At last! The much-trailed reforms of the government’s National Planning Policy Framework (NPPF) were published a couple of days before Christmas, when most people would’ve been too busy to look at them. Not to worry - over the holiday period your hard-working SOLVE committee members have been scrutinising the 78 pages, 231 clauses, and 81 footnotes in minute detail. In fact it hasn’t taken us all that long - very little of substance has changed, at least as regards planning aspects that concern our campaign. In this blog piece I’ll summarise the part of the NPPF that has direct measurable implications for local housing plan updates. This is chapter 6, ‘Delivering a sufficient supply of homes’. There are other aspects to the new NPPF that will be covered on this blog in future, but for now let's just compare what the 2023 NPPF says with the text of its 2021 predecessor.
How much has changed?
Before the reforms were published there had been considerable speculation that changes were in the offing. The media narrative framed the expected reforms as the government caving in to pressure from rural Tory MPs and their irate constituents fed up with endless new housing estates being dumped on their villages. In November, Wokingham MP Sir John Redwood informed readers of his blog that ‘… the government is dropping the national top down targets requiring large amounts of new development in places like Wokingham, and the operation of the five year supply of land rules’. He implied that this was the result of lobbying by him and fellow MPs.
But how much has changed in the actual provisions of the new NPPF document? Let’s begin with housing target numbers. Local authority planning buffs will be only too familiar with the ‘standard method‘ for establishing a local authority’s minimum housing requirement. Built into it is a formula that makes areas like ours with high house prices compared with average incomes build more housing. When it was introduced five years ago, the government’s thinking was that it would alleviate the housing shortage, but it’s done nothing of the kind.
No more top-down targets?
There were upbeat noises in the media that in the 2023 revision the standard method might be made less rigid and would let local authorities have more say in determining local housing need. At first sight, the revised framework (§61) seems to nod in that direction: the calculation derived by the standard method is called an ‘advisory starting point’. Seeing that wording, we’d be forgiven for thinking that there’s new scope for flexibility between that so-called starting point, and the finishing line, i.e. the housing target the council has to publish. Reading on a little further will quickly put paid to that idea, though:
‘There are exceptional circumstances which justify an alternative approach to housing policy; in which case an alternative approach should also reflect current and future demographic trends and market signals.’
Compare that with the 2021 NPPF wording: which said (§61):-
(The standard method should be used) ‘…unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals.’
Spot the difference?
The new ‘advisory starting point’ wording in §61 gives the impression that councils have
more freedom than before to determine the housing numbers. In reality, councils’ ability to depart exceptionally from the standard formula calculation is limited in exactly the same way as before. And just in case they think they can interpret ‘exceptional circumstances’ liberally in their favour, the 2023 NPPF has inserted an example, absent in 2021, of what the Ministry considers exceptional:
‘areas that are islands with no land bridge that have a significant proportion of elderly residents’. In other words, you don’t have to follow the standard method strictly if you’re somewhere in the Scilly Isles or the Outer Hebrides. Otherwise, it’s as you were.
No more five-year supply required?
As for the five year land supply requirement, far from being scrapped, it is largely maintained. There are just two minor changes to it. An LA no longer needs to update its five year supply annually (§75) if it has an adopted plan less than five years old, and it had a five-year supply when the plan was adopted. This doesn’t affect WBC, whose current plan was adopted back in 2010. The other point does apply to WBC: If an LA has reached the Reg 18 or Reg 19 stage of its local plan update process, which WBC now has, only a four-year supply needs to be demonstrated.
So, Shute End needs four years’ housing supply instead of five. Big deal. We’re left wondering who told John Redwood that the top-down approach to calculating the local housing requirement was being scrapped, and the five-year housing supply requirement was being given up. It looks like he was conned as much as the general public were.
There are a couple of additions to the 2021 text which may be seen as positive. Councils are told not just to provide for ‘older people’ as in the previous NPPF, but specifically for ‘older people (including those who require retirement housing, housing-with-care and care homes’). So councils will have to be more specific in how they propose accommodation for older residents should be handled. Also, a footnote states that ‘Strategic policies should promote an effective use of land and optimise site densities... to ensure that homes are built in the right places, to prioritise brownfield and other under-utilised urban sites, to utilise existing infrastructure, and to allow people to live near the services they rely on, making travel patterns more sustainable’ (§62). This is in the context of encouraging urban development, however, so how far it could be applied to our borough is doubtful.
Where does that leave us?
The fact is that most of the planning policy text on ‘delivering a sufficient supply of homes’ remains as it was before. Where there have been changes, they are so minimal as to make no real difference to what councils like ours need to do to comply with national policy.
So where does that leave our SOLVE campaign to save the Loddon Valley countryside around Hall Farm?
The Lib Dem Council Executive has been delaying a decision on the local housing plan update by saying they were waiting for the government to revise the NPPF, in the hope it would give them some flexibility on housing numbers. Well, it hasn't, so their tactic looks like it’s been a waste of time. Clive Jones, Stephen Conway and co. have been waiting for a bus that hasn't come along, and won’t. We’ll see what they do next.