Daniel Slade is the Policy Manager at the Royal Town Planning Institute.
The government has published its new version of the NPPF following a year of consultation. While we were encouraged to hear the Secretary of State speak about the importance of planners and planning putting the ‘heart into communities’, commentary on the new NPPF’s contents is probably needed so it can be properly implemented.
While I wouldn’t agree with those commentators who have described the document as a “damp squib” or “the least interesting of what was published”, it’s clear that we can divide the government’s proposals for this draft into the three broad categories: The headliners, the support acts, and those proposals that have gone AWOL. The first category will cause the biggest changes to planners’ day jobs, but it is the last category that contains the surprises.
The headliners: Housing need, supply, and the green belt
As the RTPI laid out in its response to the consultation, one of our biggest concerns about the government’s proposals for the NPPF was that they would result in few incentives for local decision makers to plan for enough housing to meet local needs. We described a ‘pincer’ on new development: one half was the strengthening of policy constraints such as the green belt and densifying development not threatening local character in urban areas, the other was the softening of the expectation that planning authorities maintain a five-year housing land supply.
We’ve ended up with a document that strengthens the language around those policy constraints, even if it does not introduce much new substance. But planners know that language matters. On green belts, it now very directly states that there ‘no requirement for Green Belt boundaries to be reviewed or changed when plans are being prepared or updated’, and that green belts should only be reviewed during plan making or updating. The proposed measures on densification not being suitable when it would be out of character with its surroundings have materialised, but only where an existing design code suggests this would be the case.
A more detailed analysis may tell a different story, but it seems that while the policy barriers are less extreme than envisaged, for some local decision makers there remains a lack of incentives to proactively plan for new housing, and the new language of the NPPF is unlikely to convince them to do so.
As we argued in our consultation response, this places more importance than ever on strategic planning. Or, in other words, on housing needs being met beyond the local authorities that face those constraints but are within the same housing market area. This is particularly important for those urban areas affected by the ‘urban uplift’. But strategic planning across England remains underpowered (something we have recently commissioned research on).
This situation also makes local leadership and resourcing more important than ever. These policy obstacles to new development are not insurmountable. Though it continues to be the case that green belts’ boundaries will only be altered where ‘exceptional circumstances are fully evidenced and justified’, forward-thinking LPAs with good resourcing and local leadership can still make the case for it where appropriate. Yet again, the crux of the issue is the provision of sufficient resources and strong local leadership that’s willing to be ambitious.
Support acts: Community-led housing and beauty
After these headliners come a raft of support acts. We were positive about many of these proposals in our March 2023 response.
Right at the top of the document is an emphasis on maintaining up-to-date local plans as a means of achieving the NPPF’s objectives has been added. Moving through it, there are additional and welcome references to planning for community-led housing, and ‘beauty’ also features more heavily. Though many of the latter additions may not be ground-breaking, a stronger emphasis on the use of planning conditions and ‘clear and accurate plans and drawings…’ as a way of preventing the drop-off in design quality often seen between approval and construction featured in the consultation and is good to see in policy. So too is a more explicit mention of the types of homes older people may need, and an added paragraph stating that ‘LPAs should give significant weight to the need to support energy efficiency and low carbon heating improvements to existing buildings’. Few would argue this isn’t a good thing.
AWOL: The Duty to Cooperate and ‘justified’ local plans continue
Looking back at the government’s December 2022 proposals, this is where the surprises are. Chief among them, the Duty to Cooperate remains in the NPPF, as does the need for local plans to be ‘justified’ – its removal was one of our biggest concerns about the original proposals, so this is a major victory.
More disappointingly, there have been no revisions to place more weight on the provision of homes for social rent, despite a question on this topic, and nothing on methods and measures for carbon impact assessment, nature-based adaptation, or climate change adaptation more generally. The latter may well be dealt with in the NDMPs, which the LURA will require have regard to climate change.
There is similarly nothing on build-out, with Gove waiting until the Competition and Markets Authority has published its housebuilding market study (something the RTPI has responded to), and the LURA taking up related themes.
Finally, the NDMPs featured in the initial consultation, but we’re going to have to wait longer to hear about their proposed contents. That’s a treat for the new year, and one of the key themes of this NPPF: Wait and see. The Secretary of State’s written statement to the House of Commons suggests that many of the changes trailed in the run up to the NPPF’s launch will actually be coming through addition policy and guidance.
