Mixed reactions as the new NPPF arrives
With the release of the revised National Planning Policy Framework (NPPF) during what is turning out to be one of the hottest summers on record, much attention has turned toward how planning policy is guiding the adaption of cities to the challenges posed by climate change. This has been stoked by the publication last week of the Environmental Audit Committee’s (EAC) report setting out the risks posed to UK cities by the increasing regularity of extreme and unpredictable weather events.
Echoing the sentiments of many, that report has criticised the new NPPF for its lack of reference to development practices that exacerbate the effects of climate change, or guidance on what government and local authorities can do about it. At a time when there is pressing demand for quick housing, the EACs report calls for reducing support for modular housing, considered to be less effective at safeguarding against heat-health problems, and for greater attention given to tackling the urban heat-island effect, which see’s soaring temperatures in the country’s towns and cities.
These are just a few examples of how the finalised NPPF has left some feeling that feedback submitted in response to the draft NPPF guidance has not been reflected in the final document.
In placing the ambition of sustainable development at the core of the planning system, there is inevitably going to be close scrutiny of exclusions, refinements and changes to the new NPPF. We have selected a few of the stand-out topics which will be significant for the planning and development industry in the years ahead.
Entry-level exception sites
The draft NPPF released back in March of this year identified the importance of supporting the development of edge of settlement entry-level exception sites in meeting the housing need. Within the draft it was outlined that these sites should ‘be adjacent to existing settlements’ and ‘proportionate in size to them’. The finalised guidance has further caveated such sites, by introducing a limit to their size with footnote 33 stating:
‘Entry-level exception sites should not be larger than one hectare in size or exceed 5% of the size of the existing settlement.’
How this test is applied remains to be seen, but this could open up challenges as to whether the 5% test is to be based on number of dwellings or the settlement boundary area, which could ultimately be proving to act as a deterrence to development.
The housing delivery test
As set out in paragraph 215, the new Housing Delivery test will apply as of November 2018 which will seek to measure how Local Authorities are performing in terms of delivering new homes over the previous three years.
This nationally set figure will establish a local target for each planning authority through figures submitted by individual councils. The Ministry of Housing, Communities and Local Government have set out that the test will be ‘…a percentage measurement of the number of new homes delivered against the number of homes required’
This could ultimately prove to be a heavy burden for Local Authorities, who may find local plans falling out-of-date within a short space of time resulting in the forfeiting of control over the type and location of development.
Reduced time to Build
A central ambition of the new guidance is to aide Local Authorities in ‘significantly boosting the supply of Homes’. As part of this there will be more emphasis on Local Authorities addressing problem sites.
Set out within paragraph 76, the new guidance seeks to address the apparent disparity between the volume of planning applications granted permission and the number of schemes being built. It suggests that Local Authorities should seek to identify sites which have failed to produce development granted and could look to incrementally reduce the timescales afforded to developers between obtaining permission and starting on-site where a site has a history of non-delivery.
Undoubtably, the wider implications of the guidance will become clearer over time, but with it’s introduction only a few days ago, many are already accusing the Government of failing to take on board suggestions made during March consultation.
If you would like to find out more about how the new NPPF guidance will impact upon your land or development options, contact a member of the NJL Consulting team for an informal consultation.