HGH Consulting


Sidestepping the Issue – proposed changes to the NPPF

hgh Associate Director Matthew Robinson shares his view on a revised National Planning Policy Framework (NPPF).

Maybe I’m being too cynical, but I can’t help but think that if you give people the option not to build new homes, then they probably won’t. Of course there are some incredibly proactive communities out there that encourage new homes and the benefits these bring. But in my experience, these are rare to come by. In my view, the Government’s proposed changes to the NPPF are a surrender to those communities who want the planning system to simply protect the status quo.

So here’s my melancholic summary of the proposed changes:

1) Meeting housing needs “in a sustainable manner” seems to be the Government’s way of saying, “or provide less if you want”;

2) There are two massive ‘get out of jail free cards’ for authorities that don’t want to meet objectively assessed needs: a) Green Belts are expressly not required to be amended, and b) densities significantly out of character with existing areas can be avoided;

3) Design codes will need to push for higher densities (but probably won’t);

4) Equally, neighbourhood plans continue to garner more prominence, particularly around the application (or not) of the presumption;

5) Plans submitted for examination are assumed to be justified, unless proved otherwise. This isn’t going to speed things up;

6) The standard method is now only an “advisory starting-point” – aka another ‘get out of jail free card’ – and it’s the urban local authorities in the top 20 most populated cities and urban centres that are required to pick up the slack. That’s not enough;

7) A greater focus has been given to meeting the needs of older people, which is a good thing with our ageing population;

8) “Oversupply” in previous years can now be taken into account, despite housing targets being minimum requirements. This does, however, allow for a more strategic and longer term view to be taken on delivery over the plan period – which isn’t a bad thing in a plan-led system;

9) The presumption applies where delivery falls below 75%, except where permissions have been granted for homes in excess of 115% of the authority’s requirement. This will help those authorities who permit a lot of homes but struggle to show delivery (which is often out of their control);

10) “Beauty” and “beautiful” are inserted numerous times, but not explained;

11) The section on mansard roofs is frankly absurd for a strategic planning document such as this;

12) The text around demonstrating “exceptional circumstances” remains, but is all but defunct now that there’s no longer a need for local authorities to amend Green Belt boundaries if they don’t want to. The “very special circumstances” test remains untouched, so perhaps we’ll see more applications for development in the Green Belt under that method moving forward. This is not good planning!

13) A greater emphasis has been given to supporting energy efficiency improvements in existing buildings (which is very important), but not much is said about improving the standards for new buildings (unless that is to be ‘built in’ to building regulations over time which would make sense);

14) Greater protections are given to agricultural land that is used for food production;

Ambitious Plans?

A national planning framework – particularly in difficult times such as these – should be a bold and visionary document that sets ambitious plans for the country’s future. These revisions suggest the opposite and sidestep the real issues and priorities of today.  


Image: Possessed Photography on Unsplash


Matthew Robinson, Director, hgh Consulting
[email protected]

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