The National Planning Policy Framework: 'Tis the season to be planning!

Yesterday’s early Christmas gift from the UK Government came in the form of the National Planning Policy Framework (NPPF)[1], which represents a major step forward in reversing the changes made by the previous government in December 2023. It provides a significant step change in terms of meeting housing need, affordability and greenbelt, all of which is welcomed by the industry.

Alterations in relation to viability, the ‘golden rules’ and the further consideration of the new ‘grey belt’ designation all underline the new government's intent to shake up the system, facilitate resource planning, and grapple with the other issues which delay development and have led to successive under delivery.

Elle Cass, Head of Strategic Built Environment Growth said:

“The general feeling is that there are some real gems contained within the updated NPPF, but that it still doesn’t go far enough to ensure that the housing targets will be met. The golden rules give more flexibility than there has been previously to look at developing on ‘appropriate’ green belt land - essentially the grey belt areas we all expected – and there looks to be a greater focus on viability, with further national guidance now expected on that.

“The concept of green belt development not harming its ‘openness’ has been reintroduced, which is an interesting development that has likely been influenced by the consultation process. While the guidance does have an exception for grey belt and PDL on this point [footnote 55], there is a lot of scope for this to remain a point of contention going forward.

“I’m slightly disappointed that for all the talk of strategic planning on a broader scale within the NPPF, it doesn’t really have any more teeth than the existing local plan process, pointing towards a continued need for local agreement between authorities rather than reintroducing a more formal regional approach to housing. The addition of Paragraph 85 within the Plan Making PPG (also published yesterday) however, provides a clear basis for intervention by the Secretary of State where there is a sub-regional, regional or national development need. This demonstrates the government's intent to grasp the nettle.

“However, it’s good to see smaller sites being championed as well, and by extension the SME housebuilders that will deliver them. These housebuilders will play a crucial role in building the homes we need as a nation, and have been long overlooked since many of them went out of business in the 2008 global financial crisis.

“Overall, this represents a good first step in what looks like an ongoing review of improving and freeing up the planning regime to deliver the development we so desperately need.”

Nick Billington, Principal Planner specialising in residential development said:

“The changes to the NPPF are a significant step change in the housing requirement for the vast majority of authorities across the country. If they translate to new homes, it would represent arguably the biggest boost to house building since the immediate post-war years.

“However, it’s not just the raw numbers. This new NPPF reintroduces and underlines the (almost) mandatory requirement to plan for local housing need as defined by the new standard method within new plans or face the presumption in favour of sustainable development. The stick introduced by the introduction at paragraph 78c of the need to apply a 20% buffer to the housing requirement if an authority hasn’t progressed a new plan by then should be a clear incentive for authorities to get on and progress new plans as quickly as possible. The strengthened requirement at paragraph 28 to actually grapple with unmet need now, rather than kick the can down the road, is also a welcome injection of pragmatism in my view. These, in my view are some of the biggest positives arising out of the new NPPF to address the housing crisis.

“A word of caution though – whilst the policy changes are a very welcome first step, the government and wider industry must look at the other issues holding back housing delivery such as resourcing, the issues in the delivery of affordable housing and strategic infrastructure delivery if the homes we all hope to see built are to be delivered.”

Pol MacDonald, Director said:

“The NPPF has the chance to create generational change. For a nation that has the biggest housing shortage in the G7, the need to accelerate development is acute, but it’s important that we don’t forget that people live in places, not planning permissions.

“While deliverability needs to be front and centre, it’s vital that we don’t fall into the trap of sacrificing quality for speed. There is a danger when the targets are as ambitious as they are that it becomes a race to the bottom, but communities don’t thrive in poor quality places – it’s about seeing the bigger picture and not falling to the lowest common denominator.”

Matt Thomas, Built Environment Senior Sector Leader said:

“From a transport planning perspective, the updated NPPF pushes more towards the vision and validate approach as opposed to predict and provide – something that SLR has been advocating for more than a decade.

“Transport design needs to be less about junctions and kerb lines, and more about enhancing community and place, and these new policy guidelines come at an opportune time in the development of our team’s solutions for basing that design around health and carbon emissions.

Daniel Watson, Technical Director – Hydrology & Hydrogeology said:

“On the flood risk front, there has been a couple of substantive changes that are worth noting. Firstly, there has been a welcome shift related to the sequential test and when it should be applied – avoiding it being triggered for schemes where the developed areas are at low likelihood of flooding, but where 'non-sensitive' land uses may have a marginal risk. The second significant change is related to sustainable drainage, increasing the requirement for SUDS from just ‘major developments’ to any applications which could affect drainage around the site.

“While these requirements are already considered best practice, it is encouraging to see it being highlighted in official guidance which should help avoid confusion.”

References:

[1]https://www.gov.uk/government/publications/national-planning-policy-framework--2