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What is this blog about?
In this week’s blog, Property Elite consultant and Planning Consultant, Francesca Laugharne BSc (Hons) MSc MRTPI (francescalaugharne@gmail.com) discusses the update to the National Planning Policy Framework (NPPF) in December 2024.
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This is essential reading for all RICS APC Planning & Development candidates, as well as candidates undertaking any planning-related competencies. It will also be helpful reading for qualified Chartered Surveyors working in the planning field.
You can read the full NPPF here.
When were the changes made?
Following a consultation in September 2024, and a week after the government announced its ‘Plan for Change’, a major revision of the National Planning Policy Framework (NPPF) was published on Wednesday 12th December. Revising the NPPF is a key part of the government's plans to deliver 1.5 million homes during this Parliament, or 370,000 homes annually.
Why were the changes made?
The Ministry of Housing, Communities and Local Government in charge of Planning, states the policy changes made this week;
‘Reflect this government’s commitment to radically boosting the supply of housing, while delivering homes and places that are high-quality and genuinely affordable’.
Secretary of State for Housing Angela Rainer added;
‘Today’s landmark overhaul will sweep away last year’s damaging changes and shake-up a broken planning system which caves into the blockers and obstructs the builders’.
So what are the key changes introduced in the revised NPPF?
Housing requirement
To deliver the proposed higher level of housing, the Government has introduced a new Standard Method for calculating local housing need, which increases significantly the minimum level of housing that local authorities have to plan for.
The detail of the new Standard Method is set out in revisions to National Planning Practice Guidance which supports the NPPF. The change to the Standard Method is fundamental.
Rather than being based on population projections (latterly from 2014), the baseline now takes 0.8% of the current housing stock in the area - essentially saying that it needs to increase by 0.8% each year as a starting point.
This metric will be updated annually with a new uplift, derived from the Affordability Ratio taking a five-year average of earnings and house prices and increased according to a formula based on the extent to which that ratio exceeds five. There are no caps and the urban areas uplift introduced by the previous Government has been removed from policy.
This new approach is applicable immediately from the date of publication for decision-making in areas without an up-to-date Local Plan. As a result, many more local authorities may no longer demonstrate a five-year housing land supply.
The requirement for local authorities to maintain a five-year housing land supply at all times is reinstated and the controversial changes to remove the compulsory housing targets for LPAs in the previous NPPF (2023) are removed. The role of Neighbourhood Plans will continue to be of importance, with the protections retained for five years where these are up to date and allocate land for the delivery of new homes.
Green Belt policy
In the further interest of housing delivery and growth more generally, the significant changes to Greenbelt policy previously mooted by Labour have now been established in the new NPPF with the additional definition of Grey Belt.
This is defined as land in the Green Belt comprising previously developed land and/or any other land that, in either case, does not strongly contribute to the of purposes restricting sprawl or merger of towns or preserving the character of historic settlements.
Grey Belt land will be considered suitable for new housing where certain conditions are met, including an absence of a five-year housing land supply. The revised NPPF states that meeting housing needs is an ‘exceptional circumstance’ justifying a review of Green Belt boundaries where necessary for local plan allocations.
Where major development involving the provision of housing is proposed on land released from the Green Belt through plan preparation or review, or on sites in the Green Belt subject to a planning application, the NPPF introduces three new ‘golden rules’.
One of these is that a greater proportion of Affordable Housing is expected from Green Belt / Grey Belt land released for housing at a 15% uplift above the existing affordable housing policy requirement (capped at 50%). The NPPF does not allow for viability considerations to justify any reduction to this provision.
The other two golden rules relate to the provision of necessary infrastructure and access to quality open space for new residents.
Presumption in favour
The ‘presumption in favour’ of sustainable development remains in the NPPF, although it has been modified to clarify the circumstances in which it may apply where a Local Plan is out of date.
This includes consideration of key principles such as the sustainability of the location, the suitability of the land use, quality of design and provision of affordable homes.
In relation to design matters, the word ‘beautiful’ has been removed from the new version of the NPPF, with the goal of planning policy to ensure ‘high quality’ design.
Plan making & transitional arrangements
For decision making, the NPPF applies with immediate effect. This will have implications for applications currently being considered for determination at the application or appeal stage, and will inevitably lead to short term delays.
In respect of local plan making, transitional arrangements apply. LPAs must prepare and publish a Regulation 19 Local Plan prior to 12th March 2025 if they wish to use the 2023 version of the NPPF and housing requirements of the former version of the Standard Method.
This approach is only acceptable where the annual average housing requirement is over 80% of the most up-to-date local housing need figure calculated using the standard method set out in national planning practice guidance with a 20% buffer added after 1st July 2026.
In practice, the changes force LPAs to secure a new and up to date Local Plan using the new standard method ASAP, although in many cases this will require a new Call for Sites and other evidence-based work that takes time.
Are further changes anticipated?
In November, Minister Matthew Pennycook outlined that further changes to the NPPF would follow in 2025, along with the anticipated National Development Management Policies. In addition, a new Planning and Infrastructure Bill is expected next year, which will detail further changes to the planning system – including a national scheme of delegation, which may give more powers to professional planning officers and restrict the scope of elected planning committees.
The Government has stated a commitment to investment in planning professionals, including a further £100 million for Local Government Planning Officers which they intend to support a more effective and efficient planning system in the future.
In the short term, the implications of the latest NPPF update for the development industry will be sure to unfold in the first half of 2025.
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N.b. Nothing in this article constitutes legal, professional or financial advice.