The ‘Housing Crisis’ – Does the New NPPF do Enough?

1st May 2018

On 5 March 2018, the Government published its long-await draft revision of the National Planning Policy Framework (NPPF).  This document consolidates a series of proposals that have been mooted over the last two and half years.

Bell Cornwell published its overview of the main proposals on 7th March, which can be found here.

However, we have now had time to consider this major planning update and can comment further on the potential effectiveness of this document.

It would seem that, at face value, the NPPF review is primarily about housing and how to address the UK’s ‘housing crisis’.  The draft NPPF has been accompanied by the release of a number of supporting document’s, Government documents and further releases including:

  • Supporting Housing Delivery Through Development Contributions consultation
  • Housing Delivery Test: draft measurement rulebook
  • Government responses to both the Housing White Paper and the Planning for the Right Homes in the Right Places consultations

However, amendments to non-housing related parts of the NPPF could also have an impact.

As far as plan-making is concerned, in allocating sites to meet the need for town centre uses, it is proposed that policies should look at least ten years ahead but not necessarily over the entire plan period, in view of the difficulties of longer-term forecasting.  The requirement for office development proposals (above a certain floorspace threshold) outside of town centres to be supported by an impact assessment is proposed to be removed.

Other changes can be found in Chapter 14 of the draft NPPF ‘Meeting the challenge of climate change, flooding and coastal change’, as the revised text clarifies that plans should have regard to the cumulative impacts of flood risk, rather than just looking at the flood risk impact of individual development sites.

What is interesting is how much the draft NPPF and the draft London Plan have in common, they are far more closely aligned than might be expected.  Polices on small site allocations, benchmark land value calculation methodology, viability assessments, affordable housing, higher densities in town centres and around transport hubs and further tightening of Green Belt policy are just some of the ways the documents align.  We welcome a coordinated planning approach between Government and regional/ strategic authorities, but what works for London where land values and pressure on housing delivery is high, may not work for the rest of England.

The draft NPPF still has a presumption in favour of sustainable development, but this needs to be backed up with economic evidence, which will also remain a key driver in planning decisions.

Given the lengthy build-up to its release, we are unsure if the draft document is sufficiently different to spearhead the necessary changes required to speed up the system and assist in delivering development. It would seem that the key issue for plan-making remains unresolved.  It will also be interesting to see how the Government deal with the consultation responses that come in ahead of the planned release of the final document this summer, as their own timetable is tight.

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