Proposed Changes to National Planning Policy
August 2024
By Sam Knowlton, Graduate Planner
The new Labour Government has published its draft amendments to the National Planning Policy Framework (NPPF) for public consultation. The consultation period will run for eight weeks and interested parties are invited to provide feedback on the proposed changes. The Government will then consider the responses made and we anticipate the new NPPF will be published in December 2024.
The proposed changes demonstrate Labour’s ambitions to boost development across England with a pledge to “Get Britain building again”, including a target to deliver 1.5 million new homes. In this blog we summarise some of the key areas of change in the draft NPPF covering a number of topics.
The proposed changes demonstrate Labour’s ambitions to boost development across England with a pledge to “Get Britain building again”, including a target to deliver 1.5 million new homes. In this blog we summarise some of the key areas of change in the draft NPPF covering a number of topics.
- Boosting housing supply
- Calculating housing needs
- The Green/Grey Belt
- Brownfield land
- Affordable housing
- Renewable energy
- Economic growth
- Design
Boosting housing supply
Labour have proposed to withdraw several of the newer policies in the current NPPF, which was published by the Conservative Government in December 2023. For example they propose to reinstate the requirement for LPAs to demonstrate a 5 year housing land supply (YHLS) during the first five years of a new Local Plan being adopted. They also propose to withdraw the policy that allowed LPAs with Local Plans at Regulation 18 or 19 stage to only demonstrate a 4YHLS.
These changes would mean that all LPAs, irrespective of what stage their Local Plan is at, will need to demonstrate a 5YHLS.
Labour are also proposing to revert back to the previous requirement for LPAs to apply an additional 5% buffer when calculating 5YHLS requirements, with a 20% buffer applied for those LPAs who have a track record of under delivering on their housing targets over a three year period.
Calculating housing needs
The standard methodology used to calculate local housing requirements is proposed to be amended. In the majority of cases the new methodology will result in an increase to housing targets for LPAs. The reference in the current NPPF to housing requirements being an ‘advisory starting point’ is also set to be removed. This sets a clear expectation that LPAs should be planning to meet their calculated housing need when preparing new Local Plans.
The Green/Grey Belt
A new classification termed the Grey Belt is proposed to define areas of lower value land within Green Belts. But what exactly is the Grey Belt? In short it’s described as any area of previously developed land (PDL) or land that makes a ‘limited contribution’ to the purposes of the Green Belt.
The introduction of the Grey Belt would require a significant change in the approach to strategic planning in Green Belt areas. While changes to Green Belt boundaries has historically only been allowed under ‘exceptional circumstances’ the draft NPPF sets a clear expectation that exceptional circumstances will include situations where a LPA is unable to meet its identified need for housing and employment sites. In short, if needs cannot be met outside of the Green Belt then LPAs will be required to release land from the Green Belt to accommodate those needs in full. In such situations LPAs should apply a sequential approach, with PDL released in the first instance, followed by Grey Belt. Greenfield land in sustainable locations should be the last resort.
Where a LPA cannot demonstrate a 5YHLS or falls below the 75% Housing Delivery Targets (HDT) threshold, the draft NPPF states that development of Grey Belt land should not be regarded as inappropriate as a matter of principle.
Where new sites are allocated or granted planning permission for housing in the Green Belt, the draft NPPF sets an expectation that 50% of units should be affordable housing.
Brownfield Land
The revised NPPF seeks to bolster delivery of housing and commercial development on brownfield land. Specifically it states that development proposals on brownfield land within settlements should be regarded as acceptable in principle.
Affordable Housing
The draft NPPF also proposes significant changes to way affordable housing is to be sought and delivered on major developments (schemes of 10+ homes). While the NPPF currently requires 10% of new homes to be made available for affordable home ownership, the new draft instead emphasises the need to meet identified local needs including both affordable rent and ownership tenures. This change would empower LPAs to define their own requirements based on local evidence of need.
The draft NPPF retains the requirement for 25% of new affordable homes to be provided as First Homes (discounted homes for first time buyers).
Renewable Energy
Although the current NPPF does give support to renewable energy developments, the energy sector has long criticised its highly restrictive approach to onshore wind energy developments. The draft NPPF seeks to delete this restrictive policy with the aim of encouraging such developments in future.
The draft NPPF also instructs LPAs to give ‘significant weight’ to a proposals contribution to renewable energy generation and a net zero future. While this may appear a small change, it does provide greater clarity over how the benefits of renewable energy should be balanced against other material planning matters e.g. landscape impacts.
Economic Growth
While economic growth has always been at the forefront of national policy, the proposed changes to the NPPF place significant emphasis on meeting the needs of a modern economy. In particular it focuses on the provision of laboratories, gigafactories, data centres, digital infrastructure and freight and logistics.
Design
The previous iteration of the NPPF placed significant emphasis on achieving ‘beautiful’ places. Recognising the ambiguity of the term (beauty means different things to different people), the draft NPPF instead refers to the need to achieve well-designed places. This still allows LPAs to consider the visual appearance of new developments, but places this on a more even keel with other design matters such as connectivity, energy efficiency and climate resilience.
Overall Conclusions
It is important to remember that the draft NPPF remains a consultation document at this stage. However, should these proposals be retained within the final published iteration of the NPPF then we can expect to see a large number of LPA’s unable to demonstrate a 5YHLS in the short term. The majority of LPAs will also need to find a way to meet increased housing requirements in emerging Local Plans, including through the release of Green/Grey Belt land where applicable.
Get in touch
For bespoke advice in relation to the proposed NPPF reforms and their potential implications for your development interests, please contact our dedicated Development Land & Planning team on 01823 334466 or [email protected].