Transport for New Homes think a more radical reform is needed to deliver truly sustainable development

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1. Introduction

The proposed changes to the National Planning Policy Framework and other ‘reforms’ to the planning system are out for public consultation until 10 March 2026. As the text explains: ‘National planning policy carries very considerable weight in the planning system and is an important consideration when making decisions on planning applications’.

There are over 120 pages and no less than 223 questions to be answered. The topics range from house building, sustainable development and land use, climate change, economy, energy the natural environment and much, much more. Within these sections, transport, planning and land-use make important appearances.

2. No National Plan or evidenced discussion

The ordinary person hoping for a rational and evidenced explanation and overview concerning future planning in England will be disappointed. There is no ‘National Plan’ as such. A clear joined-up plan seems to be missing from this salient document from the Ministry of Housing Local Communities and Government.

• There are no named cities or towns, no maps or evidence presented on many important aspects of geography such as where jobs are concentrated or likely to be in the future.

• There is no holistic strategy as to where to build new homes sub-regionally, with evidence and geographical analysis presented.

• There is no discussion of where we want housing or job growth, and matched investment public transport to support it, in particular new mass transit systems to reach out to the new places being built.
  
• There is no analysis regarding past trends in housing or transport that might be avoided, for example unsustainable patterns of development. There are no accompanying statistics that we could find.
  
• Despite requiring local planners to carry out a ‘vision-led approach to planning and transport’ in policy TR1, the NPPF does not abide by this policy at a national level.

The language of the document in general is imprecise and open to interpretation , giving something of an impressionist painting created by a patchwork of different policies pieces. The relationships between policies are impossible to decipher.

3. Accessible and understandable…to consultants

Nonetheless the document is apparently, as stated from the outset, written to be ‘accessible and understandable for everyone who uses it’. This is probably true for specialist planners, consultants and lawyers working in the development industry. But for the ordinary reader or councillor, the loops and pirouettes of policy-speak, involving the ‘spatial’, the ‘sustainable’, and the ‘strategic’ are confusing. For transport it’s not rail, tram or bus, walk or travel by bike. Think more along the lines of ‘ movement’ and ‘connections’.

4. Housing targets generated by super-simple algorithm

But in the midst of all the talk is something very definite and precise which sets the scene. The starting point – the roll of the dice that begins the game on housing –  is the centrally issued so-called ‘objectively assessed housing need‘ in Appendix D of the consultation document, a specific number given to each local planning authority by central government for the homes that they must find sites to build in their Local Plan. They maintain a ‘five year housing land supply’ of land to build the requirement, or there will be penalties. For this they rely in the main, on sites put forwards by developers.

The method used to calculate this ‘housing need’ figure is not sophisticated. The algorithm takes the existing number of homes in the area, and then increases this by a standard percentage. Then it applies an escalator, a formula to zoom up the target if the ratio of local wage to average house price in the local authority area is above 5. The higher the ratio, the more the housing target is increased. This is to bring down the price of accommodation by enabling the volume house builders to flood the market with more homes. Well that is the theory.

5. Location, location, location

We need new homes but a essential part of planning sustainably is the right location to build, and we have seen how important this is on our visits to other European countries. The problem is that using an algorithm misses out of some important themes.

• Targeting new housing to places where the economy is growing and people are looking for accommodation – building in the right cities and towns for the people who need the homes
• The need for new extended mass transit systems to reach out to new areas to connect people to the wider town or city so that they can get to work, education, see family and friends and so on
• The right locations for building at density – low and mid-rise apartments or townhouses – to achieve a proximity of  population  to support new shops, services, public transport and so on, whilst avoiding dispersed greenfield low density sites where you just have to drive.
• Places where new large-scale housing can be combined with the other elements needed for successful places – green infrastructure and parks, public amenities, integrated with residential accommodation – places noty just housing estates.
• The geographical locations and capacity of large brownfield sites to be developed as a priority

6. Car-based sprawl risks – lots more to come

But in England this does not seem to be the way we plan. Our concern is that the proposed National Planning Policy Framework does not properly steer us towards this more modern way of doing things. There are a number of policies that might well move in the right direction, towards increased emphasis on brownfield sites, smaller sites and the concept of building around stations. But ultimately we worry that it will be ‘business as usual’ in many cases with even more low density car-based sprawl because housing is targeted in places where it is for most part, the inevitable choice. This is what we see on many of our visits to new housing being built.

The giveaway is perhaps the 2-3 parking spaces per home. A life style of driving is catered for parking at both origins and destinations, and by a system of distributor roads and roundabouts for cars to come and leave easily. The traffic then pours onto the strategic road network, adding to congested trunk roads and motorways . Out of town retail, drive -thru restaurants and so on, located around the new road system, is to the detriment of the town centre. Many of the stated broad aims of the NPPF, including a vision-led approach to transport, effective land use, and building at appropriate densities, are countered and compromised by the wrong spatial distribution and dispersed nature of the locations where we build, and a lack of clear policy to direct otherwise.

There seems to be no acknowledgement of the problem, or solutions proposed. The NPPF allows us to go on building unsustainable car-based sprawl – the ‘cowpat’ developments that we have seen again and again, whilst

7. Meanwhile, the NPPF asks ‘vision-led transport and planning’

Meanwhile the NPPF has a policy on a ‘vision-led approach to planning and transport’ for local planners writing the Local Plans, blue-prints for their area lasting 15 years or more. On this basis national policy TR1 asks for:

’sustainable transport to be considered at the earliest stage of plan-making’  and for ‘locating development where it can support sustainable patterns of movement’. 

This may work for local authorities in big urban areas where good public transport and active travel provision are already established. But for the hundreds of thousands of new homes to be built outside such places, often on medium and large greenfield sites opened up by roads and roundabouts, the vision-led approach risks failing. The proposed NPPF may call for building in places that are well connected by sustainable modes – including good public transport – to jobs and services, but we then throw high targets to places where this is going to be very difficult. Will housing targets trump all and continue to dominate so much of the local planning scene? This is the risk.

8. Genuine vision-led transport and planning needs something different

To bring the ‘vision’ into the real world, a new approach is needed. We would like to see a much more evidenced methodology as to where and how much to build, taking into account jobs, housing needs of different sections of the population, coordinated investment in mass transit systems, access to services and so on. This model is about land use, local economies, life-styles, and a low carbon future, and environment. Transport is of course an important part of this too.

9. Making more efficient use of land – density

The consultation text relating to Chapter 12 ‘Making effective use of land’ acknowledges that: 

‘many of our urban areas have been developed at relatively low densities, particularly when compared to continental Europe’. 

There then follows an explanation that the government wants to see a much greater emphasis on brownfield development, intensification and higher densities around places that are ‘well-connected’ transport-wise (we hope this means public transport) which ‘can reduce the need to travel’ (presumably meaning less need to travel by car?). All well and good, but how can we build at higher densities in other places too, so that we build better from the start, in the many urban extensions, our new towns and our ‘garden communities’? There is no discussion, and indeed Policy L3: Achieving appropriate densities is very vague:

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.

Is there anything in these words to say that greenfield development should specifically not be low-density car-based sprawl built off the bypass? Not , it seems, if it is built in the wrong location.

10. Parking – how much?

Our visits to housing estates have shown are dominant car parking can be, taking up space which could go to gardens, grass verges, and trees. But in terms of car parking standards (how many spaces per home), a very flexible approach is again put forward. The text therefore explains:

Parking standards should take into account the connectivity of development in different locations by different modes of transport  and..…local car ownership levels and travel trends

We have seen how car ownership is particularly high in edge of town housing estates. Town and city centres, where attempts are being made to reduce traffic, are made busier with all the cars from the new development. Healthy life styles and vibrant town centres are countered by the car-based development at the edge, and a life style develops which we have called ‘car park to car park’. We have seen this in many places. Again there is no background discussion to set the scene so that we understand the implications of car-based development, even though other parts of the NPPF ask for a proactive approach with respect to climate change.

11. Brownfield sites and town centre vitality

It is good to see more emphasis on brownfield sites but these may need extra resources to get them built, and indeed we have seen many lying fallow sometimes for decades. The use of smaller and medium sites for housing is welcome. More people living in town and city centres means a higher density of population to provide customers for cafes and shops. The policies in the NPPF might make this point more specifically in national decision-making policy.

12. ‘Well-connected’ stations and ‘Travel to Work Areas’

The Dutch build new places around new stations as hubs for the community, where the shops and cafes are, and the bus interchange. These stations are connected into the national rail system by truly ‘turn up and go’ services . In common with modern trends across Europe and the world, the Dutch also build tram lines to cater for new areas and of course, cycleways.

The NPPF newly supports the concept of building near ‘well connected’ stations although it looks as though this might mean only two trains an hour in a given direction. Policies S4 and S5, which cover development ‘outside of settlements’ include support for housing around well-connected railway stations.

We do of course support the notion of building new homes near stations but feel the policies and the practicalities need a lot of further work. A Metro with a sequence of stops and interchanges to facilitate development closer to existing urban areas may be a better model than building around isolated commuter stations a long way out.

There seems to be no policy regarding the integration of station carefully into the public realm of new communities, in the way that a true metro station is.

The NPPF speaks of ‘Travel to Work Areas’ which appear to be based on the census 2011 commuting flows, some fifteen years ago. There are 149 Travel to Work Areas (TTWAs) defined in England in 2011 and they are very small, compared to our city regions or the proposed mayoral authorities. These Travel to Work Areas are not named or mapped. If we genuinely want vision-led transport and planning, then up-to-date information on travel to work over wider areas is surely key, this combined with geographical data on job density and economic growth, further education and health provision, large sites available for building new homes and so on. In an age of AI and data, surely we can plan in an informed way.

In conclusion

Transport for New Homes believe that new homes are very much needed. However this National Planning Policy Framework has not been thorough in terms of jobs, geography, transport, and much more. The result is a collection of policies on land-use, transport, density, parking, town centres and so on, that mean a lack of clarity. Although the NPPF asks for ‘Embedding a vision-led approach to transport’, at a national level we entirely fail to do this. The time has come for change.