Will the detail of the revised policy proposals mean that we see more homes being delivered in the right places? Despite the rhetoric the changes risk being counterproductive. Some minor changes to the plan making process could have major implications for housing delivery.

In the six years since the original NPPF came into force, UK housing has risen rapidly up the political agenda, with the affordability, availability and quality of homes all in the spotlight. Draft revisions to the NPPF and the accompanying guidance have just been released with the intention of bringing policy in to line with the Housing White Paper proposals from early 2017, with an aim to speed up the delivery of more new homes in the right places.

Our briefing note on the draft revisions to the NPPF shows that most of the Housing White Paper proposals have made it into the proposed new text at headline level. But the chances of achieving the overarching goal, to fix our broken housing market, have been jeopardised by a significant softening of the requirements that need to be met for a plan to be found ‘sound’ by a planning inspector. These changes are thought to be required to enable swift adoption of plans, but at what cost?

Housing Delivery Test

The most significant innovation is the new Housing Delivery Test, adopted as proposed in the White Paper. This adds a backward-looking test to forward-looking five-year land supply assessment. Failing on either measure can now lead to plans being out of date and a presumption in favour of sustainable development applying. But has this added unnecessary complexity to the process?

The housing requirement in these tests is based on the Local Plan housing target, where this is up to date. As before, the draft NPPF sets out that the presumption in favour of sustainable development means that plans should fully meet local housing needs. However, the first ‘soundness test’ in the new draft text weakens this to only say “meet as much as possible of the area’s objectively assessed needs”. More clarity is needed on this apparent contradiction.

Meeting housing need

The second soundness test has seen a very small change to the wording, but with a potentially significant impact. A sound plan now only needs to be “an appropriate” strategy, rather than “the most appropriate”. The status of Neighbourhood Plans has also been strengthened, which is unlikely to promote higher levels of housing delivery as it reduces the minimum land supply required in such areas from five years to three.

Where there is no up to date plan, the test falls back on the standard approach, which is another new addition to planning policy. This replaces one of the most complex and contentious parts of plan making (Strategic Housing Market Assessments) with a simple calculation, and it has been adopted essentially as proposed in a previous consultation (Planning for the right homes in the right places, September 2017). While we broadly welcome the move to a simpler system, we previously argued that the proposed method would not fully achieve its aims (see our Policy Response). The detail of the PPG has done nothing to allay these concerns.

The only slight change to the calculation method has seen the operation of the artificial cap on market signals uplifts apply to out of date targets in more cases, reducing overall numbers in the short term. Setting housing requirement at a level above the calculated standard need remains allowed but not encouraged, whereas not meeting local need through a plan will be allowed in exceptional circumstances, having been thoroughly tested for soundness at examination.

The guidance still requires that the component parts of housing need are identified, with local planning authorities required to assess the proportions of their overall figure that arises from rented housing, families, older people etc. There is a risk that the requirement to produce evidence of all these separate need components could lead to much of the complexity of the previous SHMAs being retained, defeating the benefits of a simpler approach to overall housing need.

Affordable housing need is also treated in a more prescriptive way in the guidance, with affordable housing and who qualifies as being in need redefined in the NPPF. The addition of households able to afford market rents but wanting to own a home to those in need of affordable housing, and of equity loan schemes to the affordable housing definitions, are the most important changes here.

Green Belt

There are also no significant alterations to the policy to protect Green Belt nor any overt requirement to undertake Green Belt reviews at the time of plan production. There is potentially helpful policy on the meaning of ‘exceptional circumstances’ to undertake Green Belt amendments, though this might lead to Green Belt authorities seeking to export a greater proportion of housing growth to non-Green Belt locations.

Overall, the changes do not yet provide sufficient clarity and certainty to produce the required step change improvement in housing delivery. But there may be more to come, in the form of announcements on new settlements and the recommendations from the Letwin Review on build out rates.

Further information

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