Department for Levelling Up, Housing and Communities National Planning Policy Framework
Department for Levelling Up, Housing and Communities
National Planning Policy Framework An Iceni Projects Briefing Note
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Department for Levelling Up, Housing and Communities National Planning Policy Framework
National Planning Policy Framework After a year’s wait followed by an additional week of suspense, the revised NPPF has finally landed, with what eventually hit the desks this week closely echoing what the Government proposed last winter. The past year has been a political whirlwind and we can see directly how that pressure has fed through to amendments. Notable additions include measures to control density increases which would be ‘wholly out of character’ (Para 130) – a nod to Theresa Villiers MP’s concerns, a softened approach towards meeting housing needs in Green Belt areas, and what appears to be a curious nod to the Isle of Wight’s unique demographic characteristics (Fn25). The spotlight is on housing. The Government hopes reforms will accelerate local plan preparation, whilst industry is abuzz with fears of a substantial drop in housing delivery. Some of our oldest local plans are in Green Belt areas around our major conurbations, concentrated particularly in the greater South East. The carrots to incentivise plan production include the explicit statement that there is no requirement for Green Belt boundaries to be reviewed or changed as part of the plan-making process (Para 145) and that agreements to meet unmet needs from our cities are voluntary (Para 62). Areas with an emerging plan will now only need a 4 year land supply over the next couple of years, where certain conditions are met . There is now no need for councils to undertake a 5 year housing land supply calculation for 5 years following the adoption of a plan. Beyond this, the 5% buffer has been scrapped, though the 20% buffer remains for areas where the
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Housing Delivery Test (HDT) score is below 85%. As the map on page 4 shows, the 60 areas where the latest HDT scores engage that presumption are generally focused on Green Belt areas and to a lesser degree those impacted by nutrient neutrality issues. Additionally the Para 11d presumption can now be bypassed where a neighbourhood plan (with allocations) has been made in the last 5 years, regardless of the land supply or HDT status. Overall, these changes seek to make it more difficult to secure residential consents on greenfield sites outside of the planmaking process. The Government seems to have considered some of the consultation feedback when it comes to plan-making. Plans must still be ‘justified’, grounded in evidence, based on effective joint working; and they still need to meet objectively assessed needs where is sustainable to do so. The wording of the soundness tests and Para 11 presumption favouring the meeting of development needs remain unchanged. These points are significant, but there appears to be a degree of conflict between these parts of the framework and the statement that there is no requirement for Green Belt boundaries to be reviewed or changed. It will be very interesting to watch how this is interpreted – with the Mole Valley and Elmbridge Local Plan Examinations very much ones to watch. Alongside the NPPF, the Government plans to intervene in areas with some of the oldest local plans – Amber Valley, Ashfield, Basildon, Castle Point, Medway, St Albans and Uttlesford – which will need to provide a plan timetable to the Secretary of State within the next 5 weeks. West Berkshire’s Local Plan cannot be withdrawn and intervention within London is on the horizon.
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Department for Levelling Up, Housing and Communities National Planning Policy Framework
The Government is also proposing a new urban quarter in Cambridge and further ambitious development around the city with tens of thousands of new homes and the prospect of a new development corporation to drive this forward – although the two local councils feel poorly engaged so far. As for assessing housing needs, we may need to wait for further detail in the PPG, but at this stage the changes are by no means radical. The standard method is identified as an ‘advisory starting point’ but it has never been mandatory, and an alternative approach would need to continue to take account of demographics alongside market signals. No provision is made for adjustments for past over-delivery, although there is explicit recognition that councils can choose to plan for above the identified housing need to support economic growth or infrastructure investment. In some areas, the impact of escalating homelessness and social care costs on council budgets could also sway decisions on housing targets.
Terms of Reference have not yet been published, Gove indicated that the brief is to consider whether the current group of consultees is right, whether performance reporting is effective and timely, and whether changes to the system such as the absence of a reply within an appropriate timeline being considered a green light, are warranted. Hopefully those mired in lengthy planning casework will have the opportunity to input to this review.
For smaller greenfield sites, the First Homes Exception Sites Policy persists (see Fn36), with Para 70 now explicitly encouraging selfand custom-build developments, potentially broadening prospects for this sector. Beyond housing, the changes are minimal. We see an emphasis on energy efficiency (Para 164), mention of aesthetic architecture and mansard roofs, but no significant shifts in planning for economic growth or town centres, despite the challenging economic backdrop. Of particular interest in Gove’s speech was the announcement of a rapid three-month review of the statutory consultation system. Whilst the
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Key Contacts For further information, please contact:
Nick Ireland Director, Economics E: nireland@iceniprojects.com T: 07917 417 834
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Department for Levelling Up, Housing and Communities National Planning Policy Framework
Housing Delivery Test 2022 Consequence None Action plan Buffer Presumption Nutrient Neutrality Green Belt
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