On Tuesday 30th July the Government published changes to the National Planning Policy Framework (NPPF) that have been pending since the Labour party manifesto and more recently the King’s Speech.
A consultation on the proposed reform to the NPPF runs from Tuesday 30th July until Tuesday 24th September – over an 8-week period. The consultation is part of the wider consultation where the Government is also seeking views on increasing planning fees, local plan intervention and criteria and appropriate thresholds for certain Nationally Significant Infrastructure Projects.
Headline changes to the NPPF:
Overall
- Aligning with the objectives of supporting an increase in house building (1.5 million homes) and delivering economic growth;
- Reference to effective strategic planning playing a vital role in delivering sustainable growth;
- Cross boundary collaboration is strengthened in advance of legislation to introduce mandatory mechanisms for strategic planning covering functional economic areas within the next 5 years;
- Higher expectations to have an up-to-date Local Plan to plan for the number of homes communities need, so people can engage in how, not if homes are built; and
- A taskforce to lead on a new generation of new towns to deliver large scale communities of at least 10,000 dwellings.
Updating the Presumption
- Clarification on the policies that can be considered out-of-date as expressly relating to the ‘supply of land’;
- Importance of the location and design of development and affordable housing considerations when applying the presumption;
- There has, however, been no clarification to address the concerns around whether presumption itself has weakened and consistency in decision making.
Changes to Housing Need
- A new two-step approach standard method:
- Take 0.8% of the current stock of the area;
- Apply an uplift, based on a three-year average of the median workplace-based affordability ratio, with an increase of 15% for every unit above four.
This method generates a national total of around 371.5K net additional homes per annum compared to the current method amounting to 305.5K.
- Inclusion of Social Rent, and ‘looked after children’, included in the housing mix paragraph.
- Proposed change to support delivery of ‘mixed tenure sites’, with benefits identified.
Housing Land Supply
- Re-introduces the requirements for LPAs to demonstrate five year housing land supply, even when the adopted plan is less than five years old.
- 10% buffer for rarely used ‘annual position statements’ has been removed, whilst the 5% buffer returns alongside the 20% buffer for LPAs that have scored below 85% in the housing delivery test.
- Removal of the requirement to demonstrate 4 year housing land supply for plans that had been submitted or reaches Reg 18 or 19, restoring consistency for LPAs regardless of plan progress.
Green Belt
- Introduction of ‘Grey Belt’ land which is defined as areas of previously developed land and/or land that makes a ‘limited contribution’ to the Green Belt purposes.
- Grey belt land raised the potential that urban fringe land could be classed as Grey Belt, even if the Green Belt Review finds that the site performs moderately against the Green Belt purposes.
- The requirement for Green Belt Reviews to be fundamental to release land for development to support the increase in housing delivery.
- Definition of development that is not inappropriate in the Green Belt includes ‘Grey Belt land in sustainable locations’ and where LPAs are unable to meet the 5 year housing land supply, or falls below the 75% Housing Delivery Test threshold or ‘there is a demonstrable need for land to be released for development of local, regional or national importance’. In the context that many LPAs do not have a 5-year housing land supply this is a very powerful tool for unlocking housing delivery in areas that were previously ‘untouchable’.
The changes are supported in the sense of increasing the supply of new homes across the country which is critical. We will be responding to the consultation and are more than happy to advise others on potential implications from the changes suggested. For further advice please contact: Jessica Hird