Unpacking the new draft NPPF.
T’was (almost) the night before Christmas, when all through the house. Not a creature was stirring…but DLUHC decides to launch its consultation on proposed changes to the NPPF.
While many of the changes outlined in the new draft NPPF were trailed by SoS Michael Gove in the weeks prior to its publication, we had to wait for some of the finer detail to emerge. The timing was in some ways political mastery – get the headlines you want first and then publish the full details just prior to Christmas when nobody’s looking.
A case of spin over substance, then? While some of the measures don’t, on the surface at least, quite match the rhetoric in the press, there are a few things to be aware of.
A missed opportunity?
Several of the measures from the new NPPF will need to be tested at examination or appeal for us to really find out the true implications of what’s being proposed.
But what we do know is that the proposals are in some ways at odds with what’s needed to tackle the housing crisis present across the UK, fuelled by a huge shortfall in supply. Shelter estimates that 17.5 million people are impacted by the crisis – living in overcrowded, dangerous, unstable or unaffordable housing.
Some of the changes contained within the draft NPPF could result in a drop in housing delivery. One example is removing the requirement for local authorities to review the Green Belt if this would be the only means of meeting the objectively assessed need for housing over the plan period.
The Liberal Democrat administration in Mole Valley is already proposing to remove all Green Belt sites from its Local Plan, currently with the Inspector, following the publication of the revised NPPF. We can expect others to follow.
Meanwhile, other authorities may refer to local characteristics (e.g. a high student population) to justify the use of an alternative method of assessing housing need.
That said, the new draft does mention that the aim should be to:
meet as much housing need as possible with an appropriate mix of housing types to meet the needs of communities
… a point which should be welcomed.
Focusing on ‘beautiful’
Four additions of the word ‘beautiful’ have been included in the draft NPPF. At the same time a greater emphasis has also been placed on the use of Design Codes – we can expect more authorities to adopt these in the future.
While we can all agree of the need to have well-designed homes and communities, it is not the silver bullet to reversing community objection that many think it is. Focusing on maximising the genuine social value generated from new development through meaningful engagement is a much more effective way of winning the hearts and minds of the community.
More delays?
Not much is certain in life apart from death, taxes and delays to local plans. In the immediate term, the latest announcements will embolden some local authorities to take stock and wait to ‘benefit’ from the changes, particularly if there is any wiggle room to be found regarding how many homes they will need to deliver over the plan period.
Over the longer term, the changes may speed up plan-making for some authorities will be required to start work on new plans by, at the latest, five years after adoption of their previous plan, and to adopt that new plan within 30 months.
What’s LURB got to do with it?
The Government hopes to roll out the proposed changes to the NPPF as soon as possible following the consultation. However, alongside these specific changes, the Government signals areas that it expects to consider in the context of a wider review of the NPPF to follow Royal Assent of the Levelling Up and Regeneration Bill (LURB), expected later this year.