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NPPF consultation

Members' views sought on the draft revised National Planning Policy Framework (NPPF)


The draft NPPF consultation is the culmination of at least three years of engagement from MHCLG (formally DCLG) about changes to the planning system. The Ministry have allowed just under 10 weeks to respond to their proposed draft.

As well as inviting written responses from its members, the RTPI will be holding roundtable discussions for professional planners in our regions to ensure MHCLG receives the best possible feedback on theese proposals. Details of these roundtables will be circulated by your regional coordinator.

If members would like to respond in writing, we ask that they do so by Wednesday 18 April 2018. Please send your comments to

Accompanying the consultation is also draft planning practice guidance for viability and a draft housing delivery test rulebook.

Visit the government website for the NPPF consultation


Initial Analysis


Achieving sustainable development

A small but significant change to the presumption in favour of sustainable development is proposed. The current Framework includes examples of policies, which provide a specific reason for restricting development. This is now proposed as a defined list, which is set out at footnote 7 and includes Ancient Woodland and aged or veteran trees. The accompanying note to the consultation states that this approach does not preclude other policies being used to limit development where the presumption applies, if the adverse impacts of granting permission would significantly and demonstrably outweigh the benefits. We would be interested particularly to hear practitioners' views on this.

Plan making

The draft proposes a number of changes to plan making policy. The key areas include emphasising the need to enable authorities to pursue the most appropriate strategy to meet strategic priorities, amending tests of soundness and encouraging better use of digital tools in consultation.

Decision taking (viability)

Proposals outlined in the  consultation planning for the right homes in the right places have been brought forward in this consultation, suggesting that viability assessments should be not be required where a proposal meets development plan expectations. However, perhaps more significantly is the proposal that viability assessments should use standardised methods and be made publically available.

Delivering a sufficient supply of homes

This new chapter brings forward a number of initiatives from MHCLG, which have been consulted on over the last three years.

It references a standard methodology for assessing housing numbers set out in planning practice guidance. The methodology consulted on before Christmas was designed to be simpler than currently exists, which will help remove long protracted delays at Inspection and speed up the plan making process, which needs to happen in order to bring certainty to the market in the shorter term.

However, the RTPI did raise concern at the time that the simplified housing demand-led targets will exacerbate existing trends – putting more emphasis where demand is already high and striking a blow to areas who have growth ambition but currently lack market stimulus to meet it. The planning system must ensure that places which now have lower targets do not have their growth and place-making ambitions stifled. We hope that the ethos of growth and place making, shown by the Secretary of State's enthusiasm for development corporations and New Towns, will be echoed by support for proactive and ambitious Local Authority Planning departments elsewhere in the country. This should be accompanied, as we have recommended in our paper on strategic planning, by a recognition that more needs to be done at a national level to tie together budgetary decisions with infrastructure and housing aspirations as well as support for public sector intervention in the housing market.

The Housing Delivery Test, also consulted on last year has also been brought forward, the guidance for which can be found in the draft housing delivery measurement test rulebook. The original guidance outlined a tapered approach to measuring housing delivery against local plan targets over 5 years. The draft NPPF maintains that authorities should have additional "buffer" of site allocations depending on delivery circumstances (up to 20%). As an initial requirement, the new NPPF would require authorities who are delivering under 95% against their targets to produce an action plan as to how to tackle under delivery.

As expected from the Housing White Paper, the definition of affordable housing has been widened in Annexe 2. The requirement for starter homes is included, although again as expected, the new policy now expects a minimum of 10% for affordable home ownership across the board (not specifically starter homes).

Promoting healthy and sustainable communities

We are pleased to see this chapter amended to recognise the additional roles that planning can play in promoting social interaction and healthy lifestyles. We have done significant work to promote this message, including our practice advnice note on dementia and town planning.

Promoting sustainable transport

It is also promising to see amendments show that planning policies should 'support an appropriate mix of uses across an area, and within strategic sites, to minimise the number and length of journeys needed for employment, shopping, leisure, education and other activities as well as a tightning of policy to link sustainable transport with opprununities to increase densification.

Making effective use of land

Previous proposals by MHCLG to promote higher density developments around commuter hubs have now been inserted in the relevant chapter but limited to a general requirement for minimum density requirements to be applied in such cases. The emphasis on applying substantial weight to brownfield development within existing settlements outlined in a Written Ministerial Statement in February 2018 has also been inserted. RTPI recognises the need for best use of brownfield land but also emphasises that as much weight should still be afforded to their location relative to public transport, employment and community facilities.

Achieving well designed places

We are pleased to see emphasis on good design remain in the framework. Perhaps most significantly, as we were prepared for from reading the Housing White Paper, is that policy is more specific in how good design should be achieved, for example, referencing the use of design codes and specific standards such as Building For Life. Again, we would be interested to hear members' views about how these can and have worked in practice.

Green Belt

Government has been clear in its intention to protect the Green Belt. Brought forward from consultations is that an exception can be made for affordable housing on brownfield land within the Green Belt subject to caveats. In a similar vein to RTPI's view on making effective use of land, it is important that such sites should also be well located in terms of access to public transport, employment and community facilities. In our consultation with members on where we should build new homes, we stress the importance of making Green Belt land work for everyone and to remember its purpose as a strategic planning tool.