Lanpro provide commentary on National Planning Policy Framework revisions

Lanpro provide commentary on National Planning Policy Framework revisions

Following the publication of the revised NPPF in the last 24 hours, Sav Patel, Associate Director at Lanpro provided a comment on

  • mandatory housing targets
  • housing need
  • presumption in favour of sustainable development
  • brownfield
  • affordable housing
  • Green Belt golden rules
  • housing targets
  • local authority resourcing
  • the planning reform working paper: decision-making process at a local level, mandatory training of members

 

 

Sav Patel, Associate Director, Lanpro:

 

The Labour government’s much anticipated updated NPPF has landed, just in time for Christmas! Planners up and down the land will now be scurrying to forensically examine what is new, what is in, and what is out, before the whiff of Brussels sprouts fills the air.

 

As we already know, the government has an ambitious target of delivering 1.5 million new homes over the next parliament to help ‘get Britain building again’ and grow the economy. This equates nicely to 300,000 new homes per year. As we know, this is ambitious because this annual rate of house building has never been achieved in the last 25 years. There will also be a strong focus on supporting economic growth in key sectors including renewable energy.

 

So, What’s New? The ‘grey belt’ and the ‘Golden Rules’ for Green Belt development. A new standard methodology for assessing housing need. Enhancements on green infrastructure and focus on promoting healthier living.

 

What’s In? As expected, the reintroduction of mandatory housing targets to require all local planning authorities (LPAs) to plan for and meet housing need in their area, and updating of how to operate the presumption in favour of sustainable development. A recognition of the important role that small and medium housebuilders play in delivering new homes particularly in the short term. A broadening of the definition of ‘brownfield’ land. The need to deliver more affordable housing as part of the golden rules. A strengthening of sustainable urban drainage and sustainable transport provision. The reference to ‘mansard roofs’!

 

Areas with the highest unaffordability for housing and greatest potential for growth will see housing targets increased, which could cause friction with local communities many of which are reluctant to see more development in their areas – many of these are in parts of the South East and East of England where Labour made substantial gains at the last general election and such measures could pit local MPs keen to hold on to their rural seats against the Government.

 

What’s Out? Areas of Outstanding Natural Beauty (replaced by National Landscapes). Paragraphs 76-78 which removed the mandatory housing targets on local authorities, and Michael Gove’s love of all things “beautiful”,

 

On the face of it, with so many competing factors, the updated NPPF is a positive step towards trying to achieve the government’s growth targets. It certainly sends a clear message to LPAs that the need to meet housing targets, which was diluted by the previous version under the Conservatives. The NPPF has the bark, but does it or will it have the bite? That, without getting too pessimistic, is unknown. Many of the issues delaying building aren’t just planning-related: labour supply and skills, materials shortages and other external factors all have an impact. Much will depend on how LPAs deal with the changes and their political will.

 

In terms of local plans, many LPAs had paused work on their new Local Plans until the updated NPPF, so at least the new NPPF now provides a clear steer (from a higher level at least) on how plans should be progressed and what they need to deliver particularly in terms of housing. However, the struggles (and development industry frustrations) with many LPAs up and down the country is with resourcing, whether that be in policy or development management. Councils continue to be under pressure to make costs savings and reduce overheads.

 

300 new planners is welcomed, but it is a ‘drop in the ocean’ (equating to less than one additional planner per local authority – and that doesn’t necessarily account for the additional demand for private sector arising from the Government’s wider objective to kickstart growth with more planning permission). Whether this is enough for what is required to alleviate the bottle necking remains to be seen.

 

The other significant restrictor to development is the decision-making process at a local level. Every LPA appears to have its own delegation rules. It is time that a national scheme of delegation is provided to ensure consistency across the board, particularly if development is to be delivered in a timely manner, and so the publication earlier this week of the planning reform working paper, which proposes a national scheme of delegation, is welcomed. Too many applications, particularly on allocated sites, are being taken to planning committee which shouldn’t be the case (unless there is a strong reason to do so). The White Paper that was published earlier this week, contains some very sensible proposals on the role and performance of planning committees, particularly the requirement for mandatory training of members.

 

The loosening of the Green Belt is also welcome with the introduction of a ‘grey belt’. The balance between protecting the purpose and openness of the Green Belt is essential, and the introduction of grey belt is helpful, but will it do what it is intended, over and above the previous wording? The interpretation of the purposes of the Green Belt and what constitutes very special circumstances will continue to be the main battleground. The updated definition of the grey belt will also be a matter for semantics for lawyers to litigate over. As with most things, case law will be used as the benchmark for interpretation. I’m therefore not convinced it will have the desired effect, particularly as there will be a prerequisite for a significant uplift (up to 50%) in affordable housing on grey belt land.

 

In summary, the updated NPPF has been a long time coming and the introduction of the mandatory housing requirements is a significant step forward to getting Britain building again. It may upset some local communities and local politicians who may see it as losing control over what happens within their areas but ultimately Labour came to power with a commitment to getting Britain building for good or for ill.

 

However, with so many competing factors, whether that be Green Belt or grey belt, biodiversity net gain, flooding and water scarcity, the proof will be in the Christmas pudding, as to whether the changes work or are successful in achieving the government’s growth agenda. One thing is for sure, we will all need to play our part; public sector and private sector.

 

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