As we near publication of the Government’s revised NPPF, GVA takes a look at some of the key policy changes we expect to see in the document.
Whenever it comes to updating the NPPF it is always crucial that the new policies react sensibly to the market and recognise the key priorities of the day. The shortage of housing in the UK has long been making headlines and it is vital that our national and local policies, as well as public and private partners, work in a way that expedites delivery rather than creating a further layer of confusion and delay. The six key takeaways below have the potential to achieve both the former and the latter, so a thorough understanding and collaborative approach is essential to ensuring we remain on the right road to addressing the housing crisis.
Local Plans – we will almost certainly see a greater emphasis on strategic priorities, strategic policy-making, and cross-boundary planning, which may pave the way for the preparation of more streamlined and focussed plans that address critical growth issues at the sub-regional level. However, the key to efficient plan-making at the strategic level will be ensuring that the policy-makers concentrate on those matters that are genuinely strategic. If groups of local authorities can work collaboratively to establish development requirements and define spatial strategies that span administrative boundaries, many will welcome the more co-ordinated policy framework that such Plans can deliver. We also expect the Government to retain requirements for strategic policies to look ahead over a minimum of 15 years and for Plans to be reviewed at least once every 5 years, meaning that key policies will be in an almost constant state of review.
Sustainable Development – we expect the definition of sustainable development to be tweaked to include a reference to making the most effective use of land but also for the NPPF to make it clear that the social, environmental and economic limbs of sustainable development are not criteria against which every decision should be judged. The presumption will also be re-worded. For plan-making, it will include a reference to meeting needs that cannot be satisfied in neighbouring areas which will be a welcome addition. For decision-taking we expect the words “relevant policies” to be replaced by “policies which are most important for determining the application”. This, unfortunately, has the potential to give rise to unnecessary and unhelpful debates around interpretation, further decelerating the process of delivery.
Soundness – expect the wording of the tests to be tweaked. Amendments to the definition of “Positively Prepared” are likely to mean that Plans are required to provide a strategy that meets as much of the area’s objectively assessed needs as possible (rather than “which seeks to meet objectively assessed….requirements”) and is informed by agreements with other authorities so that unmet needs from neighbouring areas are accommodated where practical and sustainable. This feels like a weakening of policy at a time when the default position should be meeting development needs in full. The amended “Justified” test is likely to require authorities to deliver “an appropriate Strategy” rather than “the most appropriate strategy” also feels like a weakening.
Assessing Housing Needs – we fully expect the Government to stick with its plan to introduce a standard methodology for calculating housing needs but don’t know whether this will be the same as the methodology consulted upon last year. The devil will be in the detail and we are expecting a full suite of guidance to be inserted into the Planning Practice Guidance (PPG) when the NPPF is published. We also expect the Government to persist with the requirement for authorities to assess housing requirements at the neighbourhood area level. However, we shall have to wait to see whether it allows authorities to rely on judgements over detailed calculations. Whatever it does, it is critical that it doesn’t create a situation where Neighbourhood Plans become obstacles to growth.
Land for Homes – we expect to see numerous changes here, including a revised definition of ‘deliverable’ housing sites; a requirement for 20% of allocated sites to be 0.5 ha or smaller; new requirements in respect of buffers and how land supply is calculated; the use of Annual Position Statements; and the introduction of the Housing delivery test. Some will be welcomed, others not and some look set to over-complicate an area that is already the subject of significant analysis at Public Inquiries that seem to run counter to the Governments over-arching objective to speed up the planning process and enable faster housing delivery. We will of course have to see how these changes impact on the supply of land for new housing but we are concerned that, overall, they have the potential to slow the planning system down and limit supply.
Green Belt – look out for several changes to the Government’s policies including: new and more stringent requirements to justify proposed land releases; the introduction of a sequential test favouring the release of brownfield land or land well served by public transport; and a requirement to identify ways in which the impact of removing land from the Green Belt can be offset by improvements to remaining Green Belt land. All appear to be designed to ensure that, more than ever before, Green Belt land is only released for development as a last resort.