A breath of fresh air...
Since the Labour government came to power earlier this month they’ve wasted little time in making their mark on the planning policy framework.
It’s likely that the Government will want to publish a final version of the new policy quickly after this - rather than waiting the 12 months we had before the last update. I would expect something before Christmas.
Alongside a new NPPF the government have:
- released details on an updated Standard Method of Calculating Housing Need;
- launched a commission into New Towns; and
- issued a letter to Planning Inspectors to encourage them not to delay the examination of local plans unless they stand a good chance of being found sound.
They have also promised (details to come) a ‘national scheme of delegation’ that will prevent local planning committees getting involved in smaller-scale schemes, or the Reserved Matters applications for schemes that they have already seen.
A what-you-need-to-know guide to each of these follows…
New NPPF
The new NPPF makes a number of changes to national policy and further changes are expected in the near future. Among the most important changes included in this round of updates include:
Beauty
Gone. All the references in the policy to creating ‘beauty’ or ‘refusing ugliness’ have been deleted. I don’t think you’ll see too many tears shed about that.
Presumption in Favour / The ‘tilted balance’
All the changes that were introduced in December 2023 by the previous Government have been deleted.
The 2023 NPPF introduced new protections and incentives to get Councils to adopt a local plan. This update removes these protections for recently adopted plans, and now requires all Councils to demonstrate a 5 years housing land supply and reinstates the need to meet the Housing Delivery Test.
I would expect to see more Councils fall into the 'presumption' category upon adoption of the new NPPF, which will make it easier for speculative developments to win approval.
The Housing Delivery Test itself, one of the triggers for falling into Presumption, has also been made much harder for some Councils (and easier for others) through changes to the Standard Method that are outlined below.
Green Belt
Although no changes to the purposes of Green Belt have been introduced. Changes to the way that Green Belt is managed have been proposed.
Councils were explicitly prevented from reviewing Green Belt boundaries - even when they couldn’t meet their housing need. Now they’re explicitly required to review the extent of Green Belt as part of a policy review.
In addition, when assessing applications - while the Green Belt was previously a (Footnote 7) protection that would prevent the Presumption in Favour from applying, it no longer is.
This is likely to open up a load of previously protected Green Belt sites to development.
To double-down on this, the updated NPPF clarifies that development should not be considered ‘inappropriate’ in the Green Belt where a council is under ‘presumption’, provided that certain tests are met. It also establishes that the test for impacts on the ‘openness’ of Green Belt (one of the five purposes) must be assessed against ‘the area of the plan as a whole’, meaning that a site-by-site assessment of impact on open-ness will no longer be acceptable.
For major developments in former green belt sites, new requirements have been included in Paragraphs 155 - 157 setting out stringent affordable housing, green space, and infrastructure requirements that must be met on these sites before they can be approved for housing.
Grey Belt
Linked to the above, sites that are in the Green Belt of ‘Presumption’ Councils may be considered to be ‘Grey Belt’ sites. A new definition has been included in the Glossary of the policy:
“Grey belt: For the purposes of plan-making and decision-making, ‘grey belt’ is defined as land in the green belt comprising Previously Developed Land and any other parcels and/or areas of Green Belt land that make a limited contribution to the five Green Belt purposes (as defined in para 140 of this Framework [i.e. the NPPF]), but excluding those areas or assets of particular importance listed in footnote 7 of this Framework [the NPPF](other than land designated as Green Belt).”
Our analysis of the sites that are likely to be considered Grey Belt has proved very popular. When we ran this we only focussed on Brownfield sites (Previously Developed Land) and land registered as vacant or derelict.
Armed with this new definition we will be rerunning our analysis in the coming weeks and will publish our findings.
Other Changes
Specific requirements to plan for the economy, namely gigafactories and data centres have been introduced, along with specific requirement to provide housing for the needs to Looked After Children. Councils have also been given a direction to support renewable energy projects.
A track-change version of the new draft NPPF is available here.
Standard Method of Calculating Housing Need
The current ‘Standard Method’ is how the housing need for an area is calculated. It is how we have arrived at the direction that we need to deliver 300,000 houses each year.
The calculation is based on 2014 housing projections, to which the average growth rate over 10 years is applied, followed by an uplift based on affordability ratios. This figure is then capped, if necessary, before a further 35% uplift is applied to the top 20 urban areas.
The proposed new Standard Method will simplify the process, and change the focus of where these houses should be delivered.
To say that it’s significant would be an understatement.
Rather than being based on population projections, the new method requires new housing to be delivered proportionate to existing housing stock. It’s based on 0.8% of the existing housing stock being annually delivered. An uplift is then applied based local affordability ratios to require more housing to be delivered where housing is least affordable.
When added up over the country the new Standard Method will deliver a total housing requirement of over 370,000 houses a year.
This change will see big increases in housing need for the likes of:
- North Yorkshire (+ 2,871 homes)
- Cornwall (+ 1,747 homes)
- Wiltshire (+1,558 homes)
It will also see big decreases for many urban areas:
- Birmingham (- 2,200 homes)
- Coventry (- 1,554 homes)
- Leicester (- 745 homes)
The picture is also mixed within London with both winners and losers resulting from the shift. Among those seeing big increases are:
- Kensington and Chelsea (+ 2,890 homes)
- Westminster (+ 1,930 homes)
- Wandsworth (+ 1,321 homes)
And at the other end of the scale, those with significant reductions:
- Tower Hamlets (- 3,013 homes)
- Newham (- 2,010 homes)
- Enfield (- 1,755 homes)
There’s a handy spreadsheet here.
Lichfields have already crunched the numbers on this here.
And prepared an interactive map here.
This will have a big effect not only on how many houses are delivered, but also where they’re delivered. Particularly as councils can no longer hide behind Green Belt as a reason to not deliver the housing demand as indicated by this Standard Method.
New Towns
The Government has announced a new task force, led by Sir Micheal Lyons and Dame Kate Barker, to deliver new settlements of at least 10,000 homes. This is to be over and above the new national target of 370,000 homes a year, and recommendations for where these new settlements should be will be delivered within the next 12 months.
“These new communities will be governed by a ‘New Towns Code’ – a set of rules that developers will have to meet to make sure new towns are well-connected, well-designed, sustainable and attractive places where people want to live. They will have all the infrastructure and public services necessary to support thriving communities. The towns will also help meet housing need by targeting rates of 40% affordable housing with a focus on genuinely affordable social rented homes.”
We will be watching this with great interest as the locations of proposed new towns emerge.
Scheme of Delegation
Currently each council has its own scheme of delegation that determines which applications are decided by officers, and which must be seen by a the committee of elected members. This leads to a picture across the country which is - at best - patchy, and to a process with which developers and other stakeholders have little confidence.
The new ‘scheme of delegation’ should ensure that the role of elected members is focussed at the right stage of the development process, that their input carries the right weight, and that once a decision is made, investments are not hampered by a need to constantly revisit decisions as committees and members within the councils evolve over time.
The hope is that this scheme of delegation will help streamline the decision making process and ensure that local representation is focussed at the right point in the process.
Further reading
- Have We Got Planning News For You - Discussing the Proposed Reforms to the National Planning Policy Framework: July 2024 Update (S13 E6)
- #Planoraks - #PlanningReformDay 2024 - what just happened?
- Lichfields - Proposed reforms to the NPPF and other changes to the planning system
- GOV.UK - Expert taskforce to spearhead a new generation of new towns
The draft changes to the National Planning Policy Framework (NPPF) will be out for consultation until 11:45pm on 24th September 2024.
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