What do planning policy changes mean for your development?
Richard Wooldridge, Director at HPA, and member of the Royal Institute of British Architects (RIBA) Planning Group, looks at the updated National Planning Policy Framework and what it means for planning and development.
In July 2018, the government introduced a revised National Planning Policy Framework document, known more commonly as the NPPF.
The original version of the NPPF was launched in 2012 in a bid to simplify national planning policy by consolidating all the national policies into one streamlined document.
The introduction of the first NPPF was seen as a success, and after six years, and a change in the balance of power at Westminster, it needed updating.
Changes in the updated document are also influenced by the recent government white paper ‘Planning for the Right Homes in the Right Places’ and the various ongoing attempts to speed up the delivery of new homes across the country.
Although some policies from the original NPPF remain unchanged; the 2018 version contains a few new policies and clarifications. This results in a longer document, which is a slight step backwards, but nevertheless a major improvement from national guidance pre-2012.
Four key areas which have changed are as follows:
Housing delivery targets
The new NPPF adds pressure to Local Planning Authorities (LPAs) to meet housing delivery targets; and includes a test in which LPAs can be assessed as a percentage by a simple calculation involving the housing delivery in the last three years and local housing target figure.
LPAs with poor housing delivery could be penalised by the government; which will put pressure on the LPAs to identify sites, keep their housing supply and needs data up-to-date and ‘incentivise’ slower LPAs to increase the speed of their decision making.
Definition and provision of affordable housing
This is one of the areas of policy which has seen the greatest change, and a great deal of welcome clarification. There are further clarifications as to what constitutes a small housing site, and new guidance on the composition and role of viability assessments to determine levels of provision of affordable housing within planning applications.
Interestingly, the weight on the outcome of viability studies has been reduced; with the individual planning officer being given greater power to decide as to whether the recommendations from a specific viability study should be adopted or ignored. The idea behind this is to give LPAs more power to resist planning applications which contain little or no affordable housing. There is widespread fear in the industry that this will simply lead to more planning refusals and in turn, more planning appeals.
There is an improved emphasis on design, although it remains to be seen how this will be realised, especially with the chronic shortage of architecturally-trained personnel within LPAs. This drive to improve design delivery must be backed up through the provision of additional resources and design expertise within LPAs; which could be delivered through the employment of appropriately qualified staff in-house, or a greater reliance on the use of design review panels.
A welcome addition to the NPPF is the Policy requiring LPAs to make sure that the quality of design from the original submission is realised through to the building on site. I expect that this will lead to the requirement for the design team to provide more drawings within the planning submission to allow LPAs to ‘tie down’ the design before work starts on site.
I have mixed feelings about how this may be realised; while I welcome any attempt in national policy to improve design quality, I worry about the lack of flexibility this new policy may create when the project is in the construction phase as every change may need to be agreed in advance with the LPA; and under-resourced LPAs are not very responsive to the demands of urgent queries. Quick decision-making and feedback are essential if a sudden problem is encountered during a live construction project.
In this area there has been a slight relaxation to national policies, asking LPAs to recognise that sites for local businesses and community needs may need to be ‘located adjacent to or beyond existing settlements, and in locations not well served by public transport’. This opens the door to sensitively designed and appropriate businesses locating away from settlements in the rural area, and certainly is of note for our rural-based commercial and leisure projects.
The new NPPF also contains a call for villages to ‘identify opportunities to grow and thrive’, which may meet resistance from those who want to protect the countryside from urbanisation. My personal view is that there is a balance to be struck; and controlled development can assist in maintaining and enhancing the provision of services in villages; which is to the benefit of all residents, especially the elderly and those who do not readily have access to private transport.
The new national policy does have immediate weight, but as ever, it will take a while for its implications to affect local policy, and also for grey areas to be ironed out through further clarifications and guidance from central government, or through precedent on decisions from the planning inspectorate.
Overall, we welcome the new NPPF, especially its emphasis on improving design quality and changes to the policies on rural planning.