The UK Government’s National Planning Policy Framework (NPPF) has undergone several revisions in recent years to reflect changing political priorities, environmental concerns and economic realities. The draft revisions to the NPPF (“NPPF24”) have been in consultation for eight weeks, concluding on Tuesday 24 September 2024.
Following the bold statement from the newly elected Labour Government to “get Britain building again”, the planning and construction industry has been waiting in anticipation for the final NPPF.
Key Changes to the NPPF
The NPPF, first introduced in 2012, serves as the central policy framework for planning decisions in England. It outlines principles that local planning authorities (LPAs) must adhere to when considering planning applications. Over the years, the NPPF has been amended to emphasize housing delivery, sustainability and design quality.
Some of the most notable changes introduced by the Labour Government in July included:
Housing Targets.
One of the key changes is the re-introduction of housing targets. Previously the NPPF included a standard method for calculating housing needs, which set housing delivery targets for local authorities. These targets have been controversial, with some local authorities arguing that they are too high, especially in areas with environmental constraints.
Recent changes to the NPPF have introduced some flexibility, allowing local authorities to challenge these targets based on local circumstances, such as Green Belt constraints or environmental protections.
However, to push the housebuilding efforts, Labour has re-introduced Housing Targets. This includes new mechanisms to intervene if councils fail to meet these targets through new powers for Central Government. Housing targets are no longer “advisory” and Local Councils must meet them.
Environmental Sustainability
The NPPF has been updated to reflect the UK’s legally binding commitment to achieving net-zero carbon emissions by 2050. Recent changes require developers to place a greater emphasis on sustainability, particularly in areas of energy efficiency, biodiversity net gain (BNG) and flood risk management. In the updates, it outlines that Local Planning Authorities should support proposals for all forms of renewable and low-carbon development, with the emphasis that these proposals’ contribution to a net zero future should be given significant weight.
Green Belt, Brownfield and the introduction of Grey Belt Sites
The protection of Green Belt land has always been a key feature of the NPPF. However, there has been a renewed focus on what defines this, with an emphasis on urban regeneration and the densification of existing urban areas.
LPAs will be required to review their Green Belt boundaries during local plan preparation in exceptional circumstances, including if they are unable to meet an identified need for housing or other development.
In addition, a new definition of Grey Belt has been introduced into the NPPF. This offers guidance as to where revisions to Green Belt boundaries should take place. Under the proposed revision, Grey belt is formally defined as land in the Green Belt comprising of previously developed land, or land that makes a limited contribution but with some exclusions, such as areas or assets of particular importance. These are for example habitat sites, SSSI, local green space, AONB, National Parks and heritage assets.
No more “Beauty”!
Some of the more subjective terminologies in NPPF have been removed or replaced. Perhaps most notable is the removal of all references to “beauty” and “beautiful” as they are deemed as simply too subjective and lead to inconsistent decision-making in developments in England. This has resulted in reversion to more technical language, such as ‘high quality design’ rather than terms such as ‘beautiful’. In addition, Labour advocates the National Model Design Code or local design codes as the basis for assessing and refining any proposed development.
Support for Infrastructure
There has been an increased focus on ensuring that developments are supported by appropriate infrastructure. The NPPF encourages LPAs to work closely with developers to ensure that transport, schools, healthcare and other essential infrastructure is planned alongside housing developments. This is intended to address concerns that new housing has often been delivered without the necessary infrastructure to support the resulting growing populations.
What does the changes mean for our clients?
The changes to the NPPF present both challenges and opportunities for developers and housing providers.
Housing delivery targets remain a contentious issue, especially in areas with limited available land. The focus on brownfield sites and urban regeneration can make it harder for developers to find suitable land for new housing developments, particularly in more rural areas. However, where green belt boundaries and grey belt areas have been redefined, this may present new opportunities, as local authorities seek to meet housing needs within constrained land supplies.
The push for greater sustainability also presents challenges for developers, particularly in terms of meeting higher environmental standards. Incorporating renewable energy solutions, ensuring biodiversity net gain and using sustainable materials can increase upfront costs. However, these features can also increase the long-term value of developments, particularly as buyers and tenants become more environmentally conscious.
There is also an increased focus on high-quality design and local design codes, meaning that developers must pay closer attention to the aesthetic and functional aspects of their proposals. Whilst this presents an opportunity to create more attractive and marketable developments, it can also increase costs and prolong the design process with more regional Design Reviews required. Developers must now engage more proactively with local communities and planning authorities to ensure that their designs meet local expectations and design codes.
How do our clients navigate through all the changes?
At the rpa:group we collaborate with our clients right at the beginning of the design process, through a series of feasibility studies and viability assessments that are tailored to the client’s individual needs. We incorporate National Design Guide, Design Codes and local planning policies from the outset and facilitate pre planning discussion to ensure proposals are considered and that concerns are captured and addressed before final submission.
Early engagement in the planning process enables us to help our clients to navigate the complexity of the revised NPPF and ensure that proposals are both economically viable, compliant with planning policy and reduce the risk of costly redesigns or delays.
In recent schemes, we have worked closely with local authorities to ensure that the local design code was embedded into the scheme from the beginning and that the design reflects local character and aspirations. We were also able to enhance the BNG, ensuring that there were opportunities for biodiversity to thrive in the future. Drawing on our internal expertise in planning and working with the Planning Officers, we were able to ensure there was a true balance between design quality, public benefits and financial feasibility for our client.
Whilst the changes to the NPPF present challenges for developers, they also offer opportunities to create better-designed, more sustainable developments. We believe that engaging the right design expertise, with knowledge of planning policy, is key to successfully navigating the evolving planning landscape. By working closely with developers, multi-disciplinary consultancies such as the rpa:group, helps to ensure that new developments meet the needs of both the market and the broader community, while also complying with increasingly stringent planning requirements.
