Since our recent article on the new Labour government’s intentions for the planning system (https://www.weaplanning.co.uk/blog/post/22324/what-does-the-new-labour-government-mean-for-planning/), the government have now launched a consultation on a new version of the National Planning Policy Framework (NPPF).
The consultation opened on 30th July 2024, and you can submit your views until 24th September via the link at the end of this article.
The proposed revisions comprise a range of policy areas, with an overall focus largely around house building and infrastructure provision.
Mandatory housing targets and the standard method
One of the key proposed changes in the NPPF it removes the December 2023 changes and makes housing targets mandatory again. Essentially, it removes text which stated that the results of the ‘standard method’ were advisory.
The ‘standard method’ is the approach towards calculating the housing target for a local authority area. Currently, this is based on household projections and then applying various uplifts or caps based on local circumstances. The proposed NPPF revisions also include an update to this methodology, where housing delivery targets would instead be based on a proportion of the existing housing stock (0.8%) with an uplift based on workplace-based affordability.
These updates have the effect of increasing the housing targets in most local authority areas and will mean that local authorities cannot ignore these targets. However, local authorities could still argue reasons they could not meet these figures on the basis of local circumstances and demonstrating that all steps under standard method have been undertaken.
The revisions also propose the restoration of the five-rear land supply requirement, meaning that local authorities will need to demonstrate this supply, even when their adopted plan is less than five years old.
Green belt reviews
One of the most discussed areas of planning reform proposed by the new government is the changes to Green belt policy, along with the introduction of a new concept of ‘grey belt’. A definition of this is provided in the proposed revised NPPF:
“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”
It is expected that a more detailed definition of grey belt will be included in the final version of the updated NPPF.
Where LPAs cannot meet their housing targets in full, the LPA will need to review their Green belt land. The new concept of grey belt land may mean that sites on the fringes of urban areas are identified as sites for development. Development on these sites would not need to demonstrate Very Special Circumstances.
However, another key proposed change in the NPPF is that housing need can justify release of the Green belt. Mandatory Green belt reviews would provide an opportunity for local authorities to release green belt land if they have an inability to meet targets elsewhere.
Additionally, developments on such green belt sites would be subject to the provision of at least 50% affordable housing (subject to viability); relevant infrastructure improvements; and provision or improvement of green spaces accessible to the public.
Design codes
The 2023 updates regarding beautification and mansard roofs are proposed to be removed, unsurprisingly. The character test has also been removed (which limited uplifts in the density of residential development if this would be out of character with the existing area). Instead, use of National Model Design Code has been strengthened, which forms the primary basis for the creation of local design codes.
Strategic planning
The proposed revised NPPF includes bolstered text around cross boundary strategic planning, specifically around housing targets and strategic infrastructure. The intention is to promote a more strategic approach to planning, by strengthening cross-boundary collaboration, which is a welcomed updated.
The government have also hinted at plans to introduce mandatory mechanisms for strategic planning. However, in the absence of such strategic planning mechanisms, the updated NPPF may not make much difference to the status quo in terms of cross boundary co-operation.
The revised NPPF recognises that local plans may come forward at different times, leading to a degree of uncertainty about the future plans of neighbouring boroughs, and therefore it is required that strategic policy-making authorities and Inspectors will need to come to an informed decision on the basis of available information, rather than waiting for a full set of evidence from other authorities.
Clean energy
There is also a focus on renewable and low carbon energy sources. Local authorities will be required to identify (rather than ‘consider identifying’ in the previous NPPF) suitable areas for renewable and low carbon energy sources and supporting infrastructure.
Paragraph 164 introduces a requirement for Local Authorities to support planning applications for all forms of renewable and low carbon energy development.
The government is also proposing to amend the thresholds at which solar and wind energy projects are considered as Nationally Significant Infrastructure Projects (NSIPs) under the Planning Act 2008, rather than being determined as planning applications under the Town and Country Planning Act 1990. Specifically, the proposals include reintroducing onshore wind to the NSIP regime but increasing the threshold to 100MW rather than 50MW, and also increasing the threshold for solar farms from 50MW to 150MW.
Other Reforms
The proposed reforms include a host of other changes, the full list of which can be viewed at the consultation link below. These include:
Changes to the NSIP regime to include data centres, gigafactories, and laboratories
Strengthening the S106 contribution model to ensure that required infrastructure is provided alongside new homes
Changes to local plan intervention criteria and examination process
·Introduction of a ‘vision led approach’ to transport planning
Consultation period for new NPPF
The consultation opened on 30th July 2024, and you can submit your views until 24th September.
The consultation can be accessed at the link below where you can submit your views:
https://consult.communities.gov.uk/planning/planning-reform/
Overall, these proposed changes are welcomed. In particular, strategic planning is recognised by professional planners as an area which has needed attention in order to effectively delivery housing and infrastructure. The package of measures is clearly aimed at promoting development, aligning with the Government's goal to stimulate building across the country. Consequently, many developers and landowners are likely to support it. However, some of the changes are expected to be highly controversial, especially in so-called ‘nimby’ areas which may see increased housing developments, and local authorities in these regions will face difficult political decisions if the proposals proceed as planned.
If implemented as envisioned, these changes could create significant opportunities for developers, housebuilders, and landowners. For planning applications, any changes will become part of the statutory policy framework once a new NPPF is adopted. In relation to policy changes, the implementation will be more gradual, particularly for emerging local plans which are already well advanced and close to adoption.
Victoria Hills, Chief Executive of RTPI has provided the following statement in response to the proposals: "The proposed changes to our planning system have the potential to rebuild trust in our planning system. We believe that the government's goals for housing, energy, and transport can be accomplished through collaboration with planners in both the public and private sectors.
“It is particularly encouraging to see the government placing a much-needed emphasis on strategic planning, which can help deliver more coherent – not piecemeal – urban expansions by integrating new housing with transportation, energy, and public services.”