The long awaited revised NPPF was published on 24th July 2018 alongside several supporting documents. The document retains a pro-growth stance, continuing to place its emphasis on the Government’s objective of significantly boosting housing supply in order to meet the target of building 300,000 new homes a year by the mid 2020s.
The revised document is now beginning to have an impact in practice with some policies having been tested through planning appeals. As a result we believe the following elements can offer enhanced opportunities for our clients:
- There is an increased emphasis on the delivery of housing with the introduction of the Housing Delivery Test (commencing November 2018) and a new definition of ‘Deliverable’ in the glossary. The latter now requires Councils to demonstrate through clear and robust evidence that housing development will begin on site within 5 years. As a result a number of Council’s housing land supply positions have been challenged with Inspectors finding in favour of appellants allowing residential development in the context of the presumption of sustainable development where previously it would have been resisted.
- Councils are now encouraged to promote a new form of ‘entry-level exceptions site’ specifically providing homes suitable for first time buyers on unallocated sites adjacent to existing settlements. These sites are to be no more than one hectare in size or the development should not exceed 5% of the size of the existing settlement (does not apply in National Parks, the AONB or Green Belt). Unlike traditional rural exception sites however, there is no mention of the land being used for affordable housing in perpetuity meaning that theoretically there could be potential for a future change to market housing. Furthermore Councils are able to consider an ‘element of market housing’ in order to help facilitate landowners bringing sites forward for development. This therefore offers potential for small sites to come forward in the short term.
- A subtle change to green belt policy now allows for residential development that contributes to local affordable housing on brownfield green belt sites, so long as it does not cause ‘substantial harm’ to green belt openness. This test has been established as a ‘high bar’ in a recent appeal decision. In essence, this provides a somewhat more flexible approach for the redevelopment of previously developed sites in the green belt than before as long as affordable housing is included and the harm to the green belt would not amount to being ‘substantial.
Small and Medium Sites
- Councils must now ensure that at least 10% of the sites allocated for housing in their plans are of 0.5ha or less to help diversify opportunities for housebuilders. This therefore unlocks smaller and medium sites which may have previously lacked policy support and offers enhanced opportunities for land promotion through Local Plans.
Please contact our team to discuss further how the revised NPPF could assist you.