Radical, lasting reform or minor tweaks?
Despite providing national planning policy for all forms of development, it is clear that the revised NPPF is focused on housing. This is evident from the opening gambit laid out in the accompanying consultation documents that states “This country does not have enough homes.” It goes on to state “The Government is clear that the country needs radical, lasting reform that will allow more homes to be built.”
The consultation runs until 23:45 on the 10 May 2018 and is open to everyone.
So, does the revised NPPF provide radical, lasting reform or is it just minor tweaks to the system?
- Revisions to the presumption in favour of sustainable development that include redefining which policies are “out of date” and having a defined list of policies in the NPPF that would result in refusal of permission (Footnote 7 previously Footnote 9);
- Inserting issues regarding viability and the need for viability reports with applications;
- Clarity that prematurity is unlikely to be a justified reason for refusal;
- The introduction of the standard national housing need methodology;
- The inclusion of thresholds for affordable housing contributions previously contained in the Planning Practice Guidance and Written Ministerial Statement;
- Support for small scale sites through the need for LPAs to ensure at least 20% of sites identified for housing in plans are of half a hectare of less;
- Identifying thresholds for when the presumption in favour of sustainable development will apply (75% of housing need by 2020);
- “Fixing” 5 year land supply positions for a year subject to criteria;
- The potential to reduce the implementation time for consents and for major housing consider why previous development on the same site did not progress;
- A whole new section on “Making effective use of land” that emphasises a need for efficient use of land previously taken out of policy.
- The inclusion of policy on parking standards;
- The ability to redevelop brownfield land in the Green Belt, particularly for affordable schemes where there is no substantial harm to openness;
- Increased protection to National Parks and AONB’s where development should be limited.
On the face of it, the revised NPPF is bringing forward a lot of previous policy and guidance, including changes mooted by the Housing White Paper. It would seem that the impact of this revised NPPF will only be tested through time, but it is our initial opinion that the changes are likely to lead to more confusion in the short term, particularly when it comes to the use of the presumption in favour of sustainable development.
We will continue to follow the progress of the NPPF through the consultation process.