Another year, another planning Christmas present!
After months of speculation around Labour’s planning reform and NPPF consultation (see our blog post on the anticipated changes) the results are here. The NPPF (2024) was published 12th December, it’s impact on decision making in planning is immediate, but it won’t impact plan making until 12th March 2025, to give some leeway to the plans currently being submitted for examination. The updates mostly revolve around housing, infrastructure, and Green Belt, and the question of where best to locate development.
So, grab a left-over mince pie and a Bailey’s and get comfortable while we look at the NPPF highlights and how this is going to impact our world of town planning.
Achieving Sustainable Development
The presumption in favour of sustainable development now guides decision makers to place even more weight on “directing development to sustainable locations, making effective use of land, securing well-designed places and providing affordable homes” (11.d.ii). The increased emphasis on “sustainable” is something that we can now see throughout the revised NPPF. There used to be a “golden thread”.
Plan Making
There’s greater emphasis on strategic plan-making, which was expected alongside the plans for devolution across the country, with a sense that working strategically will assist in delivering development in sustainable locations, spatial issues affecting housing need, delivering infrastructure, and boosting economic and climate resilience.
Annex 1 details the implementation of the new NPPF for plan-making and shows that local authorities whose new Local Plans fall below 80% of the new standard method for housing targets will need to work on a new Local Plan (236).
Delivering a sufficient supply of homes
There is a new emphasis on Social Rent as part of affordable housing provision throughout the NPPF (63 - 66). Definition from the glossary below.
Homes within released Green Belt sites (more on this later) must deliver at least 50% affordable housing (unless unviable) though this appears in flux already. This level of affordable housing must be higher than the percentage of affordable housing sought by the local authority for non-Green Belt sites (67) and the percentage can vary across Green Belt sites, i.e. a lower percentage of affordable housing for Previously Developed Land within the Green Belt and a higher percentage for undeveloped land (68).
The framework details additional support for mixed tenure sites which present a range of ownership and rental tenures, offering benefits for communities and build out rates (71). SME housebuilders get a shout out (73), emphasising the importance of small sites for SMEs.
The previous framework gave a 20% buffer for supply and delivery of housing as standard, now the buffer is reduced to 5% unless the LPA has significantly underdelivered for the past 3 years or (from July 2026) the plan was adopted in the last 5 years but only delivers 80% or less of the housing requirement, then the 20% buffer remains (78a-c).
Building a strong, competitive economy
The NPPF includes support for boosting the ‘modern economy' through the creation of new infrastructure, freight and logistics, including data centres and gigafactories (86c). The sentence supporting live/work accommodation has been removed from flexible workspaces (86e). The framework also promotes the importance of expanding and upgrading facilities to improve grid connections, supply chains, resilience and decarbonisation (87).
Promoting healthy and safe communities
The NPPF has strengthened the link between inequalities and health and planning (96c) and added that proposals for new Takeaways should be refused when they are in walking distance from schools and other areas where young people meet up (except town centres) or are in locations with existing evidence of negative impact on health, antisocial behaviour, and/or pollution (97).
The framework includes more support for social infrastructure, expanding the definition of education from schools to include early years, schools and post-16 (100) education. There is significant weight for new, expanded, and upgraded public service infrastructure, including the provision of healthcare facilities, blue light services, libraries, adult education, universities, and criminal justice facilities (101). Alongside the existing protections for open space, sports and recreation, there is now protection for formal play spaces (104).
Promoting sustainable transport
The vision-led transport approach has made it to the final NPPF (109), promising to make transport part of early community engagement and ensure that patterns of movement and parking are treated as integral to the design process and contribute to creating high quality places.
Making effective use of land
The NPPF gives greater weight to sites on brownfield land (125c) brownfield land, stating that proposals should be approved unless substantial harm would be caused. More information around ‘Brownfield Passports’ tbc.
Achieving well-designed places
Goodbye to planning to vaguely hard to define beauty standards. It now stands that beauty is less in the eye of the beholder, more in the guidance of design codes and SPDs, with the emphasis firmly on good design.
Protecting Green Belt Land
Ok now the bit we’ve all been waiting for, the slightly less green (insert wicked reference here) Green Belt.
The reforms are not as drastic as certain headlines have been alluding:
Green Belt boundaries should only be altered in exceptional circumstances (145). Such as, cases where local authorities cannot meet their housing targets, commercial or other development elsewhere (146).
After all the rhetoric around a new “grey belt” designation, it is only mentioned in two paragraphs in the final NPPF (okay, three if we include the glossary) though these could be the two most significant paragraphs for a while.
There is a new hierarchy for releasing Green Belt land; the first preference is to release Previously Developed Land in the Green Belt (as previously advertised), if that isn’t possible the second move is towards Grey Belt (description from the glossary below – and more guidance coming January 2025). Only then, as a last resort, would other Green Belt sites be released (148).
Slightly more allowances for buildings in Green Belt land in association with existing development. Appropriate development in the Green Belt now includes buildings when used in connection for outdoor sport and recreation, cemeteries, or allotments as long as the development still preserves openness and purpose of land (154b).
Paragraphs 155-157 reiterate accepting the provision of housing, commercial uses and other development on Green Belt land when using previously developed, or grey belt, land providing that the development does not undermine the purposes of Green Belt, demonstrates an unmet need for the development, utilises a sustainable location and meets the Golden Rules. These new Golden Rules concern affordable housing provision, improvements to infrastructure, and new provision or improvements to publicly accessible green spaces for Green Belt sites.
Meeting the challenge of climate change, flooding and coastal change
The framework has introduced a new expectation for planning applications to mitigate and adapt to climate change (163), with some speculation as to how this will be undertaken, presumably as an additional report supporting proposals.
Further significant weight is to be given for energy efficiency and low carbon heating improvements for existing buildings (167) as a part of development.
Many planners are criticising the NPPF for not going far enough to tackle flooding and surface water, as the framework proposes a sequential risk-based approach for applications in areas at risk now or in the future from any form of flooding (173), but this is not needed if the built elements of a proposal are outside of the areas at risk of flooding (175) or for minor applications and change of use of existing development (176).
So, what does this mean for you?
There is clearly more potential for LPAs to allow development on Green Belt land but this development would have to pass a lot of tests. Greater weight for sustainable locations and accessible sites. More emphasis towards strategic planning. And of course, far higher housing targets for local authorities to meet.
If that wasn’t enough to keep you busy over the holidays, further information around the reform of local councils and the return to strategic planning have been outlined in the Government’s White Paper on Devolution (16th December 2024). Changes to planning committees to speed up planning permission. Planning Policy Guidance has also been updated for plan-making, viability and housing need.
In January 2025, we have been told to expect more guidance following in the trail of the NPPF, including further guidance on the Green Belt reforms, Planning and Infrastructure Bill, and 12-week Land Use Framework consultation early in the New Year.
