CIH responds to the National Planning Policy Framework consultation (December 2025)

Strongly agree.

A) Please provide your reasons, particularly if you disagree.

We have heard positive reactions towards the new format and structure of the NPPF, which has greater consistency, clarity and guidance.

Partly agree.

A) Please provide your reasons, particularly if you disagree.

We welcome the use of spatial development strategies in the NPPF. CIH has long called for the return to strategic planning, to create greater cooperation between areas, as well as more certainty and consistency. This is particularly important in the context of further devolution across the country, to allow local areas to set clear priorities and plans to deliver the homes we need.

We would like to encourage government to more explicitly encourage the development of affordable housing within the content of spatial development strategies. Whilst the text currently discusses new housing, it is vital that government sets a national expectation for this to include a clear framework for affordable housing. This will demonstrate the priority for the government, and ensure it is included at local and regional levels within planning decisions, creating consistency to meet housing needs across the country.

It is essential that clarity is provided about the scope of spatial development strategies, in particular what should be included versus what is best left to Local Plans and related local planning authority policy.

We also believe that there must be clearer strategic consideration to the social and economic needs of rural communities through spatial development strategies. This will ensure that rural needs are not overlooked when catering for large and diverse geographic areas covered by the spatial development strategy. We therefore recommend including a clause into PM1 with a new sub paragraph (d), following similar wording in the Scottish National Planning Framework 4, which reads:

'Including a strategic approach that supports rural revitalisation through sustainable development in rural areas that recognises the need for rural communities to grow.'

Partly agree.

A) Please provide your reasons, particularly if you disagree.

Late-stage review negotiations are both a vital and a complex stage in the planning process. They are essential in ensuring that any land value uplift generated after planning consent is shared between landowners/developers and providing public benefits through developer contributions.

If a scheme originally would not provide sufficient affordable housing due to viability constraints and these viability issues are alleviated throughout development, it is crucial that additional profits should be reinvested into delivering necessary affordable housing, as outlined in the policy requirements of the NPPF. 

These viability reviews will only be required where viability has improved, and additional affordable housing can be delivered. Local plans must outline where viability reviews are required, and what approach should be taken.

We are aware from our members, however, that late-stage viability reviews can be complex, costly and resource-intensive for local planning authorities (LPAs).

As CIH has consistently argued, LPAs already lack the capacity, resources and personnel to process planning applications quickly, and often will come against larger developer legal teams during viability reviews.

It is essential that government both fully resources LPAs as well as sharing clear guidance and advice on how to approach viability reviews. This follows recent government commitments to support LPAs in negotiating Section 106 agreements. 

Partly disagree.

A) Please provide your reasons, particularly if you disagree.

CIH understands the justification for seeking to limit local standards for energy efficiency in local plans. We acknowledge that allowing local planning authorities to set higher energy efficiency standards could lead to the creation of hundreds of marginally different standards, which could increase the cost and complexity of development by for-profit and not-for-profit developers alike.

We are also aware that, although previous examples of these standards have been based on widely recognised industry carbon measures, there has been some subtle variations. CIH works with some housing associations that own and/or develop homes in over 100 local planning authority areas, and it could be challenging for them to meet this number of different standards, even if all based on an accepted carbon metrics.

However, these challenges must be balanced against the urgency of tackling climate change and ensuring that the planning system is in-line with our legally binding carbon targets. As we have stated elsewhere in this response, planning policy should be aligned with the Climate Change Act (2008). Restricting the production of local standards for energy efficiency could close an important avenue for accelerating the development of safe, modern homes that are fit for the future. 

We would therefore propose an alternative approach. PM13 should allow strategic planning authorities and the Mayor of London, and/or county councils (where appropriate and subject to the conclusion of local government reorganisation), to develop and agree tighter energy efficiency standards with all relevant stakeholders – including LPAs, housing associations, developers, and others - at a sub-regional level. 

All LPAs would agree that the standard approved at the strategic or county planning level would be reflected in their local plans. This would enable tighter energy efficiency standards to be set at a ‘Goldilocks zone’ sub-regional level; accelerating the delivery of low-carbon, energy efficient homes that go beyond minimum building regulations, while ensuring that for-profit and not-for-profit developers do not have to navigate marginally different standards at the local (especially district) plan level and can be active collaborators in the production of each standard.

As an example for how this model could work, we are aware that Essex County Council has developed a county-level standard that has been adopted by eight district councils within their county boundaries. Replicating this approach could be a pathway to enabling more ambitious standards to be set at a level that is large enough to be effective for all stakeholders wishing to develop homes in a particular sub-regional geography, yet local enough to satisfy the climate requirements of LPAs. 

In addition, this model could be extended to other parts of the building regulations, where appropriate. In particular, CIH would support LPAs, especially in London and elsewhere in the south of England, being given powers to introduce tighter building regulations on overheating than the national minimum (i.e. Part O). This is because Met Office analysis shows that London and southern England are at particular risk of extreme heat in the future. 

By 2070, the chance of the temperature exceeding 30°C for two days or more will become sixteen times more frequent in the south than it is today, and the average hottest day in summer could see temperatures reaching 40°C. Allowing LPAs in these parts of the country flexible to introduce tighter overheating new build standards would give them the flexibility to build homes that are fully resilient to the extreme heat they will see in the future. 

Partly disagree.

A) Please provide your reasons, particularly if you disagree.

We are concerned that the current definition of settlements in the glossary may risk many rural settlements being excluded due to vague wording. Because rural areas have limited access to public transport and other services, LPAs may consider that rural settlements do not meet the requirements of contributing towards sustainable development.

We would encourage the amendment of this definition to include the provision that, in rural areas, individual settlements or clusters of villages which share services, can act together as a sustainable settlement.

Partly agree.

A) Please provide your reasons, particularly if you disagree.

We support the boosting of development through the planning process by revising the presumption in favour of sustainable development. This includes the ‘brownfield passports’ policy, which CIH has previously commented on, and encourages all areas across the country to build the homes we need. We have received comments from members that further detail is required to define ‘suitably located development’, such as what this means for connectivity to services, facilities and employment, to provide a good quality of life.

We would also include the caveat from our response to question 35 that the proposed definition of settlements must be amended to better include rural areas, to avoid this presumption having a negative impact of excluding rural communities.

We would also like to point towards our response in question 172 on the sequential test on surface water flooding, to note that we are not supportive of these changes to widen the ability to build homes on unsuitable land.

Partly agree. 

A) Please provide your reasons, particularly if you disagree.

We largely support the proposed approach to development. The only point we would like to make on this approach is a need to emphasise the importance of affordable housing. Policies S4 and S5 outline that national decision-making should be taken into account when assessing individual applications (such as policy HO8), but we believe it can go further in ensuring the balance towards affordable housing is protected.

This could be outlined by amending policy S4(2) to include "failure to meet or exceed up-to-date development plan requirements for the proportion and mix of affordable housing tenures relevant to the location, including the minimum proportion of social rent" as an "adverse effect".

This would ensure that the government’s priority of delivering social and affordable housing is protected, and that the proposed approach’s aim to boost development will ensure that the right homes are built to meet housing needs.

Partly agree.

A) Please provide your reasons, particularly if you disagree.

We broadly welcome the continued focus on climate change, extreme weather, and long-term climate trends in policy CC1. We would make two comments for improvement: 

• While we welcome the language concerning "radical reductions in greenhouse gas emissions", we feel that it is necessary to be more specific and prescribed regarding the definition of radical. CIH continues to believe that CC1 must refer to the Climate Change Act (2008), and specifically that proposed development patterns should be compatible with the greenhouse gas emissions reductions set out in the Climate Change Act (2008) and associated carbon budgets, as far as possible. If we do not prioritise this, we risk jeopardising our carbon budgets through housebuilding activity alone.
• CC1, paragraph 1d refers to "green infrastructure provision". This should be amended to read ‘green and blue infrastructure provision’. Blue infrastructure can play much the same role as green infrastructure in supporting carbon storage and nature recovery but is qualitatively different. The government’s own health and inequalities project on blue spaces, led by the Environment Agency, also found that water environments like rivers, lakes, streams, marinas, and canals have a range of physical, social, and psychological health benefits. We would like to see CC1 (and planning policy more generally) explicitly recognise the climate and health benefits of blue space provision.

Partly agree.

A) If not, what additional measures could be taken to ensure climate change mitigation is given appropriate consideration?

We welcome the amendment in Policy CC2, paragraph 2, to include district heat networks, notwithstanding the practical delivery challenges associated with the Heat Network Technical Assurance Scheme (HNTAS) (see our response to question 97).

Paragraph 167 of the current NPPF, essentially introduced as Paragraph 164 in the 2023 update to the NPPF, gives significant weight to energy efficiency and low-carbon heating improvements. In Policy CC2, paragraph 2, this is changed to ‘substantial weight’: a change we welcome, although one that may not result in changed interpretations in the development of local plans. 

We would like to see Policy CC2, paragraph 2, go further in one specific area. Despite the current Paragraph 167, CIH members we have consulted with have experienced challenges obtaining planning permission for major energy efficiency upgrades in housing association properties, preventing them from undertaking this work, even after the 2023 update to the NPPF, which introduced Paragraph 164.

In addition, our members have noted that there are a range of inconsistent practices adopted by LPAs. For instance, we have been informed of one example where, at preliminary inquiry stage, one local planning authority has asked a housing association to submit individual applications for each home. This is not only financially unviable, but also impossible to resource, because it would involve the preparation of thousands of individual applications.

In contrast, the same housing association has received a presumption of approval following outline information from adjacent LPAs, which enables energy efficiency upgrades to be undertaken quickly, delivering immediate benefits for residents and climate alike.

The planning system should make it as simple as possible to undertake energy efficiency and low-carbon heating upgrades to existing homes, including solar PV. We acknowledge that LPAs may wish to scrutinise energy efficiency upgrades to existing homes within their boundaries. However, this must be balanced against the urgent need to improve the energy efficiency of our homes to meet statutory fuel poverty targets and, for social and private rented housing providers, updating Minimum Energy Efficiency Standards (MEES).

We would therefore like to see Policy CC2, paragraph 2 strengthened, perhaps through the addition of a statement of presumption in favour where adequate outline information has been provided. Some of the issues that are raised at planning stage (such as questions of aesthetics around external cladding, installation of solar panels, etc.) could be dealt with satisfactorily in design guides.   

Partly agree.

A) What additional measures could be taken to ensure climate change adaptation is given appropriate consideration?

We broadly welcome the content of CC3, and the guidance in the associated draft Design and Placemaking Planning Practice Guidance. For example, it is welcome to see the Guidance refer to the importance of passive cooling measures, green infrastructure, and minimising the Urban Heat Island effect.

However, our one comment is that CC3 is not specific enough about the meaning of the ‘current and potential impacts of climate change over the lifetime of the scheme.’ We recommend that CC3 make specific reference to the Climate Change Committee’s (CCC) advice on UK adaptation objectives. Specifically, CC3 should refer to the CCC’s advice that national adaptation policy should prepare the country for the weather extremes that will be experienced if global warming levels reach 2°C above preindustrial levels by 2050.

National decision-making policies should in other words be required to have specific regard to whether development proposals are sufficient to minimise vulnerability to the impacts of warming of, and in excess of, a minimum of 2°C above preindustrial levels.

The CCC’s guidance should also shape a more strategic approach to plan-making and decision-making, rather than a narrower focus on design and placemaking. The CCC has emphasised that 2°C above preindustrial levels should be the minimum level of warming that national adaptation policy considers.

Many new homes built in the coming years will still be occupied in 2100, and the CCC has been clear that 'reaching 4°C above preindustrial levels by the end-of-century cannot yet be ruled out and should be considered as part of effective adaptation planning.' At a strategic level, planning policy needs to make sure that all new developments have a level of resilience to the most drastic future climate scenarios. This principle also applies to building regulations. 

We would therefore recommend a wording change to CC3 paragraph 1 as follows:

'Development proposals should take into account the current and potential impacts of global warming of between 2°C and 4°C above preindustrial levels over the lifetime of the scheme, and in order to minimise vulnerability to these impacts should, where relevant to the proposal.'

Partly agree.

A) Please provide your reasons

CIH has recently completed a piece of research examining the links between wildfire risk, the risk to existing homes, and the risk to new developments. At the time of writing, the draft output of this work, a guide for housing providers, is being peer reviewed by experts in housing, fire safety, and by wildfire experts in the fire and rescue service. We have previously shared the draft output with MHCLG officials. We aim to publish this output in spring 2026, subject to the satisfactory conclusion of peer review.

Evidence shows that, in a world that is 2°C hotter, the frequency of days with ‘very high’ fire danger in the UK will double compared to preindustrial levels. According to the CCC, there will be almost a trebling of days with conditions favourable for wildfires in the peak wildfire month of July from three days per year on average in a 1981 to 2010 climate, to approximately eight days per year for the UK as whole. The wildfire season will become longer, starting earlier and extending into autumn (notwithstanding evidence that wildfires already occur all year round). According to a team of academic experts, this means that there is an ‘urgent need’ to reduce people’s exposure to the growing threat of future fire weather events compounded with hot and dry conditions.

Overall, we therefore strongly welcome and support the inclusion of CC3, paragraph 1, part E within the new NPPF. We would make three comments:

• While we generally feel CC3, paragraph 1, part e concisely explains when risks should be considered, and how these risks should be mitigated, further guidance will likely be required to support planning and development teams to understand the risks, terminology, and definitions in more granular detail.
• Relatedly, the greatest risk to new developments is typically the smoke that wildfires emit. Wildfire smoke contains hazardous pollutants, such as nitrogen oxides and fine particulates. Smoke is also particularly harmful to vulnerable groups, such as children, pregnant women, older adults, and those with pre-existing health conditions. To give one example, the 2018 Saddleworth Moor wildfire substantially degraded air quality. According to an academic study, during the wildfire, “PM2.5 concentrations increased by more than 300 per cent in Oldham and Manchester and up to 50 per cent in areas up to 80 km away such as Liverpool and Wigan. This led to one quarter of the population (2.9 million people) in the simulation domain (−4.9–0.7◦E and 53.0–54.4◦N) being exposed to moderate PM2.5 concentrations on at least one day […] This equates to 4.5 million people being exposed to PM2.5 above the WHO 24-hour guideline of 25 µg m−3 on at least one day.” Planning and development teams may therefore need guidance to consider not just the location of the proposed development in relation to wildfires, but the interrelation of this location with atmospheric and weather-related factors that could increase or decrease the risk of smoke affecting the development. These factors include the specific type of vegetation/fuel loads near the development, which affect the different kinds of smoke emitted (e.g. peat fires result in large dense ground level plumes), and the possible impact of prevailing winds on smoke distribution, and local terrain or access issues.
• Lastly, with reference to both the NPPF and the associated Design and Placemaking Planning Practice Guidance, there are further mitigation measures that could be considered beyond blue infrastructure, the creation of defensible spaces and fire breaks, and reducing fuel loads. Specifically, guidance could include more details on design and construction approaches that minimise the risk of ignition through ember penetration. Embers can be spread beyond the frontier of direct flames and cover significant distances. When they are blown close to homes, they can ignite if they land in the wrong place, such as in gutters or nearby flora. Guidance could also consider access/egress provision and/or turning space for emergency vehicles, especially if the local terrain and/or road network constrains response times.

Overall, we would encourage MHCLG to engage further on these areas with wildfire experts, especially land managers and their representative bodies (e.g. the Moorland Association) and fire and rescue services, to ensure that guidance developed for planning and development teams is sufficient to support them to minimise wildfire risk.

While our own guidance is more focused on asset management and minimising the risk to existing homes, we would also welcome the opportunity to support MHCLG with the development of guidance for planning and development teams.

Strongly agree.

A) Please provide your reasons, particularly if you disagree.

We agree that spatial development strategies and local plans must take into account housing need assessments, to ensure all developments are meeting local need. This is especially pertinent to ensure the development of housing for specific groups, such as specialised housing for older people or supported housing for members of the community who need extra support to live independently and for those who are homeless.

Whilst the ‘different groups’ outlined in HO1 are broad, we would argue that these categories should be strengthened with the inclusion of explicit reference to specific measures of housing need which exist within each local authority to ensure that planning authority assessments of housing need are strategically aligned with other departments.

For example, the need for specialist housing can be evidenced tangibly in local plans and spatial development strategies by referencing incoming local authority supported housing strategies. These are an obligation of the Supported Housing (Regulatory Oversight) Act 2023 and each local authority is required to produce a likely estimate for new homes of this type over five years.

For general needs homes, we would recommend that the number and size of statutorily homeless households reported in Homelessness Case Level Information Collection (H-CLIC) data and the number of rough sleepers assessed in quarterly counts should be referenced and accounted for in setting spatial development strategies and local plans. These existing measures of local need are also absent from Annex D: Housing calculations and supply. The implementation of the above changes would allow a shift towards targeted housing development to truly meet local need and the strengthening of local government strategic alignment. 

Strongly agree.

A) If so, what elements should this guidance cover?

Further guidance should support local authorities to make robust assessments of the housing needs of older people (across mainstream and specialist models to support ‘rightsizing’), taking account of the evidence of the benefits of accessible and specialist homes for public services - reducing increasing demands on health and social care - as well as benefits for residents to maintain independence, dignity and wellbeing. We support the recommendation of the Older Person’s Taskforce for a standardised methodology that recognises changes over time, including health and care needs.

Guidance should similarly be provided for supported housing for working aged people. This is an invaluable housing tenure which is critical for reducing homelessness, addressing domestic abuse, helping people live fulfilling lives within the community and relieving pressures on the NHS, justice system and social care, representing a huge saving to the public purse.

The National Housing Federation’s research estimates that 167,000 more supported homes need to be delivered by 2040 (across all ages), a target which may be met more realistically by recognising the national need for these homes in the planning system.  

Building these homes is often much more expensive than general needs homes and without adequate inclusion in the planning system and accompanying funding it is unlikely that they will meet commercial viability levels and, therefore, be built. Some local authorities have the delivery of supported housing built into their local plan, but by no means all, and guidance should support this to be adopted across all councils.

Further guidance is required to support local authorities to assess needs for fully wheelchair accessible homes (if M4(2) is mandated across all new homes). This would enable local authorities to meet the requirements proposed in the NPPF and set out the proportion of accessible housing needed. Please see our response to question 58 for more information on M4(2) accessible homes.

All of the additional guidance should clarify expectations that the information, evidence and expertise of local partners across health and social care should be utilised to inform needs assessments.  

We broadly support the intention to integrate relevant policies relating to traveller sites within the NPPF as this could help ensure that planning for Gypsy and Traveller accommodation is considered alongside wider housing need and local plan development.

A more integrated approach may help reduce the perception that provision for Gypsy and Traveller communities is a separate or exceptional planning issue. However, it is important that integration does not dilute the specific policy attention required to address the long-standing shortage of suitable sites and the distinct accommodation needs of Gypsy and Traveller communities.

Evidence shows that the delivery of sites has historically been inconsistent, with many local authorities struggling to move from identifying need in plans to delivering sites on the ground. Effective policy must therefore continue to recognise the structural barriers to site provision, including difficulties identifying suitable land, overcoming local objections, and securing planning permission and funding for site development.

For integration within the NPPF to be successful, the framework should continue to emphasise the importance of:

• Robust and defensible evidence of accommodation need
• Strategic, proactive planning for sites rather than reactive responses to unauthorised encampments
• Strong local leadership and engagement with Gypsy and Traveller communities the inclusion of sites within Local Plans to ensure delivery.

Yes.

Further national guidance would be helpful to ensure a consistent and robust approach to assessing need and establishing requirement figures across local authorities. The evidence suggests that methodologies used in accommodation needs assessments can vary significantly, particularly in relation to assumptions about population growth and definitions of Gypsy and Traveller households.

For example, different studies have applied varying population growth rates when estimating future need. The choice of assumption can have a significant impact on projected accommodation requirements. There are also concerns that broader housing needs assessments may not capture the full extent of need if the specific circumstances of Gypsy and Traveller communities are not properly reflected.

Evidence indicates that generic assessments risk underestimating need if they do not include targeted engagement with these communities. Clearer national guidance would therefore help ensure that need is assessed consistently and transparently, and that requirement figures are based on robust evidence.

A) If so, what are the key principles this guidance should establish?

Any further guidance should be based on several key principles to support fair and effective assessment of need and delivery of sites:

• Robust and transparent evidence of accommodation need. Assessments should be based on clear and defensible evidence, recognising that robust data on need is a fundamental prerequisite for successful site delivery.
• Engagement with Gypsy and Traveller communities. Local authorities should actively involve Gypsy and Traveller residents in the design and delivery of accommodation needs assessments. Evidence suggests that assessments are stronger when community members contribute to survey design, research and outreach.
• Realistic assumptions about household growth and future demand. Guidance should support authorities to use locally informed data where possible, including information on household size, age profiles and family formation, rather than relying solely on generic national assumptions.
• Recognition of hidden and unmet need. Assessments should consider concealed households, overcrowding, unauthorised encampments and those unable to access land or planning permission through the private market.
• Integration with wider housing strategies while recognising specific needs. Traveller site provision should be considered alongside wider housing planning, but with appropriate adjustments to reflect the cultural, social and spatial requirements of Gypsy and Traveller communities.
• Strategic planning and delivery. Need assessments should inform Local Plans and site allocations, enabling authorities to move from evidence of need to practical delivery of sites.

Neither agree nor disagree.

A) Please provide your reasons, particularly if you disagree.

CIH has been supportive of the reintroduction of new towns, and the use of large-scale developments to meet our significant housing needs. New towns provide an opportunity to create sustainable, accessible, affordable communities that meet local needs, and it is essential that the planning system is an effective framework to deliver these.

We would like to reflect wider points throughout the housing and construction sectors around skills and materials shortages, which may impact the delivery of these developments. Large projects such as new towns will take significant volumes of workers and materials to deliver, and there are concerns that this could exacerbate challenges for other local developments due to the overall shortage.

To ensure that these issues are taken into consideration at the planning stage, we would support recommendations from the Chartered Institute of Building (CIOB) to include additional wording to express the need for a skills and materials plan to be in place to demonstrate how new towns will be delivered, prioritising locally sourced skills and materials where possible.

Strongly agree.

We welcome the government’s commitment to rural housing throughout the NPPF and have received positive feedback on the changed definition of rural designated areas. The changes will ensure that greater numbers of parishes with populations of 3000 or fewer will now be able to have affordable housing contributions, and this will increase the supply of much-needed rural affordable housing.

It will also reduce the price of allocated sites, which will support SME developers to compete for land in rural areas, as well as reducing the reliance on rural exception sites.

However, it would be helpful to amend the wording of policy HO5 to reflect the introduction of medium sized developments in the NPPF as follows:

'...setting requirements for the type and mix of affordable housing (applying the definition in Annex B) required to meet identified local needs, including the minimum proportion of Social Rent homes required, as part of major and medium developments. In Designated Rural Areas, development plans may also set affordable housing requirements for small residential developments of fewer than 10 dwellings.'

Partly agree. 

CIH supports mandating Part M4(2) as the default standard for new homes. Previously, there was extensive consultation and agreement on this, that eventually led to a government commitment to introduce it.

This would enable local planning authorities to focus on assessing the needs for fully wheelchair accessible housing – M4(3) – and setting out the proportion of new homes required to that standard. 

Partly agree.

A) Please provide your reasons, and would you support an alternative minimum percentage requirement?

CIH has called for all new homes with limited exemptions, to be developed to Part M4(2). This would ensure that homes across all tenures are built to standards that will make any future adaptations cheaper and easier to install, thereby supporting people at whatever life stage where this might be required. We are also a member of the Housing Made for Everyone (HoME) coalition which made the same representation.

The demand for adaptations and support through the Disabled Facilities Grant is growing and is likely to continue to do so, reflecting our aging society and people living longer with limiting conditions, alongside the low accessibility standards in existing homes. The government has acknowledged this, and the benefits of safe adapted homes with the recent additional £50 million announced for this financial year, bringing funding to £761 million in 2025-26.

It is therefore important that we do not continue to build homes that will still require expensive retrofit and adaptation to increase accessibility in the future. Arguably it is a matter of equality to enable people with disabled members in the household to have the choice to live in appropriate accessible housing of whatever tenure (where affordable) that will enable them to engage with education, employment and social connections within their communities. Research for Habinteg Housing Association highlighted the social and economic benefits from increasing the delivery of Part M4(3) homes, with estimated savings being between £67,000 to £100,000 over ten years per household (depending on the household composition/length of habitation etc.).

CIH welcomes the commitment demonstrated in the government’s proposal to mandate 40 per cent of homes to be to the higher accessible and adaptable standard. However, recent analysis shows that eight out of nine local authorities would already deliver this proportion over the next decade. If the proposal for 40 per cent is introduced, it must be seen as an absolute minimum or it risks stalling current progress, with encouragement for local authorities to go beyond this. Even in that case, we would still be concerned that it will leave room for potential challenges on a site-specific level and further reduce the choices available to disabled and older people in certain neighbourhoods.  

If all new homes (with certain agreed exceptions) were required to be built to Part M4(2), this would provide a level playing field and expectation of all developers, and ensure that planning and design features are incorporated at the earliest stages, reducing any disadvantage from inclusion of the standard to any one developer, and any additional costs from it. It would also enable local planning authorities to concentrate their focus on assessing and planning for higher needs, covered by Part M4(3), and other specialist housing as required by current and future communities, making the local plan process smoother for councils, developers, and other stakeholders.

Strongly agree.

A) Please provide your reasons, particularly if you disagree.

Through our member engagement for this consultation, concerns have been raised about including military housing within the definition of affordable housing.

The primary concern regarding the proposal is the expansion of the Section 106 process to include military housing. Section 106 agreements deliver almost half of all affordable homes in England each year (UK Housing Review), and are a vital mechanism to build the homes we desperately need. We have welcomed the government’s recent commitments to ensure this process is effective in delivering homes through its roadmap. However, the roadmap, alongside this NPPF proposal, outlines that the Ministry of Defence (MoD) could purchase Section 106 homes from developers for military housing. This may result in developers prioritising the delivery of military homes over social rent homes, due to viability, and may also drive up the price of Section 106 homes as the MoD is bidding against registered providers, who have limited financial capacity. This could create a disincentive for registered providers to bid for Section 106 homes, further exacerbating the current obstacles in the process.

There have also been questions raised about cross-subsidy, with the MoD able to access government housing subsidy. The subsidising of military homes may result in lower costs for the MoD, but could have wider scale impacts on measures to resolve the housing crisis, and provide genuinely affordable homes for local people. Ultimately, the planning system and Section 106 is responsible for supporting affordable housing delivery, rather than military housing within the MoD’s remit. We would argue that including military housing within the affordable housing definition would not be appropriate and may have unintended consequences for the delivery of affordable homes for those most in need.

Although we are concerned about the unintended consequences of including military housing in the definition of affordable housing, we do support the need to have good quality, affordable military housing provision. Ensuring that military families live in safe, decent homes is essential, and we strongly support improvements to the quality and oversight of service family accommodation and welcome the alignment with the Decent Homes Standard introduced through the Renters’ Rights Act. We fully support the objectives of ensuring military accommodation is decent and safe; we feel that this would be better achieved through direct government investment and specific defence housing policy rather than through wider planning policy frameworks aimed at securing affordable homes for local communities. 

Strongly agree.

A) If so, what would be an appropriate minimum proportion and development size threshold taking into account development viability?

CIH has long advocated for an increased supply of social rent homes, which remain the only genuinely affordable tenure for many households in the greatest housing need. Ensuring that new development delivers homes that people on lower incomes can realistically afford is essential if housing policy is to respond effectively to rising housing need. We therefore support the introduction of a minimum proportion of social rent homes within new developments. Establishing a clear baseline expectation would help ensure that housing delivery reflects identified local need, rather than focusing solely on overall housing numbers. This would complement the government’s ambition to increase social rent provision through the Social and Affordable Homes Programme, which includes a commitment to deliver a significant proportion of homes for social rent.

Evidence suggests that a minimum requirement of around 20 per cent social rent on medium and large sites could deliver a substantial number of additional social homes while remaining broadly viable in many circumstances. CIH would therefore support 20 per cent as a national minimum expectation, with local planning authorities able to set higher proportions where this is justified by local housing need and viability evidence.

At the same time, we recognise the viability challenges facing some developers, particularly SME builders. It will therefore be important for local authorities to retain limited discretion where robust viability evidence demonstrates that the full requirement would prevent development from coming forward. Any such flexibility should be applied carefully and transparently to ensure that the overall objective of prioritising social rent homes is maintained.

Introducing a clear minimum requirement for social rent, while allowing appropriate local flexibility, would help ensure that new housing supply better reflects the needs of communities and contributes meaningfully to addressing housing affordability pressures.

We do not agree with the changes to temporary accommodation space standards. Whilst we understand the concerns on affordability, particularly in supporting local authorities to meet their legal duties in ensuring everyone has access to safe housing, we believe there are wider issues with reducing quality of standards in temporary accommodation. Temporary accommodation is rarely temporary due to the lack of supply of genuinely affordable homes, and the most common length of time for households with children to have spent in temporary accommodation was two to five years, according to the government’s latest statistics on statutory homelessness.

CIH has previously argued for national minimum standards for temporary accommodation, such as regular inspections and reporting of hazards, to bring this in line with the rest of the social housing sector. It is well evidenced that there is a clear lack of reliable data and oversight of temporary accommodation, which means we do not know the conditions of much of the existing supply (including space standards). However, there are multiple and consistent reports of homeless families being placed in overcrowded and cramped temporary housing. We would argue that the proposal to reduce space standards in such accommodation is premature given the lack of evidence of how many homeless households are currently living in these conditions. Furthermore, as noted above, stays in temporary accommodation too often span into multiple years; any reductions in space standards will therefore result in lengthy stays for families in homes that would normally be deemed unsuitable for them. It is therefore essential that reduced standards are not applied to temporary accommodation on this basis.

Whilst the provision of temporary housing for homeless households is something for the country to be proud of, as it stands now, we are ‘at risk of normalising’ the current holding system of households as a shadow tenancy, which produces adverse outcomes for families and for the public. Our members have flagged that in some circumstances current temporary accommodation may be converted into general needs homes, which is a desirable outcome. As a result, we must ensure that current space standards are upheld to allow for this conversion to long-term housing.

However, we would also argue that other forms of specialist accommodation, such as those housing and supporting individuals as they transition out of homelessness, such as Stepping Stones accommodation may benefit from flexibility of space standards. We know that these standards can create an obstacle for specialist, good quality providers in developing this form of accommodation.

Whilst we are extremely hesitant to advocate for a national, blanket flexibility of space standards, we would argue that for these specific, specialist schemes, local planning authorities (LPAs) may be best placed to determine if a development meets local housing needs, within the context of its supported housing strategy.

Strongly disagree.

A) If so, would it be desirable to limit the circumstances in which cash contributions in lieu of on-site delivery can be provided – for example, should it not be permitted on land released from the Green Belt where the Golden Rules apply? Please explain your answer.

The ‘Golden Rules’ of the NPPF demonstrate that green belt land must only be released when it is delivering affordable homes, with the understanding that more land needs to be released to build the homes we desperately need. As such, CIH supported the brownfield-first approach, with a review of green belt land where social homes can be built as required by the local authority’s discretion.

The Golden Rules were clear that developments should deliver higher levels of social and affordable housing. Yet, cash contributions in lieu of this on-site delivery of affordable homes does not fulfil these requirements. It instead creates an avenue for developers to build 100 per cent market value homes, often too expensive for local residents to afford. This goes against the spirit, intention and purpose of unlocking the green belt with the Golden Rules, and therefore green belt land should not be released if cash payments, in lieu of affordable, housing are proposed by developers.

We have expanded on our view of cash in lieu of affordable housing delivery in part b of this question.

B) If you do not believe applicants should have blanket discretion to discharge social and affordable housing requirements through commuted sums, do you think cash contributions in lieu of on-site delivery should be permitted in certain circumstances – for example where it could be evidenced that onsite delivery would prevent a scheme from being delivered? Please explain your answer

We support the introduction of medium sites within the NPPF to provide additional support for SME developers. We know that SMEs are experiencing difficulties with material costs and rising wages, which impact upon viability and delivery outcomes. Ultimately, we need all areas of the housing market to work effectively to resolve the housing crisis, and SMEs contribute significantly to meeting local housing needs by working in partnership, particularly on small sites. Please see our response to question 215 for further thoughts on the application of the building safety levy on medium sites.

However, we do not believe that applicants should have discretion on whether to discharge social and affordable housing requirements through commuted sums or cash payments in-lieu. Section 106 agreements produce nearly half (UK Housing Review) of all affordable housing delivered, and play a vital role in ensuring that we are building homes to meet local needs. At a time when we are facing a substantial lack of truly affordable housing, it is crucial that all avenues to delivering this housing are effective. This is supported by the government’s ambition to build 1.5 million homes in this parliament, with the ‘biggest increase to social and affordable housing in a generation’, and the recent government Section 106 roadmap.

Whilst cash payments in lieu may initially appear to be a like-for-like replacement of on-site delivery, the reality is very different. We know that local authorities have reduced capacity, resources, and financial headroom to build new homes, and it is therefore often the case that the commuted sums cannot be translated into the same number of new homes, compared with direct on-site delivery by the developer. For the local authority to use the commuted sums to build new homes, they will need to start from scratch: finding land, planning permission, contractors, and have the additional funds to get the scheme off the ground, which can create a significant time delay compared to the original scheme’s completion. For the developer to deliver on-site provision, there is existing land, planning permission, and a team already building homes on site, meaning that this would be faster, more effective, and better value-for-money.

A further unintended consequence of this is a lack of provision of mixed communities within new developments. Members have shared that onsite delivery of affordable housing on sites up to 50 homes (medium sites) are vital in ensuring they have mixed communities. Mixed communities can improve social acceptance, reduce stigma, and promote cohesion. The draft NPPF emphasises the need for a diverse mix of homes, which CIH supports, and this must include affordable housing within medium and large developments. By ensuring that developer must provide on-site delivery of affordable homes, we are demonstrating the need to integrate different groups and not reinforcing the perception that social housing tenants should be stigmatised and separated from the market sale homes on developments.

Whilst we argue that on-site delivery must always be the initial preference, we believe there must be some local discretion in practice. From engagement with our members, we understand that cash payments in lieu of onsite delivery can occasionally be of greater benefit for the local authority and would be preferred. As such, rather than the applicant having discretion on choosing cash payments in lieu, we believe the local authority should have some discretion in the decision for on-site, offsite or cash payments in lieu of delivery. In these specific circumstances where cash payments would be preferable and more beneficial, there must be certain rules in place:

• Any cash payments must be ringfenced for new affordable housing delivery. Section 106 agreements are crucial in delivering much-needed new homes, and therefore all money made in contribution for this aim must be protected.
• Local authorities must be encouraged to work with registered providers to spend the cash payments. Currently, developers receive any unspent payments made under Section 106, which results in no new affordable housing. This cannot continue. Instead, local authorities should work with local partners to deliver the ringfenced affordable housing. This could be done in a variety of ways, depending on local authority capacity and resource, such as working with a preferred registered provider partner, creating a pool of all Section 106 cash payments for registered providers to bid for, or working with Homes England or the Greater London Authority. There must be an encouragement for local authorities to do this efficiently and spend the money to build new homes, such as a time requirement if they are unable to build the homes directly. We believe any time requirement must be decided in consultation with local authorities and representatives working on the ground, to ensure this is realistic and practical.
• Rural communities are some of the most at risk of the proposed changes to Section 106 delivery on sites of 10-49 homes, as they are often smaller developments. The proposed changes could have a significant negative impact on rural housing provision, when rural housing needs are acute. Whilst onsite delivery is preferred, where local authority discretion opts for cash payments in lieu of onsite delivery, rural communities must be specifically protected. We would encourage the introduction of a rural ‘cascade’ approach, to ensure that priority of spending of the cash payments would first deliver rural affordable housing in the rural community it was raised, followed by support for other surrounding rural communities in the area, and finally to support affordable housing elsewhere in the local plan area. This would ensure that rural housing is still delivered to meet local rural needs.

We would also like to note concerns raised about the wording of policy HO8. The above requirements apply to medium sites, as newly defined in the NPPF consultation. However, the wording in HO8 1.b is more vague and allows for cash payments in lieu of onsite delivery wherever it can be ‘justified robustly’.

Whilst we acknowledge this has been in place previously, we are concerned that within the current climate of Section 106 delivery (as noted in the government’s roadmap), this could be misused on a wider scale and result in a reduction in new affordable homes. From discussions with our members, some large developers will routinely renegotiate Section 106 agreements to reduce affordable housing contribution, often due to viability arguments. Local authorities often have limited staff and expertise to renegotiate with large developer legal teams, and it could be argued that many developments could be ‘justified robustly’ against the delivery of affordable homes through Section 106 agreements. We would therefore suggest that the government review this wording in the NPPF, to emphasise the need for on-site delivery and/or provide additional guidance for local authorities where cases are being renegotiated on viability terms.

Overall, at a time when we desperately need truly affordable homes, it is concerning that this could be undermined by guidance that will result in less homes delivered through on-site delivery.  Our members and much of the sector are concerned about the impact of these proposals within the NPPF and we urge the government to rethink the policy. 

As stated in our response to question 67b, we would argue that the policy for applicants to decide to pay cash payments in lieu of onsite delivery of homes will be damaging, particularly for rural areas. This will have significant impacts upon the numbers of affordable homes delivered as cash payments largely do not result in the same level of delivery as developer onsite contributions.

Please see our answer to question 67b for further details.

It has been raised to us that calculating the appropriate value of cash contributions in lieu will be complex and resource-intensive for local authorities already straining under financial and capacity pressures. With each site being unique, these calculations will be complicated and will add another layer of work required within a planning application, potentially causing delays.

More guidance is required for local authorities who decide to use cash contributions in lieu in exceptional circumstances (as explained in our response to question 67b), particularly on how these should be calculated, how to handle developer negotiations effectively, and how these funds can be ring-fenced and used effectively (again see our response to question 67b on use of commuted sums).

Partly disagree.

A) Please provide your reasons, particularly if you disagree.

As stated in our response to question 67b, on-site delivery is preferable in the majority of cases. The purpose of Section 106 agreements is to mitigate the impact of development on the local community, by providing affordable housing to meet local needs. Offsite delivery could therefore be far removed from benefiting the local community impacted by the development. However, where local authority discretion decides that offsite delivery would have more positive impacts with affordable housing delivery, this will be generally preferred to cash payments in lieu.

Please also note our proposal in question 68b on rural housing, which could have significant impacts if offsite delivery did not directly benefit rural communities. The ‘cascade’ approach recommended would mitigate these concerns.

Agree.

A) Please provide your reasons, particularly if you disagree.

Specialist housing for older people should be located where residents can access services and amenities with ease (by walking or wheeling). This depends not only upon the accessibility of the home but also the neighbourhood, with appropriate physical features that support mobility (including adequate paving, resting places etc.).

This makes it suitable for town centre sites, but consideration should also be given to urban extensions with public transport links. Some models such as Integrated Retirement Schemes which include health and other additional facilities require more land and therefore should be considered within larger development schemes incorporating appropriate infrastructure.

Partly agree.

A) Please provide your reasons, including what other changes may be needed to increase their uptake?

We support the government’s commitment to rural housing in the proposed NPPF. However, CIH supports calls for the introduction of a Rural Exception Site (RES) Planning Permission in Principle policy. Without this policy, we are concerned that the positive inclusion of RES in NDMP HO10 will be undermined and less effective, as well as impacting the government’s support for rural housing in the new Social and Affordable Homes Programme.

RES schemes face considerable delays in the planning process, which in turn reduce the appetite for rural housing delivery with increased risks and costs for providers to take on these schemes. This has a detrimental effect on rural housing delivery and does not tackle the acute rural housing needs facing these communities.

Whilst the generic Permission in Principle (PiP) extension is argued to support this, it will ultimately not be used for RES schemes. LPAs are unlikely to approve an application submitted through the generic PiP as it does not require the application to state the tenure mix, which could then be used to deliver a scheme with no affordable housing provision. This will also impact the prices landowners are willing to sell at to make the RES site viable, and communities are unlikely to support a scheme that could result in only market housing being developed. With this uncertainty, LPAs will not approve these applications in RES, with concerns that affordable housing will not be delivered.

This is counterproductive to the aims of the generic PiP and will result in reduced rural affordable housing delivery. Instead, a specific RES PiP would mitigate these impacts and ensure that RES delivery is more efficient in meeting rural housing needs.
We therefore encourage the government to amend the Town and Country Planning (Permission in Principle) Order 2017 to include a RES PiP that requires the applicant to state the location, number of dwellings and proposed tenure mix.

Strongly agree

A) Please provide your reasons, particularly if you disagree

CIH has consistently argued that First Homes will not deliver the necessary affordable housing provision required and we support the government’s proposals in the NPPF to reduce this to ensure local authorities can focus on affordable homes that will best meet local housing needs.

Partly agree. 

A) If so, which approach and value as set out in the narrative for policy HO10 of the consultation document is the most beneficial for government to set out?

We agree that setting a benchmark value for RES sites for viability assessments would avoid delays and difficulties in securing sites. There have been mixed views on what the value for this should be, as a potential value of £13,000 can vary in its value (too high or too low) based on geographic differences. It may be best to therefore implement a range, or link to another metric such as land value (existing use or agricultural). 

Neither agree nor disagree.

A) Please provide your reasons, particularly if you disagree.

CIH previously responded to the government’s working paper on speeding up build out, and outlined our key points. We welcome the commitment to tackling barriers to development, such as build out rates, but all measures must be clear, proportionate and implementable, with safeguards to prioritise incentivising affordability. It is essential that the focus must be on improving the working relationship between local authorities and developers, for early engagement to ensure that homes are built in an effective and positive way to meet local needs.

We have also been clear that increased capacity and resource in LPA teams is essential to speeding up development. Recent Savills research found that whilst planning reforms have improved the number of planning applications being submitted, the processing of these applications is still delayed due to the lack of capacity in LPAs. It is therefore necessary to look at how we can speed up the development of affordable homes through all parts of the planning and development process, and to ensure LPAs are resourced sufficiently to implement and approve increased numbers of applications coming through as a result of the government’s planning reforms.

Partly agree.

A) Please provide your reasons, particularly if you disagree, what alternative approach would you suggest?

We agree with the creation of a standalone chapter on securing clean energy and water. It is essential that the development of local plans is synchronised with ongoing work to improve water and energy security, on both the demand and supply sides. Research supported by CIH Northern Ireland demonstrates the extent to which a lack of water infrastructure can limit housing supply, a challenge that applies across the whole of the UK, and we therefore particularly welcome the focus on water infrastructure in the revised NPPF.

We would make the following comments:

• It is vital that local plans are aligned with Regional Energy Strategic Plans (RESPs) the Strategic Spatial Energy Plan (SSEP), and, where they exist, Local Area Energy Plans (LAEPs). In particular, the National Energy System Operator (NESO) must ensure it has a good understanding of relevant local plans and SDSs, including the timelines for forthcoming local plans and SDSs, when developing the demand inputs and demand sensitivity testing for RESPs and the SSEP. There is a risk that NESO’s work and timelines may not properly capture the status of recently updated or forthcoming local or strategic plans, potentially leading to a mismatch between SSEPs/RESPs and actual future demand. To avoid this, emphasis must be placed on NESO’s capacity to engage locally at least as much as on early engagement by local planning authorities.  
• In our experience, described in our responses to Ofgem’s prior consultations on RIIO-ED3 and connections reform, the most persistent challenge with the type of early engagement referenced in W1 is the (in)visibility and interoperability of data produced by utility providers, regulators, and network operators. We welcome Ofgem’s ongoing work to improve this through its work on RIIO-ED3 and other associated workstreams, and we are encouraged by recent statements from NESO that they are placing significant weight on the need for transparency, visibility, and accessibility of data. Despite this, it would be helpful for the government to explore other ways that accurate energy and water network data can be made available to local planning authorities to supporting their plan-making. 

Partly agree. 

A) Please provide your reasons, particularly if you disagree.

We broadly agree, and would make two comments:

• As above, local planning authorities will require clarity on how their requirement to identify areas suitable for renewable and low-carbon energy, and electricity network infrastructure, aligns with NESO’s work on RESPs and the wider Strategic Spatial Energy Plan (SSEP).
• The practicalities of decentralised energy supply should not be underestimated. CIH has concerns that the complexity and cost of the forthcoming Heat Network Technical Assurance Scheme (HNTAS) could disincentivise the planning and development of new homes connected to new (or existing) heat networks. Decentralised energy systems can offer clean, affordable, and efficient heat, however, are more unlikely to do so without a wider approach to HNTAS that supports not-for-profit developers with the cost and complexity of meeting the technical standards. 

Partly agree. 

A) Please provide your reasons, particularly if you disagree, and any changes you would make to improve the policy.

Nothing to add. 

Partly agree. 

A) Please provide your reasons, particularly if you disagree.

Nothing to add.

Partly disagree.

A) Please provide your reasons and preferred alternatives.

CIH supports the policy to establish a ‘default yes’ on development around train stations in existing settlements and around ‘well-connected’ train stations. We are particularly pleased to see the greater links between housing and infrastructure throughout the NPPF proposals, which CIH has long supported. In order to encourage public support and create sustainable communities, it is vital that housing developments have access to transport, GPs, schools and roads, as well as access to nature with green and blue spaces.

We would like to suggest an amendment to the definition of ‘well-connected’ train stations. Through our engagement in this consultation, whilst there has been broad support for this policy, there has been concern raised that the current definition will exclude many rural areas that could benefit from the policy, in order to boost the development of much-needed rural affordable housing.

We believe that amending the definition from top 60 Travel to Work Areas to top 80 will create vast benefits for a greater number of communities, without significantly changing the intention of the policy. This has been demonstrated by analysis from Lichfields.

131. Please provide your reasons, particularly if you disagree.

Please see our response to question 67a on use of green belt for schemes not delivering on-site affordable housing, which we argue should not be permitted under the Golden Rules policy, as well as our response to question 141 on the affordable housing floor.

Strongly agree.

As stated in our response to question 66a on use of green belt for developer contributions, it is vital that all developments on the green belt using the Golden Rules deliver the intended boost for social and affordable housing provision. We therefore support the introduction of an affordable housing ‘floor’ within the Golden Rules, alongside local authority discretion on necessary levels of affordable housing through its local plan.

A clear ‘floor’ would also prevent land prices from escalating on these green belt sites, where developers could otherwise reduce affordable housing contribution through viability tests and pay higher land prices. 

A) Please provide your reasons, particularly if you disagree.

CIH has long supported the need for healthy homes and well-designed places, to create sustainable communities. Please see our response to question 158 on healthy communities for more information.

Agree.

A) Please provide your reasons, particularly if you disagree.

Delivering better health and wellbeing for local residents should be a priority of development plans, and incorporate local green space, recreational and community spaces and facilities, as well as good connections to health and other services.

Ideally this should draw on the range of experience amongst residents as well as partners providing housing and other services, to maximise the opportunities to incorporate and embed features that support wellbeing across communities. For example, planning for specialist housing models for older people, as well as contributing to wellbeing for the residents specifically, can provide facilities for the wider community such as health surgeries or community spaces, enabling a wider public benefit in the local area. 

CIH supports the TCPA’s Healthy Homes principles, and calls for all new homes to be developed to higher accessibility and adaptability standards (Building Regulations Part M4(2)). These measures are fundamental to delivering homes that are safe. Decent and enable people to maintain dignity, wellbeing and maximise their independence.

Partly agree.

A) Please provide your reasons, particularly if you disagree.

Nothing to add. 

Strongly disagree.

A) Please provide your reasons, particularly if you disagree.

The sequential test should not be disapplied from developments at risk of surface water flooding. We agree with the position set out by the TCPA; specifically, that a more precautionary policy approach is required to direct vulnerable developments away from flood risk areas.

We agree that there are clearly circumstances where innovative developments can be built safely in areas of flood risk. CIH has previously worked with Zed Pods, a developer of affordable modular homes that specialises in the design and construction of flood resilient homes. However, the sequential test remains a vital tool and one that should be required for developments at risk of surface water flooding.

This is primarily because of the growing risk of volatile, unexpected surface water flood events in the future. Environment Agency analysis shows that the total number of properties at risk from surface water flooding in England is 4.6 million. The number of properties at high risk is 1.1 million, and there are now three times as many properties at high risk of flooding from surface water than there are from flooding from rivers and the sea. With climate change, the Environment Agency estimates the number of properties at risk of surface water flooding will rise to 6.1 million (an increase of one third from 4.6 million today) and the number of properties at high risk will increase to 1.8 million (compared to 1.1 million today). In addition, the proportion of high-risk properties flooding to depths of 60cm or deeper could increase by over two thirds (73 per cent) between 2040 and 2060.  

In part, these changes will be driven by precipitation events that are longer in duration, more intense, and more frequent compared to the present day. Scientific evidence is clear that, as a general rule of thumb, each 1 degree rise in global temperature increases UK winter rainfall by a compounding seven per cent.

There is also a significant risk that in seeking to disapply the sequential test from developments at risk of surface water flooding, other priorities in the NPPF could be undermined. In relation to health and wellbeing, research has consistently demonstrated the links between experiencing a flood event and experiencing mental ill-health. This also has a knock-on effect on the economy, with a recent study, published by the government, estimating the monetised cost of mental ill-health arising from flooding to be £1,878 per adult per flood for shallow floods (less than 30cm of water in a home) to up to £4,136 per adult per flood for deeper, more severe floods (when water is over 1 metre deep).

These costs arise from treatment, medication, and loss of employment or earnings due to time off work. Flooding also has considerable macroeconomic impacts, such as through the cost to insurance companies: in 2025, the cost of domestic flood claims rose by 38 per cent (to £312 million), and the average flood pay-out to a homeowner also rose significantly by 60 per cent, reaching £30,000. 

In this context, disapplying the sequential test from developments at risk of surface water flooding is not appropriate or desirable. The sequential test should be retained for areas at risk of surface water flooding in policy F5. 

Yes.

CIH understands the importance of supporting SME housebuilders and addressing the viability pressures that can disproportionately impact smaller developers. A diverse development market, including SME participation, is integral to sustaining housing supply across different areas and local markets.

CIH has previously supported the introduction of the Building Safety Levy as part of the post-Grenfell funding framework. In our response to the Building Safety Levy consultation (January 2023), we welcomed the levy's aim of raising funds for remediation and avoiding costs being passed on to leaseholders. We continue to support the principle of the levy and the need to maintain a sustainable funding base for remediation, consistent with our wider work on cladding remediation and post-Grenfell reform.  

Therefore, we would support evidence-based exemptions that fully consider housing needs and development size. 

We have been clear in our previous work that remediation must be properly funded and that safety should not be compromised; therefore, we have concerns that blanket exemptions within the new medium sites category pose a threat to the funding available for the wider remediation programme.

However, we also recognise the concerns legitimately raised by SME representatives and understand that if the government concludes that SME-led schemes are unduly impacted, a more proportionate and evidence-led approach may be necessary. We would welcome an approach that considered some form of tapered levy rates or a phased introduction to help address viability pressures, while still ensuring a fair and broad contribution to the levy.

We would also welcome the government undertaking and publicising an impact assessment to fully understand the impact of such exemptions, including the projected effect on remediation funding capacity and the pace of works.

For more information, contact Megan Hinch, CIH policy manager, megan.hinch@cih.org 

To find out more about the consultation, visit the government website.