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Our wish list for the National Planning Policy Framework update

26 July 2024

The Kings Speech added limited further context about how planning policy will evolve under a Labour Government, leaving the industry now eagerly awaiting the updated National Planning Policy Framework (NPPF) consultation, which is due ‘before the end of the month’.

In advance of this, James Smith and Nick Stafford from our Town and Country Planning team, outline what changes they would like to see to encourage development and provide more certainty in the planning process.

1. Back to the future around housing need and supply:

We fully support government plans to re-introduce mandatory housing targets. We have seen the withdrawal or significant delay of local plans under instructions of members in direct response to the December 2023 changes to the NPPF. For local plans to be robust in their ambition and deliver to meet local need, a mandatory target is essential.

Similarly, re-introducing the requirement to demonstrate a 5-year supply of deliverable housing would be a much welcomed change. To reverse the negative effect seen across areas with an up-to-date local plan, or where progress has been made towards new policy. This would encourage local planning authorities to once again include a buffer to ensure a robust supply.

No need for radical change, a reverse of the previous damaging amends will get things moving. Although it may be necessary to review the standard method for calculating need to have a chance of meeting the manifesto pledge of 1.5million homes over the next 5 years.

2. Open the grey-belt to protect and enhance the green belt – what does this mean:

With the government’s references to prioritising ‘grey belt’ land there is a need for the NPPF definitions and policy to be updated to confirm what exactly what this means and if this differs from the existing ‘previously developed land’ (PDL) definition and policy.

Assuming “grey-belt” is merely a buzzword with the same definition, we propose removing the requirement that redevelopment of PDL is only acceptable when it does not have a greater impact on openness. We hope this change will shift the focus to how development can mitigate its impacts while enhancing the greenbelt through additional landscaping.

3. Finding balance in decision making:

Sustainable development has been at the core of planning for some time, with the goal being to secure mutually supportive benefits for economic, social and environmental objectives. Despite this, many planning applications are held in limbo or require significant alterations whilst one matter is considered unacceptable in isolation.

We would like to see the NPPF further encourage local authorities to take balanced and pragmatic views to support the delivery of housing. Whilst some matters may have a shortfall against standards, this should be understood and scheme should be considered on its wider merits and impacts of the changes requested, including time delays.

4. Evolution of Character:

‘Beauty’ was a clear focus of the last Conservative Government’s NPPF changes, and we do not expect this will be removed in the updates. However, we do hope there will be an acknowledgement that heritage and settings needs to be considered with the modern world in mind.

We believe the ‘London Plan’ captures this better and should be used in the NPPF. It confirms “local character evolves over time and will need to change in appropriate locations to accommodate additional housing…” (we have intentionally excluded the ‘on small sites’ ending to that line).

5. Common sense sequential tests:

Planning applications with minor fluvial or surface water flooding seem to be haunted by the looming shadow of the possible need for a sequential test. This process that can add significant costs, time and risk to schemes where flood risk can be easily mitigated.

Although the High Court case ‘Mead Realisations Ltd v The Secretary of State for Levelling Up, Housing and Communities & Anor’ may have clarified the interaction between the NPPF and Planning Practice Guidance, it does not address the issue that many sites are hindered by subjective requirements for extensive site reviews.

How can we help?

Our Planning team has an established track record in assisting developers of all sizes to promote and secure planning permissions for schemes across the UK. As an established built environment consultancy with 1,200 staff and 13 offices across the UK, Ridge can provide a broad range of early-stage pre-planning services for clients. These include:

Town and Country Planning
Transport Planning
Architecture and Masterplanning
Civil Engineering and Flood Risk Modeling
Geo-Environmental Assessments
Geo-Spatial Services
Sustainability

And many more to get your project moving.

For more information about our services and how we can help unlock the value of your land, contact:

Nick Stafford is the Planning Partner and Ridge Land Lead. Contact Nick at: nickstafford@ridge.co.uk

James Smith is Planning Senior Associate based in our Winchester office. Contact James at jamessmith@ridge.co.uk

Giles Brockbank is a Planning Partner based in our Cheltenham office. Contact Giles at gilesbrockbank@ridge.co.uk

Guy Wakefield is a Planning Partner based in our Cheltenham office. Contact Guy at guywakefield@ridge.co.uk