There is no doubt the amendments to the National Planning Policy Framework (NPPF) set a clear direction of travel for the new Labour government. They recognise that changes to the planning system have the ability to stimulate economic growth, including the manifesto pledge to deliver 1.5m new homes over this full term.

Nick Stafford and James Smith from our Town and Country Planning Team welcome the changes to the revised NPPF consultation and give their insight into what they mean for the industry, drawing on the thoughts and comments of colleagues within Ridge disciplines actively working in sectors potentially affected by the proposed changes.

 

Simplified housing land supply

Whilst reference to the ‘standard method’ of determining housing land has remained, changes to the method provide a welcome relief to all who are looking for certainty on need and numbers.

The new method requires local authorities to plan for housing numbers that are proportionate to the size of existing communities. They need to take 0.8% of the existing housing stock as a baseline and then add an uplift based on the disparity between house prices and local incomes, using an affordability multiplier of 0.6%.

The government has published the impacts of this method, showing that annual housing requirements in England have risen from 305,223 to 371,541. London Boroughs have experienced the largest reduction, with almost a 20% decrease in required numbers, while some boroughs in the North East have seen housing requirements nearly double.

 

Green belt viability

Changes to ‘Protecting Green Belt land’ is one of the most significant alterations to planning policy. In essence, where short on ‘housing, commercial or other development’, there must be a review of green belt land. The sequence to finding suitable land must be previously developed land, then grey belt land, and only then other green belt locations. However, the most significant change is the requirement that any green belt land released for development must have at least 50% affordable housing included.

“If land released from Green Belt is transacted above the benchmark land value and cannot deliver policy-compliant development, then planning permission should not be granted…”

The overall message is lack of housing supply should result in development being considered on green belt land. A concern for developers will be that LPAs will still lean on ‘harm to green belt’ to resist release.

 

Grey belt and brownfield definition

Grey belt is defined as: “land in the green belt comprising Previously Developed Land and any other parcels and/or areas of Green Belt land that make a limited contribution to the five Green Belt purposes…”

This definition may be more of a token to support the grey belt buzz-word, however it helps support the focus on some areas of the green belt becoming acceptable for development.

As for brownfield land, Angela Rayner has said it would be expanded to include hardstanding and glasshouses. However, the NPPF has made no to reference to this. There is also no change to the definition of ‘previously developed land’. We believe both types of land could offer significant possibility for delivering more houses. We would like to see national planning policy updated to include a full definition of brownfield land to increase this potential.

The changes and clarity to housing supply and Green Belt considerations are clearly a positive for the industry. The weight to be given to a lack of supply when considering Green Belt sites is necessary clarification, but there may be some concern that the text provides several ‘get out of jail’ clauses when it comes to Green Belt release. This will not be a quick fix.

 

Nick Stafford, Town Planning Partner

 

Clash of economic and housing land

“Appropriate sites for commercial development which meet the needs of a modern economy should be identified, including suitable locations for uses such as laboratories, gigafactories, data centres, digital infrastructure, freight and logistics.”

Understanding how planning can support the economy with commercial developments is positive. However, we have concerns about how some councils will balance the need for significant areas of land to support these uses, whilst also allocating the larger amounts of land needed to support the Government’s primary ambition for 1.5 million homes.

Rennie Dalrymple, Project Management Partner, said the following regarding data centres: “Addressing data centre development in an updated NPPF is a positive move and gives the opportunity to recognise the importance of these facilities, how they underpin the UK economy and their impact on society as a whole. Recent events in the national news regarding the disruption of systems from media platforms, travel and payment services for example has highlighted how much data centres contribute to the functioning of commerce and society in general.

There are many elements of data centres that can easily be viewed in a negative light, from huge energy and water consumption, an often-austere building aesthetic and the fact they are not significant employers. With a greater profile in the planning landscape there is an opportunity to educate, policy makers, local authorities, town planners, and the rest of the Built Environment sector, as well as the general public to demonstrate data centres support and enable modern society rather than being a drain on resource.

We would encourage data centres to be allocated their own planning classification, but individual centres should be considered on merit before being considered part of national critical infrastructure.”

 

Leading on low-carbon

The election included a lot of talk about how a transition to a greener future could be achieved through renewable energy. Whilst the proposed NPPF only included minor changes, they are a step in the right direction. These changes will encourage councils to work with renewable energy developers to allocate land, and provide them with further reasoning to support any upcoming non-allocated proposals:

• Local authorities are required to identify suitable areas for renewable and low carbon energy sources rather than simply ‘consider identifying’. This is a positive change in encouraging infrastructure that would not normally be considered.
• It is now clear that LPAs should support planning applications for all forms of renewable and low carbon development. Also, ‘significant weight’ should be given to a proposal’s contribution to renewable energy generation and a net zero future.

Delivering clean power will help boost Britain’s energy independence, save money on energy bills, support high-skilled jobs and tackle the climate crisis. The UK Government has committed to doubling onshore wind energy by 2030 and this change will support this, also offering councils the opportunity for a future income stream and potentially significant contribution in meeting decarbonisation targets.

 

Chris Bradburn, Building Services Engineering Partner

 

A ‘vision led approach’ to transport

The proposed changes recognise the latest approach to planning of new communities and reducing car dependency as outlined by the Department of Transport.

This will strengthen our vision-led approach. There is increasing support for this method in planning of new communities and in assessing both planning applications and local plan evidence. The shift from investing in highway capacity improvements to the delivery of sustainable travel measures has been challenging. This change will enable us to deliver developments we can be proud of.

 

Sarah Matthews, Transport Planning Partner

 

What’s missing?

Two areas notably missing are any amendments to planning and flood risk, as well as conserving and enhancing the historic environment.

We had hoped to see the requirement for LPAs to consider how areas change over time when evaluating local impacts. This could have allowed for careful development of sensitive housing schemes in areas where heritage sites limit opportunities in otherwise sustainable locations.

I would have liked to see clarification on how the sequential test should be practically applied to all sources of flooding. 2021 updates to the NPPF increased the scope of the flood risk sequential test from coastal and fluvial flooding to all sources of flooding, including overland surface water runoff. Planning Practice Guidance updates in 2022 referenced this policy but did not provide clear guidance on how the sequential test should be practically applied to all sources of flooding. This has resulted in increased numbers of applications where surface water flooding has caused disproportionate difficulties and delays. We had hoped that clarification would be provided in updates to the NPPF, and we will be responding accordingly.

 

Brendan McCarthy, Flood Risk Partner

 

Our contributors would love to hear from you:

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

James Smith
Planning Senior Associate
Contact James at: jamessmith@ridge.co.uk

Sarah Matthews
Transport Planning Partner and  lead
Contact Sarah at: sarahmatthews@ridge.co.uk 

Brendan McCarthy
Flood Risk Management Partner
Contact Brendan at: brendanmccarthy@ridge.co.uk 

Rennie Dalrymple
Project Management Partner and Data Centre sector lead
Contact Rennie at: renniedalrymple@ridge.co.uk

 

Chris Bradburn
Building Services Engineering Partner
Contact Chris at: cbradburn@ridge.co.uk