Housing and Planning

Now that the final form of the National Planning Policy Framework (NPPF) has been around for some time we can review its implications in a slightly calmer environment.

Professional bodies generally see the final version as an improvement on the earlier draft. NHF and CIH welcome simplification of the system and the potential contribution to housing delivery. Some environmental groups are still taking a negative stance, especially regarding the presumption in favour of sustainable development (the impact of which has been over-hyped).

In relation to housing land supply, the NPPF requires local authorities to identify and update annually a supply of specific deliverable sites sufficient to deliver 5 years housing against their requirements with an additional buffer of 5% (reduced from 20% in the draft) from later in the plan period to ensure choice and competition in the land market. Where there is a record of persistent under-delivery the buffer can be increased to 20%.

The revised NPPF points developers more strongly towards brownfield sites but discourages garden-cramming. Councils can make an allowance for “windfall” sites so long as there is compelling evidence that such sites consistently come available.

The NPPF says councils should use their evidence base to meet “full, objectively assessed need for market and affordable housing … as far as is consistent with the policies set out in this framework”. The evidence base includes strategic housing market assessments and strategic housing land availability assessments.

For the first 12 months councils can rely on old plans even if they conflict with the NPPF. After that, weight will be given to old policies according to how consistent they are with the NPPF.

There are three major issues that will affect the delivery of new housing under the new planning system:

Deliberately planned under-delivery by councils that argue other factors limit land release and are influenced by public opposition to new development
The extent and pace of new housing development will obviously be constrained by economic factors – market conditions, mortgage availability, investment funding, and public subsidy regimes
In the absence of up-to-date plans in so many areas, we are likely to see a lot of decisions made on appeal following debate about the presumption in favour of sustainable development – it has taken a long time to get plans in place following the 2004 Act and current public spending cuts will make it difficult for councils to speed up the process.

Kim Penfold
June 2012