Gábor Csontos is a policy and data analyst at the RTPI. As the new housing specialist in the RTPI’s Policy Practice & Research team, his first blog tackles the issues raised by the government’s proposed changes to the NPPF.
This blog looks at the changes the proposed amended NPPF would bring about for housing. With the cost of living crisis putting further pressure on those most vulnerable to the UK’s ongoing housing crisis, addressing housing issues is very timely. Here we will look at the four main changes to the NPPF that we discuss at the RTPI’s ongoing members’ consultation workshops.
First, the government is proposing to loosen the requirement for local authorities to demonstrate the availability of five years’ supply of housing. At the moment, there is a requirement for all LAs to ‘continually’ demonstrate that there is enough land dedicated to housing development for the next five years. The need is calculated by the Standard Method, sometimes modified by local circumstances.
According to the new NPPF, local planning authorities that have an up-to-date local plan could forego this duty to demonstrate adequate housing supply with every planning decision. According to the government, this change would incentivise the making and maintaining of local plans. On the other hand, a critical perspective might suggest that this will just let authorities that underperform in housing provision off the hook amidst a deepening housing crisis and effective cuts to councils’ funding.
Connected to this is the issue of the ‘urban uplift’. In the housing needs formula, the top 20 urban centres are required to factor in an excess 35% housing need compared to the ordinary calculation (see Step 4 here). This is justified by the larger demand for homes in the largest urban areas with the most jobs and economic growth. The intention is that these urban centres meet their demand by densification within their borders—and not by “spilling over”, as it were, to neighbouring authorities.
Until now, the Duty to Cooperate was in place partly to ensure coordination between such neighbouring authorities. Now the Duty is to be removed, to be replaced in the future by an “alignment policy” that would recognise that sometimes there is only “minimal distinction” between uplift areas and neighbouring authorities, enabling some cooperation. But once again—would this be a step forward, respecting the economic unity of some neighbouring places, or a step back, allowing some urban cores to escape the uncomfortable task of densifying?
Another measure on the table is to remove the requirement for local planning authorities that their plans are ‘justified’ in order to be considered ‘sound’. Currently a plan is considered sound if it is:
- ‘positively prepared’ (takes into account local needs and was prepared in cooperation with neighbouring authorities),
- ‘effective’,
- ‘consistent with national policy’ and
- ‘justified’.
The latter demands that ‘reasonable alternatives’ are taken into account, and the eventual plan is ‘based on proportionate evidence.’ The requirement of ‘justification’ on top of the others currently forces LPAs to produce very large amounts of evidence when planning for meeting housing needs. It is questionable whether this is necessary or productive and can be a disproportionate bureaucratic requirement in some cases, ultimately hindering the ability to deliver housing.
Finally, the new NPPF takes a clear stance on a contentious issue around the Green Belt—are local authorities required to alter Green Belt boundaries if housing delivery requires it? The new answer is ‘no’—if the only way to deliver appropriate amounts of housing would be through the development of Green Belt land, authorities are not required to do so (although they can if they want to and can make a good case for it). This issue can, in some localities, be seen as a welcome protection against encroaching on the natural landscape driven by bureaucratic dictates—but in other places it might serve as a convenient excuse to not prioritise housing delivery.
The RTPI takes the stance that to address the housing crisis, planning has a crucial role in delivering sufficient numbers of affordable homes, close to transport and amenities, and embedded in good quality places. The question is whether these changes will do this.
This is why at this time it is crucial that we hear from our members around the country—how would the proposed NPPF affect you and your ability to do your job as a planner and deliver good places to live?
If you’ve not yet done so, we’d strongly encourage RTPI members to lend us your thoughts at an upcoming roundtable. Take a look here for more details about the consultation and opportunities to participate.
