Draft NPPF (National Planning Policy Framework) published for Public Consultation
Bricks are seemingly the choice of building material for the Prime Minister as she led the Government’s latest plans to reform, and maybe fix, the broken housing market.
The draft revised National Planning Policy Framework (NPPF) was published on 5th March for a public consultation until 10th May – before the final NPPF is published later this year. This ‘major overhaul’ has been launched to deliver the homes the country needs, but aside from the housing focus includes an amended version on the operation of the presumption in favour of sustainable development and refinement of other core planning principles in the 70 page document.
So much has been said by the Government, including in this announcement, about the ‘hoarding’ of land and planning permission and the consequence of slow rates of delivery. As the Prime Minister put it “after all, families can’t live in a planning permission” which can’t be disagreed with.
The draft NPPF promotes early commencement of permissions by reducing the time limit below the three year default. This would sit alongside assessment of reasons why an early grant of permission of a similar development on the same site did not start. It strengthens the obligations on local planning authorities through the expected introduction of a Housing Delivery Test whereby the presumption will be engaged where delivery has fallen below 75% of the established requirement over the preceding three years. However, it offers some respite to authorities where a five year housing supply position can be fixed for 12 months and tools to encourage a more flexible choice of supply of smaller sites.
Draft NPPF key revisions
Overall the draft NPPF is an evolution of the current version, but its key revisions include:
- A standardised methodology for calculating local housing needs.
- Strategic plans to set out a housing requirement figure for designated neighbourhood area, albeit without any obligation on those preparing neighbourhood plans to use their plan-making powers to actively engage with the pressing need to deliver more homes.
- A focus towards the identification of at least 20% of sites allocated in local plans for housing of a site area of 0.5 hectares and less.
- Incorporation of the Written Ministerial Statement on support for small scale developers into policy, with proposed removal of the 1000sqm threshold when assessing the triggering of affordable housing contributions.
- A revision to the definition of deliverable sites meaning local planning authorities must provide clear evidence that major outline permissions and allocations will deliver completions within five years.
- Support for entry-level exception sites, suitable for first time buyers (or those looking to rent their first home) on sites outside existing settlements on land not already allocated for housing.
- The subdivision of existing dwellings can be a special circumstance enabling new isolated homes in the countryside.
- Encouraging the use of previously developed land and sites that are in the countryside, but well-related to existing settlements to support the growth of the rural economy.
- A drive towards the effective use of land through substantial weight being given to the value of using suitable brownfield land within settlements for homes and other identified needs.
- Viability assessments submitted as part of decision-taking are to be made publically available
- Affordable housing developments on brownfield land in the Green Belt, and which would not cause substantial harm to openness and would meet an identified need, would not be considered inappropriate development.
Ultimately implementation of the revised NPPF, when published, and success of these reforms will be limited by the 6-month transitional arrangements offered to the local planning authorities submitted a plan for examination. Also the interpretation of the policies and the statements of weight that the Government expects are to be afforded to considerations in the planning balance.
More reforms to come
After the long wait for the revised NPPF, the published draft offers a lot to analyse and consider how the policies operate in practice. The Prime Minister’s speech confirms that the Government’s reforms are far from complete as they look towards the magical target of 300,000 homes per year.
Later this year we can expect further reforms following the outcomes of Sir Oliver Letwin’s review of build out and future consultation will include a new permitted development right for upwards extensions; and more effective ways of bringing agricultural land forward for housing. Planning reforms are clearly never finished, rendering certainty as an obsolete terminology in planning.
Here at Fowler Architecture & Planning, we will be carrying out a further analysis of the consultation draft NPPF and will be providing a written response to the Ministry of Housing, Communities & Local Government (MHCLG).
Get in touch
Get in touch with our planning team for more information on 01672 569444 or email enquiries@faap.co.uk
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April 13, 2023