Introduction
Major proposed revisions to the National Planning Policy Framework (NPPF) and the planning system were published for consultation on 30th July. Whilst many summaries, blogs and articles rapidly appeared in print and on social media, this blog focusses on the implications specifically for plan-making.
Through the proposals the Government has signalled a clear and very welcome intention to strengthen the plan-led planning system and ensure universal local plan coverage by the end of this parliament. There will be staged implementation of changes to local plan making processes, with the need to consider the completion and adoption of local plans in the short term under the existing legal framework, and the introduction of new style local plans thereafter.
The proposed changes to the NPPF represent a key step in the new Government’s commitment to build 1.5 million homes in the next five years, not to mention the Government’s proposed new towns programme and Taskforce. Also important is the Secretary of State Angela Rayner’s written statement and letter to local authority Leaders and Chief Executives which accompanied the proposed changes to the NPPF. These are now material considerations for local authorities.
The proposed NPPF revisions (assuming they do not change dramatically) will undoubtedly have major implications for England and demonstrate a clear commitment to significantly increasing housing delivery nationally to boost economic growth, whilst recognising the key role that planners and local planning authorities must take to enable plans for economic growth to become reality.
There are major implications for local authorities in early stages of plan-making, particularly authorities whose local plans will not reach Regulation 19 Publication by the time the new NPPF is published. We describe the transitional arrangements in more detail below. In the meantime, there is a clear message that local authorities should continue with plan-making – albeit some will now need to take a step back (or sideways!) and others may now feel more incentivised to try and get an updated plan in place prior to the introduction of the new system given the extended deadline.
Here are some of the key changes:
Overhaul of housing need calculation method
Ending the use of household projections and approach to apply urban uplifts.
Introduction of a new "stock-based" approach which would increase the national housing target to about 372,000 homes annually. While London's target decreases, other regions will see substantial increases. Over 90% of local authorities will experience a rise in housing need numbers.
The new standard method for assessing housing need will increase the significance of affordability and reflect house price variation.
Meeting housing need
Revision of national Green Belt policy
Brownfield land, acceptable in principle
Support infrastructure delivery and the economy
Duty to Cooperate and strategic planning
Other proposed changes with implications for local plan making include:
Local planning authorities would be required to add a 5% buffer to their 5-year housing land supply calculations
Housing needs assessments would need to assess the need for Social Rent when undertaking needs assessments and reflect this in affordable housing policy criteria
Proposed revisions to local plan intervention policy criteria, which would be applied flexibly
Future exploration of accessible and interactive, web based national policy
Retention of the National Development Management Policies
Transitional Arrangements
The policies in the new NPPF will apply to plan making one month after its publication. The new NPPF is expected by the end of 2024. Funding will be made available for local authorities who will be required to now undertake additional work in modifying emerging plans as a result of the new NPPF.
The following transitional arrangements are proposed to apply to Local Plans and Spatial Development Strategies (SDS) from one month after the publication of the new NPPF:
If your Plan is at the Regulation 18 stage, you will need to produce your Plan under the new NPPF.
If your Plan is at Regulation 19 publication stage and your housing requirement is more than 200 homes less than the new proposed local housing need figure for your area, then your Plan will need to be prepared under the new NPPF and submitted within 18 months.
If your Plan is at Regulation 19 publication stage and your housing requirement is within 200 homes of the new proposed local housing need figure for your area, then continue plan-making under the current NPPF.
If your Plan has been submitted for examination, your Plan will be examined under the current NPPF.
If your Plan is a Part 2 plan that does not introduce new strategic policies setting the housing requirement (unless the Local Plan Part 1 was prepared under the new NPPF) it will be examined under the current NPPF. After adoption, if the Plan has an annual housing requirement within 200 dwellings of the new proposed local housing need figure for your area, you should start producing a new Local Plan as soon as possible to address the housing shortfall.
Transitional arrangements are also proposed for Spatial Development Strategies.
What happens next?
The consultation runs until 24th September 2024 and the revised NPPF is expected to be published by the end of 2024.
If all that wasn’t enough a new plan-making system as set out in the LURA is set to be introduced between summer and autumn 2025, which will transform how local plans are developed and implemented. Local Plans produced under the existing legal framework (regardless of which version of the NPPF they are being prepared under) will need to be submitted for Examination by December 2026. This represents an 18 month extension to the June 2025 deadline that many authorities have been working towards, and may now incentivise more authorities to work to get an up to date plan in place under the existing system.
How we can help
DAC Planning has extensive experience and understanding of plan making, and provides dedicated support to local authorities nationally.
For a discussion on how we can assist you, please get in touch with the team:
admin@dacplanning.com / 01206 259281
This information is for general informative purposes only. Whilst every effort has been made to ensure its accuracy, DAC Planning accepts no liability whatsoever for any direct or consequential loss arising from its use.
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