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. 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.
| |
|
|
| |
 |
|
| |
|
|
| |
National policy consultation 2025
Our web resource brings together Lichfields' analysis of the Government’s Draft National Planning Policy Framework consultation and other proposed reforms affecting the development industry
|
|
| |
|
|
