Following the end of the National Planning Policy Framework (NPPF) consultation, the Home Builders Federation’s (HBF) Director of Planning, Sam Stafford recaps on the risks of proposals to the planning system.

Back in November when the Levelling Up & Regeneration Bill was effectively being held hostage by amendments tabled by a ‘Planning Concern Group’ of Conservative MPs, there was speculation that the price to be paid by the Government was a reversion from top-down housing targets back to locally-derived assessments of need.

Whilst unhelpful, the home building industry could have accepted this and sought to move on as quickly as possible.

However, a Ministerial Statement (WMS) tabled by Michael Gove on 6 December 2022 outlined the extent of the concessions to the rebel block and they go some way beyond a relatively simple change to housing need calculation.

The concessions, which were consulted upon as proposed changes to the National Planning Policy Framework (NPPF), pose a very serious and immediate threat to housing delivery.

From a development management point of view, the proposals include a series of measures to soften land supply and delivery requirements, limiting the circumstances in which the ‘presumption in favour of sustainable development’ can be applied. In practical terms, this will make it more difficult to secure a recommendation of support from planning officers at committee and more difficult to win appeals.

A list of DLUHC’s other proposals, such as boosting the status of neighbourhood plans, are outlined in HBF’s member briefing from December. However, it’s the changes to policy and local plan-making that will have the greatest impact.

Firstly, the consultation fails to support and encourage credible calculations of local housing need. It suggests the current standard method (widely held to be unfit for purpose) be retained, but that it become a starting point. Under these proposals, Local Planning Authorities (LPAs) will have the power to plan for a lower figure if:

• there has been recent ‘over-delivery’
• to meet need within existing urban boundaries would be detriment to ‘local character’
• to do so would mean amending Green Belt boundaries – which is a tantamount to a moratorium on new Green Belt allocations

Further, the consultation’s proposals set a lower bar for local plans to meet to be adopted by reducing both the evidence base required to justify the intended approach and the scrutiny that inspectors are able to inject at examination.

Finally, of the more significant provisions, the proposals outline that LPAs unable to meet local housing need will no longer be required to speak to neighbouring authorities about accommodating these needs. This means shortfalls generated in major town and cities are less likely to be addressed elsewhere within the housing market area.

Unsurprisingly the WMS raised serious alarm within the home building industry. The Home Builders Federations (HBF) and the Land Promoters and Developers Federation (LPDF) jointly instructed Lichfields to prepare a detailed assessment of the likely impact. This fed into the HBFs ‘Planning for Economic Failure’ report that you might have seen covered in The Guardian and the Financial Times.

The report concluded that housing supply could drop by over 120,000 homes a year, due to:

• Proposed changes to the NPPF – 77,000 homes a year;
• Nutrient neutrality requirements – 37,000 to 41,000 homes a year
• Water neutrality – 1,500 to 1,900 homes a year
• Recreational Impact Zones – 1,200 to 2,100 homes a year

At a recent Prime Minister’s Questions Keir Starmer pressed the Prime Minister on his approach to housing targets and planning reform. He referenced in his question HBF’s research and that housing supply could fall to the lowest level since World War Two as a result of a range of planning policies brought forward by the Government.

It is widely thought that a revised NPPF will be published towards the end of March, before the local election purdah period. The size and scale of the industry response and the political spotlight upon the proposals (the LUHC Select Committee is also holding an inquiry that HBF will be contributing to) will hopefully though prompt a wholesale pause for further reflection.

HBF submitted its response to the NPPF consultation on Thursday 2 March 2023.