NPPF Consultation
Another NPPF consultation!
The new Government's Proposals for the National Planning Policy Framework, and Standard Method for calculating housing numbers.
Consultation to 11.45pm on 24 September
On its web page, the Ministry of Housing, Communities & Local Government gives an outline of its proposed changes to the NPPF; guidance on its consultation and its reasoning, and a table of all the questions posed.
Also a copy of the NPPF Draft Text for Consultation with tracked changes.
Please take time to have a look and respond on issues of interest to you.
Thoughts on the general theme of boosting housing numbers:
1. Headline is the new Standard Method
The previous Government’s Standard Housing Assessment Method was based on demographics and an ‘affordability ratio’. The affordability ratio was much criticised as artificially inflating figures and being flawed in concept.
Labour’s new Standard Method is based on current housing stock and a yet stronger ‘affordability uplift’ which will give Hart a housing allocation (on one calculation) of 734 instead of 297 homes per annum, come its Five-year Review.
Hart
Proposed standard method (per 1,000) 17
Proposed standard method figure 734
Current standard method figure 297
Current Local Plan 423
Average delivery (3y average) 580
https://lichfields.uk/blog/2024/july/30/a-new-standard-method-stocking-up
See the Government website Consultation guidance:
Chapter 4 A new standard method for assessing housing needs.
Question 16 asks: Do you agree that using the workplace-based median house price to median earnings ratio... to adjust the standard method’s baseline, is appropriate?
Question 17: Do you agree that affordability is given an appropriate weighting within the proposed standard method?
A criticism of the premise that increasing housing figures will lead to building more houses – which will cause prices to fall – is that this can’t be realistic in a housing market where developers manage supply to ensure profit margins.
Responsibility of Local Planning Authorities (LPAs) doesn’t extend to the onsite delivery process. Buildout rates are controlled – and sites with planning approval may be banked – to suit market conditions, not to meet housing targets. These issues should surely be acknowledged when formulating Policies intent on increasing numbers.
2. The Five-Year Housing Land Supply
Not at this present moment an issue for Hart which 1- has a strong supply of deliverable housing, and 2 - is not required to declare a land supply position as per provisions of the NPPF Dec 2023.
However.... in principle....
The housing land supply policy intends that Local Planning Authorities (LPAs) have a constant supply of identifiable and deliverable housing land sufficient to meet their Local Plan housing figures.
The problem is that the penalties for falling behind the required land supply provision are damaging to the LPA and advantageous for developers. Yet once planning permission is granted, the housing delivery process is subject to many variables including developer and landowner decision making. On this basis the answers to the question below would be ‘NO’.
Q 7 asks: Do you agree that all LPAs should be required to continually demonstrate five years of specific, deliverable sites for decision making purposes, regardless of plan status?
One set of (positive) changes made in the Dec 2023 NPPF was to reduce land supply requirements in some circumstances; and remove the need to demonstrate them in others. There is a strong argument that this supports Local Plan-making and supporta planned (as opposed to unplanned) development.
The NPPF Draft Text for Consultation reverses all the Dec 2023 provisions to reduce land supply requirements; tracked changes mark them for deletion.
If an LPA is unable to show sufficient housing land supply, the penalty is a weakening of its Local Plan housing policies (which are deemed to be out of date). Planning decisions default to the NPPF’s presumption in favour of development; the LPA’s ability to defend its planned Housing Strategy is undermined; its vulnerability is much greater to unplanned housing on green fields attractive to developers.
The Dec 2023 land supply provisions aimed to support Plan-led development. The Consultation proposals encourage opportunities for a cycle of speculative applications – negating the value of an arduous process of Plan-making – taking up more Planning Officer and Inspectorate resources, while allocated housing land can be banked.
3. Strengthening... the presumption in favour of sustainable development
To consider these proposals in light of the need to support a Plan-led approach and questions regarding re realities and practicalities of housing delivery as raised above when considering increasing the claim for housing numbers above all else.
Please take some time to consider the many other Proposals on the Government website.
for eg on social housing; character, density and removing urban uplift; removing references to ‘beauty’; green energy; support for key growth industries; proposals for brownfield and agricultural land.
Please respond online or via email to [email protected]