Proposed reforms to the National Planning Policy Framework

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The NHC was invited to discuss the government’s consultation on reforms to the National Planning Policy Framework (NPPF) with Housing Minister Matthew Pennycook.

NHC Executive Director, Patrick Murray, attended and shared the views of our members on what the changes to planning policies will mean for the North’s housing sector. He also had the opportunity to share our recent research on the opportunities to unlock brownfield land for homes in the North, if the adequate funding is provided.

The discussion was positive, and it was clear to see the ambition in both government and the housing sector to use planning reform alongside much-needed investment to deliver more social housing.

 

 In the briefing below NHC Senior Policy Advisor Karen Brown outlines what the key proposals in the revised NPPF mean for members. 

The new Labour Government published a draft of the revised NPPF. The Secretary of State Angela Rayner addressed Parliament to outline the reasons why change is necessary. Key amongst these is the need to increase the supply of new homes to meet the Government’s 1.5m homes target (the equivalent of 300,000 homes per year).

 

Key points in the NPPF proposals:

  1. Reversal of NPPF changes made in 2023, including:
  • Making the standard method for assessing housing needs mandatory for all local authorities
  • Removing the ‘urban uplift’
  • Strengthening the ‘duty to cooperate’ and cross-boundary strategic planning
  • Restoring the five-year housing land supply requirement and the 5% buffer for housing delivery in local plans
  • Removing the requirement that a minimum of 25% of affordable housing units should be First Homes
  • Replacing ‘beauty’ standards with ‘well-designed development’
  1. Setting out expectations for Local Plans by every local authority
  1. Defining ‘grey belt’ land with ‘golden rules’ such as a 50% requirement for affordable homes. Expectations for brownfield planning approvals will be strengthened.

 

Housing targets

A core change in the draft NPPF includes a new Standard Methodology for calculating Local Housing Need (LHN). Underpinned by the Government’s ambition to deliver 1.5 million homes over the Parliament, this results in an increased target of 370,000 homes per annum across England – up from 300,000 under the current method.

Instead of household projections, the new method uses a stock increase approach – a baseline set at a percentage of existing housing stock levels, driving a level of delivery proportionate to the existing size of areas. The revised method has as its starting point a multiplier of 0.8% of existing housing stock each year, plus a revised affordability adjustment of 0.6% (previously 0.25%). LPAs can still propose a lower figure due to local constraints and conditions e.g. major flood problems.

The proposed revised method for the Northern regions is:

  Current Method Proposed Method Average Annual Net Additions (2020/21-2022/23)
North East 6,123 12,202 8,466
Yorkshire & Humber 18,699 27,433 17,602
North West 21,497 37,817 27,742
England 305,223 371,541 228,871

The proposals remove the previous 40% cap on any uplift above the previously adopted local plan housing figure as well as removing the 35% uplift that applied to the 20 largest cities.

 

Affordable Housing and tenure mix

For affordable housing the requirement will be widened for planning policies to specify the type of affordable housing required, including the minimum proportion of Social Rent homes required. On sites in the Green Belt, for major developments, there is a proposed target of 50% affordable housing with an appropriate proportion being Social Rent, subject to viability.

The proposals remove the requirement that a minimum of 25% of affordable housing units secured through developer contributions should be First Homes.

 

Land Use and Green Belt

The proposed NPPF attaches great importance to Green Belts.

The consultation seeks to identify a new classification of ‘grey belt’ land within the Green Belt, to be used in the planning system through both plan and decision-making to meet development needs. There are proposed ‘golden rules’ for development on land released in Green Belt – 50% affordable, with appropriate proportion being social rent, but this would be subject a viability test using a new Green Belt benchmark land value. Proposals for compulsory purchase for housing are also outlined.

The proposals re-introduce the requirement for all Local Planning Authorities to undertake a Green Belt Review as part of their Local Plan preparation where housing need cannot otherwise be met.

The proposals establish a sequential test – brownfield sites should be prioritised, and to support release in the right places, first consideration will be given to PDL within in the Green Belt, before moving on to other grey belt sites, and finally to higher performing Green Belt sites where these can be made sustainable.

Government defines grey belt land as, ‘land in the green belt comprising of 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, excluding areas or assets of particular importance.’

The proposals seek to broaden the existing definition of brownfield land, with a strengthened expectation that applications on brownfield land will be approved, with the consultation stating, ‘the default answer to brownfield development should be yes.’

 

Local Plans

The new NPPF aims for universal plan coverage “as quickly as possible” and “within this Parliament.”

The publication date of the new NPPF (publication date + one month) will trigger the application of new figures, depending upon the stage of a Local Plan adoption – so the new figures will likely be enforced by the end of the year.

There are obligations on plan making authorities to collaborate. The plan making authority is obligated to cooperate and make sure that their plan policies are consistent with those of other bodies, promoting a more strategic approach to planning. The initiating plan making authority will assume responsibility for making an informed decision based on cross-boundary matters.

 

Fees and cost recovery

The consultation document recognises that local planning authorities will need to be appropriately resourced.

A chapter of the consultation proposes new fee structures for planning services and also options for localisation of planning fees which would require primary legislation to establish.

 

Next steps

Whilst the Secretary of State was keen to emphasise the need to avoid too much reform there is more to come. Notably the measures in the Planning & Infrastructure Bill, consultation on National Development Management Policies, Right to Buy consultation and the first round of New Towns designations. A long-term housing strategy will be published alongside the Spending Review.

Alongside the NPPF consultation, the Lords Built Environment Select Committee is carrying out an inquiry into the Grey Belt as proposed in the NPPF consultation. This short inquiry will seek to gain a better understanding of what Grey Belt land is, how it can contribute to housing targets and what sustainable Grey Belt development looks like.  The inquiry is open for submissions from anyone with answers to the questions in the call for evidence. Evidence can be submitted until Monday 14 October 2024.

The NHC has responded to the NPPF consultation.  The published response is here.