Consultation on the Draft National Planning Policy Framework

7th March 2018

On Monday 5th March, the Government released the long-anticipated revised version of the National Planning Policy Framework [NPPF], which sets out national policy on planning issues.

The NPPF was originally published by the Coalition Government in March 2012. It has not been updated since, but has been the subject of several high-profile legal judgements and Ministerial Statements which affect the way in which it is interpreted and implemented.

The revised draft NPPF is more closely aligned with the current Conservative Government’s thinking and seeks to clarify some contentious issues. Many of the changes were trailed last year in the Housing White Paper, the Chancellor’s Autumn Statement, and related consultation papers.

Overview of the main proposals:

  • ‘Presumption in favour of sustainable development’ remains at the heart of the NPPF, albeit in a re-ordered form, but its twelve core planning principles are now dispersed throughout the document, rather than being listed separately. As expected, housing is the main subject of the proposed revisions.
  • Housing Delivery Test is to be introduced, alongside a standardised formula for calculating the five-year supply of housing land. There is also an increased emphasis on the identification of smaller sites in local plans, to widen housing choice and supply.
  • Local planning authorities will be encouraged to impose a 2-year limit on the implementation of planning permissions, rather than 3 years, while the renewal of unimplemented permissions will be discouraged. This measure is specifically designed to discourage perceived ‘land-banking’ by developers.
  • A return to the ‘brownfield first’ policy applied by the last Labour administration, densities should be maximised in sustainable locations, while the upward extension of existing buildings and the re-use of redundant retail and employment sites or premises for housing will be encouraged. This is coupled with a call for improvements in housing design quality.
  • Standardised assessment of housing need is to be introduced, aimed at increasing the delivery of affordable homes. Viability testing will no longer be required where a proposal is policy compliant. Local plans will be expected to promote specialist housing for students and the elderly, plus starter homes and homes to rent.
  • Protection for the Green Belt is maintained, with land release for new development being precluded unless all other reasonable options have been explored. There is increased protection for Ancient Woodland.

Partner Ian Sowerby added, “It’s rather disappointing that the government has decided to apply the big stick to housebuilders and developers before the publication of Sir Oliver Letwyn’s independent review into the main causes of the gap between the grant of planning permission and construction. Planning practitioners are well aware that a principal cause of delay is not so-called ‘land-banking’ but the speed of the planning system, particularly the imposition of too many unnecessary and overlapping planning conditions which must be formally discharged before a spade can be put into the ground. While the draft NPPF seeks to address housing supply at the local plan level, it has little helpful to say about removing delays at the delivery end of the process.”

Bell Cornwell’s strategic lead, Liz Alexander examined the key implications for strategic planning and has summarised these as follows:

  • Clarity will be provided for Neighbourhood Plans as each local planning authority will need to clarify the strategic policies to which neighbourhood plans have to accord.
  • Local planning authorities will also need to set out a housing requirement figure in their Local Plans for each designated neighbourhood area, which will establish the amount of housing land that the Neighbourhood Plan has to identify. Where this isn’t possible, an indicative figure should be provided if requested by the neighbourhood planning body.
  • Local planning authorities will have to review their strategic policies every five years, with reviews to be completed within five years of the adoption of the plan. This will be necessary, for example, if the objectively assessed housing need increases. This requirement will present a challenge for the many local planning authorities who have struggled to prepare their plans swiftly and will lead to a constant cycle of adoption and review.
  • The previously announced Statements of Common Ground to demonstrate that the Duty to Cooperate has been carried out effectively are included in the consultation draft, with more detail on their content and application to be set out in National Planning Practice Guidance.
  • The emerging NPPF confirms that the provision of affordable housing should not be sought for non-major developments – i.e. less than 10 units – unless in a designated rural area.
  • 20% of the sites identified for housing in local plans should be half a hectare or less. Neighbourhood Planning Groups should also consider the opportunities for allocating small sites suitable for housing in their area. This move is intended to encourage small and medium-sized housebuilders back into the market, to increase supply and buyer choice
  • The support for rural exceptions schemes has been expanded to encourage entry level exception sites, suitable for first-time buyers (or those looking to rent), located outside existing settlements and currently non-allocated.

Liz added, “It is much as expected, with, disappointingly, no change to the protection given to the Green Belt, and many of the same familiar phrases remaining, but some of them expressed more vaguely than before! I can’t see the new NPPF being particularly effective in freeing up the necessary land in the south east to meet our housing needs. However, I do welcome the emphasis given to the development of small sites, and the broadening of rural exceptions schemes to include homes for first-time buyers. I also welcome the change to the definition of deliverable to make it clear that some sites, including those with only outline consent or which are allocations in the development plan, can only be considered deliverable if there is clear evidence that they will come forward within the five year period”.

For more information on the recently announced draft NPPF contact us on either 01256 766673 or

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