements, so it becomes an issue of weight applied to those policies and the degree of divergence deemed acceptable. Therein lies uncertainty, but with pragmatic application market mix flexibility could give certain development schemes precisely the deliverability boost they need in the current market.




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Footnotes

[1] William Davis Ltd & Ors v Charnwood Borough Council [2017] EWHC 3006 (Admin) (23 November 2017) - https://www.bailii.org/ew/cases/EWHC/Admin/2017/3006.html

Planning matters

A pedestrian renaissance for Oxford Street? Pulling the Mayoral Development Corporation lever

Draft NPPF: Minimum Density, Maximum Impact?

Cutting Down to Size: How the New NPPF Proposes to Ease the Burden for Small Sites

Plan-making and Development Management: a proportionate approach that reduces documentation requirements

Affordable housing: Greater flexibility for Payment in Lieu and size standards

Development Viability: A Standardised methodology and obligations

Standardisation of Planning conditions and obligations

Summary and Conclusions

Footnotes

It’s all in the mix

National policy consultation 2025

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Planning matters

Plan-making and Development Management: a proportionate approach that reduces documentation requirements

Affordable housing: Greater flexibility for Payment in Lieu and size standards

Development Viability: A Standardised methodology and obligations

Standardisation of Planning conditions and obligations

Summary and Conclusions

Footnotes

National policy consultation 2025

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