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RTPI Cymru's response to the Senedd Cymru: Social housing supply consultation

On 21 January RTPI Cymru responded to the Senedd Cymru: Social housing supply consultation. Read the response below.

For the Committee’s information, through our 2026 election Planifesto (our manifesto asks for the land use planning system in Wales) we are making several asks for the incoming Senedd Cymru government. These include supporting an ambitious and agile plan-led system that delivers, championing well-designed places with access to quality homes and infrastructure where communities thrive, and joined-up action to address the climate and nature emergencies. Our Planifesto calls for these asks to be underpinned by a commitment to invest in planning and planners, without which Government priorities cannot be delivered.

 

Work underway to meet the current 20,000 target and to ensure a pipeline post-2026; 

Welsh Government statistics show, between 2024 and 2025, 3,643 additional affordable housing units were delivered across Wales. This is a 12% increase on the previous year and the highest total since data was first recorded in 2007 to 2008 Affordable housing provision: April 2024 to March 2025 [HTML] | GOV.WALES. However, over that same time period, overall numbers of new homes fell - “3,798 new dwellings were started, 26% fewer than in the previous year. This marked the lowest number of new dwelling starts on record”. New house building: April 2024 to March 2025 [HTML] | GOV.WALES

In our RTPI Cymru Planifesto we have called for the reintroduction of housing targets and monitoring of delivery to support this target and pipeline post 2026. It is vital that Local Planning Authorities and the Welsh Government all provide up to date accessible statistics and data that build a strong evidence base and support monitoring and improvement. Measuring outcomes, along with spatial targets for different parts of Wales is an integral part of the long-term delivery of social housing. The RTPI’s Measuring What Matters Research (2020) considers how the outcomes of planning decisions can be measured, which goes beyond simple metrics like the number of homes delivered to encourage analysis in terms of placemaking aspirations and social, economic and environmental value, in order to track and improve the real impact of planning in Wales. This could support better recognition of the quality of homes, rather than focusing solely on numbers.

A well-resourced plan-led system is essential to support housing provision, including social homes. See our comments on resourcing the planning system under the heading ‘Issues relating to planning’ below.

We note in response to Committee recommendations 1 and 2 Welsh Government have provided the following evidence: data-showing-progress-towards-the-20000-affordable-homes-target-april-2021-to-march-2027.xlsx. This is a useful resource and should be kept updated and accessible to stakeholders in the future.

 

Progress towards implementing the recommendations of the Affordable Housing Taskforce

RTPI Cymru sits on the implementation group for the Affordable Housing Taskforce and has attended two meetings and one working group meeting (latter was about increasing SME involvement and included Welsh Government, Design Commission for Wales, Development Bank Wales and RTPI).

This involvement is welcomed however progress feels slow with few tangible changes to date. We understand that the Government's window of opportunity to make changes is curtailed by the forthcoming pre-election period, which inevitably impacts on the pace of progress and provides a lack of certainty.

External to the Implementation Group there is wider progress, which is being fed into the Implementation Group, for example work by Town Legal LLP on standardised S106 agreement templates and a roundtable on 26 January on planning and Sustainable Drainage Approval Bodies (SAB) arranged by Hugh James Solicitors. The former example highlights that the issues around slow and unduly complex S106 agreements is not unique to Wales. The latter example demonstrates a wider industry desire to make progress on the Taskforce recommendations.

 

The extent to which work to increase supply is being undermined by other policy goals; 

The land-use planning system plays a crucial role in delivering sustainably located, quality and safe homes alongside many interlinked policy areas which cannot be considered in isolation. There are close links between the provision of social housing, planning and other sectors such as health and transport.

Although debate often focuses on the planning system, discussion and research have shown, obstacles in delivery can be found in many areas, such as the markets for buying and selling land, and for buying and selling houses, and in terms of social housing in procurement practices. The provision of infrastructure is another example. However, the lack of a housing target for Wales and the cancellation of TAN1 has had the unintended consequence of creating a plan-only system in Wales rather than a plan-led system. In this context, there is no safety valve to continue to deliver urgently needed homes if LDPs are delayed. Ironically, the removal of a provision for un-planned housing sites to come forward has resulted in a default position on non-delivery, which is a more politically comfortable position for locally elected members than making the difficult and controversial decision to allocate land for development and adopt an LDP. In the past, locally elected members understood that they needed to adopt LDPs to proactively manage and shape where development happens. That incentive no longer exists. Without adopted plans and allocated sites, delivery stalls. 

Some Councils are seeking to increase energy standards for new homes via local planning policies, which is admirable but risks inconsistent approaches across Wales that would cause difficulties for the development industry. Ideally this issue would be addressed via Welsh Government leadership with national planning policy, or better still, via Building Regulations. RTPI Cymru’s Planifesto calls for the raising of standards to achieve low/net zero carbon development by updating Building Regulations, with the aim of simplifying plan-making and ensuring consistency and certainty for developers as well as achieving decarbonisation and helping to address fuel poverty.

There continues to be a need for an adequately resourced and committed partnership approach to housing supply and delivery, in line with the Well-being of Future Generations (Wales) Act 2015.

 

How the Welsh Government is developing its strategic role in relation to land; 

The Committee recommended (recommendation 5) that the Welsh Government establishes a national development corporation to lead on delivery of large-scale strategic sites and to support alignment of housing and regeneration efforts. This recommendation was rejected by Welsh Government. They felt this role could be provided by their Land Division which has developed over time, now forming part of a newly formed Place Division, combining land and regeneration functions to deliver proactive place-based approaches. However, we question the capacity and resources available to the Land and Place Division to ensure this role is fully carried out.

RTPI Cymru’s Planifesto, published in October 2025 is calling for the creation of a national arm’s length delivery body to assemble land and co-ordinate development, ensuring that land use, transport and infrastructure are aligned in terms of planning, funding and delivery. 

We note the Committee’s recommendation 15, recommending that Welsh Government work across the public sector to ensure greater transparency in public land ownership and bringing information and expertise into a central place. We also note the work of Ystadau Cymru in this respect. It would be useful if a register of all publicly owned land in Wales were compiled, published and kept up to date, to enable it to then be sifted for suitability for development. However, it must be recognised that not all land in public ownership is in an appropriate location for development. It is important that sites allocated in LDPs are included because they are in the best location, not simply because they are in public ownership. The current plan-making process relies on landowners promoting their land for inclusion in LDPs, which does not always provide the optimal sites for allocation.

 

The availability of finance; 

The principle of front-loading the LDP process to seek to provide certainty of deliverability and infrastructure investment is admirable but it has had the unintended consequence of excluding SMEs from the plan-making process. The costs of promoting sites and associated risks mean that only the volume housebuilders and large Registered Social Landlords can engage in the process.

RTPI Cymru welcomed the recent discussion around the increase in planning application fees. It is essential that Councils show leadership and reinvest that extra income into improving the planning services. Ideally, there would be a primary focus on the LDP strategy and identification of sustainable locations for growth, followed by use of CPO powers if land owners are not willing to bring their land forward.

The principles of transit-oriented development are fully supported, however it must be recognised that a proportionate level of housing growth is needed in rural areas to sustain communities. The majority of Wales is rural and served poorly by public transport. Policy aspirations need to be applied sensibly in a way that works outside of Cardiff and Wales’ cities.

 

Issues relating to planning

The role of planning is to enable the right development in the right places and to plan for the long term to meet policy aspirations including the provision of housing, including social housing.

A well-resourced, plan-led, positive planning service can deliver Council and Welsh Government objectives, which, if properly encouraged and effectively organised can bring together objectives across services and sectors. Planners have an important, proactive role as drivers of change, but collaborative working is needed across sectors, with resources and funding in place to support this. It is essential that the strain the public sector is currently under is recognised in developing policy and target setting, so that achieving those targets and ambitions is realistic. Sufficient resourcing of public bodies and investment in key skills and specialisms for the longer term are all important aspects of meeting targets. 

RTPI Cymru has been commissioned by the Welsh Government to produce an evidence-based report on public sector planning resources in Wales. Its remit covers LPAs, PEDW, NRW’s planning division and the Welsh Government. The research makes some stark findings and is due to be published in February 2026.

 

Progress on developing the workforce.

RTPI Cymru has long called for the proper resourcing of planning services. However, until now we have lacked the hard evidence and complete overview of resourcing issues to support the identification of the changes required to address this problem. RTPI Cymru has been commissioned by Welsh Government to investigate current capacity and resources within public sector planning services in Wales. This work will be published in February 2026.