Delivered just in time for the festive season, the update to the NPPF has landed – and promises to reshape housing delivery, reform Green Belt policy and promote collaboration between local authorities, all aimed at meeting the UK’s ambitious housing targets.
So, what has changed? Here are our key headlines of the new NPPF:
- Strategic Working The “Maintaining Effective Cooperation” chapter of the Framework has seen the introduction of a number of new paragraphs, making way for more strategic working between authorities.
- Housing Land Supply As promised by the draft, the allowance of a 4-year housing land supply for qualifying authorities has been removed. Instead, where a plan has been recently adopted but is looking to achieve only 80% or less of its housing need, a 6-year supply will be necessary. Thereby placing further incentive on adopting a robust new Local Plan that meets the local housing need.
- The Presumption Paragraph 11 d) ii. has been expanded to explain what the decision-taker should have regard to when assessing whether any adverse impacts of granting permission would significantly and demonstrably outweigh the benefits – including directing development to sustainable locations, making effective use of land, well-designed places and affordable housing provision.
- “Beauty” All reference to “beauty” has been removed and replaced with an emphasis on high quality design. This in effect will retain the element of subjectivity around this topic.
- The Buffer From 1st July 2026, a 20% housing supply buffer requirement (equivalent to a 6YHLS) will be applied where an LPA has a housing requirement adopted in the last five years. Authorities whose annual average housing requirement is 80% or less of the most up to date local housing need figure [calculated using the new standard method] will also be subject to the 20%.
- Green Belt The purpose of the Green Belt remains unchanged, but with greater emphasis on the acceptability of previously developed sites if a scheme “does not cause substantial harm to the openness of the “Green Belt”. In such cases, development is no longer seen as “inappropriate”.
- Grey Belt Now defined: “… land in the Green Belt comprising previously developed land and/or any other land that, in either case, does not strongly contribute to any of the purposes (a) [restrict sprawl], (b) [merging of towns], and (d) [special character of historic towns]. “Grey belt” excludes land where the application of policies relating to the area or assets would provide a strong reason for refusing or restricting development”. Whilst no reference to specific uses, e. golf courses or previously worked land, the “and/or” [our emphasis] reference will no doubt provide some useful appeal fodder!
- The “Golden Rules” For major residential development in the Green Belt should meet the following: a) affordable housing at 50% or until policies are place or 15% above “the highest existing affordable housing requirement” which would otherwise apply, with a 50% cap, b) necessary improvements to local or national infrastructure and c) provision of new or improved green spaces that are accessible to the public. New paragraph 158 is clear: “a development which complies with the Golden Rules should be given significant weight in favour of the grant of permission”.
- Brownfield Land Para 125 c) includes new wording that provides a much stronger presumption in favour of approving development on brownfield land where “..substantial weight should be afforded to using suitable brownfield land within settlements for homes and other identified needs, proposals for which should be approved unless substantial harm would be caused” (our emphasis).
- Flood Risk Assessments A new exception explains that sequential tests should not be used where a site-specific FRA demonstrates no ‘built’ development (including access or escape routes) would be located in an area at risk of flooding from any source now and in the future. Further PPG meat to add to the bones of this exception are however warranted and will no doubt be played out at appeal.
- Local Plan preparation Policies in the new NPPF will apply from 12th March 2025, unless – insert multiple caveats here. Highlights include: before this date a Local Plan has been submitted for examination, or a Local Plan has reached Reg. 19 stage and its draft housing requirement meets at least 80% of its local housing need using the new standard method.
Beyond the NPPF
We also note the special delivery of:
1 The new standard method for calculating housing need for each authority have been published to make way for the 370k new homes nationally per year;
2 Housing delivery test scores for 2023 are in! These results set out how each authority has performed against its housing need over the last 3 years;
3 The PPG has also seen updates on plan-making, viability, housing supply, housing and economic needs. But all eyes on January 2025 for the further release of more PPG updates on green belt reviews and grey belt…
4 Funding of £150 million towards new planning officers.
Putting into practice
We very much looking forward to putting this new guidance into practice to help our clients deliver great projects. Do get in touch if you want to know more about what the revisions to the NPPF might mean for you.
