Places for People responds to today's National Planning Policy Framework
12 December 2024
Following last week's announcement of the National Planning Policy Framework (NPPF), we sat down with Dinny Shaw, Head of Planning, to explore its implications and whether it will help us achieve the goal of delivering 1.5 million new homes.
What are your initial thoughts on the new NPPF?
The new National Planning Policy Framework represents the seismic change needed in planning and demonstrates that this is a government listening to the sector. The right framework is essential, and the introduction of the grey belt definition is to be commended, as it will help bring more sites into scope. However, new definitions and a "brownfield-first" approach alone will not enable us to meet the government’s self-proclaimed ambitious targets.
While there is much to digest, these changes are generally positive. The new NPPF should facilitate the release of more land in sustainable locations for housing and communities, whether it be brownfield, grey belt, or green belt land. To achieve this, we need the right people with the right skills in local planning departments to translate these rules into planning permissions, so that we can deliver the much-needed homes.
Why do we need to address the skills shortages in planning?
Without sufficient personnel to grant planning permissions, policy can only go so far. It is vital to ensure certainty regarding the resourcing of Local Planning Authorities (LPAs), statutory consultees, and the Planning Inspectorate to address shortfalls in decision-making capacity.
The introduction of £46 million in funding for 300 new graduates and apprenticeships last October was a welcome step. However, training takes time, and 300 new roles equate to less than one new person per local authority. To meet the target of 1.5 million homes, we need to see a significant increase in planning permissions granted over the next two years—and for that, we need more people.
The NPPF’s provisions for increased planning fees for LPAs and proposals to enable LPA’s to set their own fees are a positive development, provided that these fees are ringfenced for planning teams, enabling them to adequately resource themselves. With the impending removal of the Apprentice Levy for certain Level 7 programmes, all financial support must be channelled towards properly resourcing the sector.
We must not forget as well the need to resource not just the planning teams within LPA’s but supporting technical and legal experts as well.
We would like to see more consideration given to streamlining and simplifying the planning system. Applying for planning permission has become overly complicated and costly over the last few years with numerous supporting reports now needed. There are plenty of opportunities to bring this forward, and it’s essential that all changes give consideration to SME’s who are disproportionately affected by the additional costs and time delays.
Other options include expanding the permitted development rights for householders or look to the use of technology, such as AI. Similarly promoting the use of Local Development Orders and Mayoral Development Orders particularly for strategic sites could simplify the process for these schemes. Any of these would reduce the strain on stretched planning officers and could enable precious resource to be redirected to key applications providing new homes and infrastructure. The NPPF has raised housing targets for all regions except London. Do you think this approach will work?
With over 1.2million people on social housing waiting lists, no one denies the need for more homes, and any targets or incentives to promote housing delivery should be welcomed. Clear housing targets from national government provides certainty to all parties as to what is required to meet that need. We’re fully supportive that local authorities should determine how and where to deliver that new development; they know their areas best and should therefore retain full control of their local plans.
But there’s no time to sit on our hands. Whilst we wait for NPPF and subsequent Local Plans to be embedded we need applications for sustainable development of new homes to be approved outside of local plans so developers can start building. We know the housing target is highly ambitious, but we must start with ambition—it is the only way to drive change and deliver homes that work for local people and meet local demand.
For this to work it will require collaboration between developers, local authorities, stakeholders and communities. And as developers, we must support local authorities in every possible way to make these targets achievable.
Brownfield, Grey Belt, Green Belt – will the reclassifications make a difference?
Absolutely. The fundamental aim of the Green Belt policy is to prevent urban sprawl – but it has hindered delivery of new homes and communities in areas most needed and in sustainable locations.
At PfP, we fully support a "brownfield-first" approach, as demonstrated by successful schemes across the UK, such as Port Loop, Park Hill, and East Wick + Sweetwater. However, this alone is not going to meet housing need across the country.
For too long, we have lacked a clear debate on the green belt and its definitions. The government’s provision of a new definition of grey belt has reopened that conversation. The clear classification and requirement for LPA’s to review Green Belt and identify Grey Belt when housing need cannot be met in full, will release more land for homes we need.
Developers are not seeking to concrete over large swathes of green land; instead, we aim to create thriving communities - like our development Brooklands, Milton Keynes - which are built in sustainable locations that meet local needs, provide infrastructure, and offer ample access to nature—the health benefits of which are undeniable.
We’ve been introduced to Golden Rules. Can you explain what these are?
The Golden Rules are criteria that developers must meet to obtain planning permission for Green Belt and Grey Belt land.
The most significant requirement is the Affordable Housing Golden Rule, which mandates that any development on Green Belt land must include at least 15% affordable housing on top of local policy requirements, capped at 50%. However, affordable housing is already more costly to build than housing for outright sale, presenting challenges for developers—particularly on sites where viability is already constrained or in lower value areas.
If this policy proves challenging to implement, there may be calls for increased investment in the Homes England Affordable Homes Programme to address viability issues and unlock stalled sites.
Will these changes make it more expensive for developers to apply for planning permission?
Potentially. The government plans to introduce regulations to increase fees for planning applications, including prior approvals, condition discharge, and Section 73 applications. Additionally, LPAs may be given the authority to set their own fees, which could result in increased charges to support outsourcing and ensure targets are met.
Developers are unlikely to challenge this as they are not averse to paying the right fee to LPA’s to ensure that there is the resource to deal with planning applications in a timely manner.
What had you hoped to see but didn’t?
I had hoped to see measures that promote stronger relationships between the public and private sectors. While the private sector plays a key role in delivering homes, organisations like PfP have the expertise to create multi-tenure communities that address local demand.
I would have liked to see policies encouraging strategic partnerships between public and private sectors to deliver public-interest-led collaborations. These partnerships could help acquire and deliver land to maintain a consistent pipeline of development.
What’s next? What should we now be looking out for?
We can expect further updates to the Planning Practice Guidance (PPG), including Green Belt reviews, viability guidance, carbon emissions, and vision-led transport planning. We’re waiting on the Planning and Infrastructure Bill as well as the Devolution Bill which is likely to have more impact on planning. The government also plans to consult on National Development Management Policies (NDMPs) to streamline the system and bring forward their Housing Strategy with the Spring Budget. These may include support for social and affordable rent, small site support, mixed-tenure communities, and size thresholds.
Change is definitely coming; we just need to make sure that it’s not managed in isolation and all plans are adequately funded to support the delivery of these homes.
At PfP, our focus extends beyond simply building homes. It is about creating vibrant, connected communities where people feel proud of the places they call home.