The NLA Housing and Planning Expert Panels came together during the government's public consultation on the revised National Planning Policy Framework, drawing on combined expertise across housing delivery, design, planning policy and development to submit a joint response. The government's renewed commitment to housing delivery is genuinely welcome. After decades of chronic undersupply, the ambition to plan more proactively, increase density around accessible locations, and streamline the system is broadly the right direction of travel. As panel chairs, we are united in wanting a framework that delivers well-designed, genuinely affordable and sustainable homes at the scale and pace this country needs; and it is in that spirit that we offer the following observations. 

Density Done Properly 

The aspiration to maximise the use of land around accessible locations is one we share. However, minimum density thresholds as currently proposed would benefit from refinement. A single figure applied across PTAL 0–1 areas does not account for the full range of site conditions, heritage context, flood risk and local connectivity that responsible planning must consider. A more sophisticated approach: one that reflects residential typology, regional viability and transport infrastructure; would be more effective in delivering the right homes in the right places. 

Community trust matters here too. Experience shows that when communities are not properly engaged, delivery becomes harder. Any new density tools should be accompanied by clear expectations for meaningful engagement throughout design stages, not just at pre-application. 

Energy Standards and Sustainability 

The NPPF should do more to drive improvement in energy and sustainability standards. A clearer, more consistent definition of "net zero" would help address inconsistency across local plans, and a tiered approach; actively incentivising higher performance, not just setting a minimum; would better reflect the government's ambition. 

We would also encourage greater weight to be given to retrofit and refurbishment. The carbon savings achievable through refurbishing existing buildings are significant and currently underweighted; the framework should explicitly encourage refurbishment over demolition where it delivers better carbon outcomes. 

London's Specific Challenges and Accessible Homes 

As a national document, the NPPF applies across diverse contexts. We would encourage greater recognition of major metropolitan areas such as London, where complex urban environments require a more nuanced approach. Referencing a national equivalent of TfL's Public Transport Accessibility Level (PTAL) rating; a measure of how well a location is served by public transport; would be a helpful step. 

On accessible housing, we recommend that M4(2) compliant homes (adaptable and accessible standard) be required at 100%, with a "comply or justify" approach applied to M4(3) wheelchair-standard provision. 

A Significant Gap: Homelessness and Housing Need 

One meaningful gap in the revised NPPF is its treatment of homelessness. With over 350,000 people recorded as homeless in England and rough sleeping continuing to rise, homelessness statistics and housing register figures should be formally embedded in local plan-making as evidence of need. Emergency and temporary accommodation should be explicitly included within the NPPF's definition of housing need; their current absence reflects an incomplete picture of the housing crisis. 

The revised NPPF has the potential to be genuinely transformative, and we are committed to supporting that ambition. With a more sophisticated approach to density, clearer direction on sustainability, and fuller recognition of housing need; including the needs of the most vulnerable; the framework can deliver the homes and places communities across the country so urgently need. We look forward to continuing to contribute to that conversation.