This presentation summarizes implications of revisions to the National Planning Policy Framework (NPPF) for local government leaders and chief executives. Key changes include a strengthened emphasis on strategic planning through statements of common ground between authorities, a requirement to review local plans every five years, and a new housing delivery test that could trigger a presumption in favor of sustainable development if housing delivery falls below 75% of targets. The presentation recommends that authorities focus local plans on core strategic policies, work collaboratively across boundaries, establish groups to boost housing delivery, and prepare communications around potential implications of the housing delivery test and presumption.

1. Implications of the new NPPF
HIOWLGA
Richard Crawley, Planning Advisory
Service
21 September 2019 www.local.gov.uk/pas

2. This presentation ...
• Was designed for a group of leaders and chief
execs
• Was delivered in September 2018 when the
NPPF / NPPG was still quite new
– that is why there are lots of question marks and
uncertainty
• Had some maps in it from our original work on
the Housing Delivery test
• You are welcome to borrow / recycle

3. Today
1. Recap - the NPPF in context
2. The key issues from the NPPF
a. Strategic policies
b. Plan making and plans
c. Housing delivery
3. So what ?

4. Reminder - the NPPF
• National Planning Policy Framework
– March 2012. 65 pages replacing 1000s
– Short. Accessible. Strategic.
– Policy not regulation (so no Parliament process)
• July 2018 is the first revision (“NPPF2 ?”)
– Mostly “tidying up” and incorporating WMS
• 80 reforms
– But also raises ante on delivery

5. • See the LGA briefing for a more complete run-
through
• https://www.local.gov.uk/parliament/briefings-and-responses/revisions-national-planning-policy-framework
• Definition of “Affordable housing” … “deliverable” …Viability …
Standard methodology / HDT … Garden City principles … Entry-
level exception sites … Small sites policy … Biodiversity … 10%
affordable homes … Parking standards … etc
• Lots of trailed changes didn’t make it
Reminder - the NPPF

6. Reminder - the NPPF
• Updates represent a significant change
• Intended to reduce legal argument
– ”Are my policies “out of date” ?”
– “Is my previous underdelivery “persistent” ?”
• We all need to update our understanding
– including the Planning Inspectorate
• It will take time to bed in
– new legal arguments will appear

7. Reminder - the NPPF + NPPG
• NPPF = what
• NPPG = how
• 47 guides
• Some also
updated
• More to come
• Not consulted

8. Reminder – the NPPF in context
• In the bag
– NPPF and some NPPG (plans, housing)
• November
– Letwin review. Budget. (CPO ? uplift ?)
• early 2019
– more NPPG (design, transport, ?)
– CIL ?
• See also housing deals, Homes England, CAs

9. 2. The key issues
• The NPPF lands differently for each council
• Most importantly ...
a. Strategic policies
b. Plan-making and plans
c. Housing delivery

10. a. Strategic policies
• Refinement and extension of working together
– not regional planning
• new “Statement of common ground”
– inc. Duty to Cooperate
– Key strategic matters / distribution
– agreements / disagreements
• We don't have a great track record at this
– even where there is history of cooperation

11. a. Strategic policies
• Strategic (shared) policies are the right way to
– reflect functional geography
– engage with LEPs / CAs / Mayors / London
– do difficult but “good planning” things
• like greenbelt reviews
• new settlements or significant growth
• big infrastructure / tariffs
• Perhaps also a way for councils to resource
– share burden

12. a. Strategic policies
• Has strategic planning found its opportunity?
– Where will it live ?
– Is there anyone left with the skills ?
– Can we get better at this ?
• It is difficult and the landscape keeps
changing
– Requires both technical and political

13. b. Plan-making and plans
• Two very important changes:
• Plan reviews
– straightforward in concept
• review within 5 years
– straightforward in execution (just £ and time)
• Plan viability
– straightforward in concept
• Stop arguing viability on applications - do it upstream
– ? in execution ?

14. b. Plan-making and plans
• Housing policies are the core of plans
– Must be reviewed / refreshed / adopted within a 5
year cycle. Otherwise use LHN for 5yrLS
• Can your council go round the plan-making
loop every 4 years ?
– electoral cycles / resources / oversight
• Very few councils have ever achieved this
– you may (or may not) need to (cf LHN /
requirement)

15. b. Plan-making and plans
• Viability – trying to reduce gaming and
argument at application stage
• Objective to get land fairly priced through local
plan process
– Standard inputs / model different typologies
• Will it reduce argument / increase confidence?

16. c. Housing Delivery
• A standard method for assessing local
housing need (LHN)
– based on household projections
– and a market signal from affordability
• A starting point
– unconstrained by capacity / designation
– an assessment not a requirement
• For some areas startling differences between
previous OAN and LHN (both high and low)

17. c. Housing Delivery
• For those with a plan
–expect calls for an early review if LHN is
very different to your plan requirement
• For those without a plan
– use LHN to demonstrate a sufficient land supply
– use LHN as a requirement in the housing delivery
test

18. c. Housing Delivery
• The housing delivery test
–An annual calculation with consequences
–For the past three years
• compares delivery to requirement
• eg 100+100+100 / 92+78+110 = 93%
–Conceptually simple. Complex in practice
–Note transition and stepped threshold
• 25% > 45% > 75%
• Three years = not long in development terms

19. 3. So what ?
1. Do less
2. Understand your risks
3. Respond to delivery

20. Do less
• Only skinny plans can be reviewed every 3 or
4 years
• Pick your battles
– Strategic policies (eg housing)
– Abandon unnecessary content – use the NPPF
• Even better
– Work together on them (SoCG)
– Broader political buy-in ?

21. Understand your risks
• Clearer how & when presumption applies
– 5 year max, or
– Housing delivery test result < 75% in 2020, or
– Overturns at appeal
• Speculative development
– Undermines planning system
– Very difficult politically
• Green belt protection (?)

22. Respond to delivery
• Many will be required to make an action plan
in response to housing delivery test <95%
– A Council statement on development and
intervention to boost supply
– Manage your risk of presumption in the future
• A new team / approach
– Beyond planning and planners
– What is really going on ? How can we influence?
– A development forum (inc councillors) ?

23. Leaders and CExs
• Rethink SoCG
• Rethink Plan
• Establish delivery group
• Update 5yrLS / presumption
– comms

24. Questions?
Email pas@local.gov.uk
Web www.local.gov.uk/pas
Phone 020 7664 3000
Twitter @Pas_Team