The revised National Planning Policy Framework (NPPF) was published on Tuesday, within hours of parliament breaking up for summer recess. This was a stark contrast to the launch of the draft at a special public event back in March, by Theresa May herself. The timing was no mistake of course and it’s avoided some immediate backlash from MPs who are now on holiday.
In reality though, very little has changed following 30,000 responses to the consultation since the draft was launched back in March. It [rightly] remains highly focussed on the delivery of new housing, and charting a path tobuilding better and faster. The policies aim to help “fix” the broken housing market, although James Brokenshire acknowledges in the Government’s response to the consultation that the Framework is only part of the Government’s strategy to boost the delivery of housing and unblock barriers to more building. It is clear that policy change must be backed up with very significant resources and funding if we are to achieve a step change in housing delivery. The launch of Homes England at the start of the year and the Housing Infrastruture Fund being other welcome components.
Our key take-away is that the new NPPF provides a better tool for the developers. It places greater importance on achieving high quality design and undertaking engagement with local communities, and crucially it provides a clearer framework in which to demonstrate doing so. Simultaneously, through sensible additions such as support for airspace development above existing residential and commercial premises for new homes, the use of minimum density standards in urban areas and taking a flexible approach in applying standards relating to daylight and sunlight, the NPPF provides greater potential to make effective use of land and increase the density, and subsequently the value, of development in suitable and central locations.
Furthermore, the strong emphasis on design quality is welcomed as it is imperative that we do not repeat the mistakes of the past when accelerating delivery of much needed new homes. A role for communities in developing design policies that will reflect local characteristics and aspirations is set out in the guidance, and this will only increase the importance for developers of early and effective engagement with community groups when bringing forward major schemes.
Local Planning Authorities (LPAs) will face increased pressure from the new Housing Delivery Test, which introduces a major incentive to process housing applications as swiftly as possible and work with developers to speed up implementation and delivery. This means there will be very real implications for underperformance. Where housing delivery falls below the 95% benchmark in the Housing Delivery Test, LPAs must produce an action plan to assess the cause of under delivery and set out mitigation actions. This could be a challenging element of the new NPPF because actually getting homes up on site is beyond the LPA’s control in most cases, unless they are also the developer. Therefore, this emphasises the need for increased public sector-led delivery of homes, and an increasing number of local authorities are now choosing to go down this route rather than through a private sector partner. A more interventionist approach to land assembly and delivery of affordable homes through the increased use of CPO powers, as set put recently by London Mayor Sadiq Khan, will also play an important role in accelerating delivery.
Unsurprisingly strong protection for the Green belt is maintained, as any loosening up is just too much of a political thistle to grasp.
Overall the document, which is referred to as a “new rule book” in the Government’s press release, contains a wide range of new or amended policy guidance which is generally helpful and a step in the right direction. However, the major challenge of closing the gap between homes granted consent and homes built cannot be addressed by planning policy alone and will require a range of other interventions to back up the policy intent. Further, the document is highly focussed on housing and talks much less about employment uses. In a time of post-Brexit economic uncertainty and when, in parts of the country, industrial land is being lost at a rate to housing use, we must get the balance right and the document does not address this as much as needed.
For further analysis of the new NPPF then please click here.