After the government released an updated National Planning Policy Framework last year, Lawrence Turner, director of Boyer, discusses his predictions for how this will affect 2025
Following Angela Rayner’s promise in July to spearhead a ‘decade of renewal’ with an ambitious housebuilding programme, the development sector was pleased to see the publication of a revised NPPF on 12 December. The following day a message from the Chief Planner was sent to local authority planning heads, appending updated timetables for Local Plan preparation, details on funding for local authorities to support local plan transition and Green Belt reviews, and an opportunity to provide responses to the Government’s paper on modernising planning committees.
In the wake of the Labour Government’s ambitious plan to build 1.5m new homes by mid-2029, the NPPF has come under significant scrutiny, and the Government’s vision appears increasingly challenging to fulfil. As the Home Builders Federation (HBF) recently reported, new build completions saw a significant decline, to just 198,610 in 2024, illustrating a substantial gap between the Government’s ambitions and the current trajectory of housing supply.
Furthermore, financial constraints stemming from high inflation and diminishing affordability has put a strain on first-time buyers’ access to the housing market and the HBF has urgently called for targeted Government interventions.
Housing targets
The new NPPF retains the majority of the Government’s proposed reforms to national planning policy. The most important of these, fundamental to increasing housebuilding, is the change to the Standard Methodology. This increases housing need figures and puts a greater onus on local authorities in city regions to meet their housing need – effectively delivering the outcomes of the failed Duty to Co-operate. Furthermore, the NPPF strengthens the requirement for local authorities to use the Standard Method and then to “meet an area’s identified housing need”.
The NPPF continues to reverse the former Conservative government’s 4-year housing land supply requirements. Evidently, these proposals were deemed to have reduced housebuilding and were counterproductive.
A significant addition to the NPPF is that found in paragraph 78c, which requires that from 1 July 2026, a 20% buffer be applied to an LPA’s housing land supply where its annual housing requirement (adopted under a previous version of the NPPF) is 80% or less of the most up to date local housing need figure calculated using the standard method. This, in effect, is a requirement for a 6-year housing land supply, which will impact many LPAs who rushed to submit their plans before the previous transitional arrangements came into effect – and will incentivise LPAs to restart plan-making at pace to avoid speculative planning applications for development in their authorities.
Brownfield development
Further emphasis has been placed on putting brownfield development first, with reference to brownfield passports and the strengthening of NPPF paragraph 125, which states that brownfield proposals should be “approved unless substantial harm would be caused”. Closely following previously developed land, is the important role of grey belt sites in meeting the Government’s 1.5 million home target.
Green Belt
The Labour government has made significant changes in relation to Green Belt policy. Notably, the new NPPF includes a requirement for an authority unable to meet housing needs without altering a Green Belt boundary to undertake a Green Belt review. Leading on from this, the concept of ‘grey belt’ land will be fundamental to meeting our housing needs. The NPPF now provides further clarity on what land qualifies as grey belt, stating that:
“For the purposes of plan-making and decision-making, ‘grey belt’ is defined as land in the Green Belt comprising previously developed land and/or any other land that, in either case, does not strongly contribute to any of purposes (a), (b), or (d) in paragraph 143. ‘Grey belt’ excludes land where the application of the policies relating to the areas or assets in footnote 7 (other than Green Belt) would provide a strong reason for refusing or restricting development.”
The Government’s proposed “golden rules” for releasing Green Belt land remain; however, the NPPF has been updated in paragraph 67 to require LPAs to set specific affordable housing requirements for major housing developments on land which is proposed to be released from the Green Belt, or which may be permitted on Green Belt land. This percentage requirement should be higher than land outside the Green Belt and require at least 50% affordability, subject to viability. Until these local plan policies are adopted, paragraph 157 requires a 15% point top-up on the plan’s currently adopted affordable policy, capped at 50%.
These modifications appear to address concerns raised during the consultation period, principally the removal of earlier proposals in relation to benchmark land values (BLV) and its potential to disincentivise the release of land for development.
Need for government intervention in housebuilding
To streamline the planning process, the government has also announced proposals to modernise planning committees, including the possibility of limiting the number of councillors involved in decision-making and establishing a two-tier system of planning committees.
Meeting the 1.5m homes target will inevitably create a significant challenge and a pressing need for effective Government intervention in plan-making and decision-taking. As various local authorities have expressed scepticism about the achievability of new housing need targets, proactive measures will be required for the Government to even get close to its target.
One of the challenges for the Government will be to decipher which local authorities are deliberately stalling in their plan-making and which are failing because of a chronic lack of resources and funding.
In response to these challenges, the NPPF’s transitional arrangements have been updated in paragraph 234. For plan-making, the NPPF will now come into force from 12 March 2025 – giving local planning authorities an extra two months to be ready to implement its policies.
This means that LPAs will now have until 12 March 2025 to progress their Local Plans to the Reg. 19 stage, so long as the Plan’s draft housing requirement meets at least 80% of local housing needs (previously, the benchmark was for a Plan to be within 200 dpa of the local need figure); or have submitted their Plan to the Secretary of State. Many LPAs will now be reassessing their housing land supply underpinning their draft plans to ensure they still meet the transitional criteria.
The stick for LPAs comes in paragraph 236, which requires LPAs that have recently submitted their Plans under the transitional arrangements to begin work on a new Local Plan if the Plan adopted meets less than 80% of housing needs. For those LPAs which reach Reg. 19 stage before 12 March 2025, with a draft housing requirement that is also less than 80%, they should proceed to examination within 18 months of 12 December 2024 – or face intervention from the secretary of state.
Neighbourhood Planning
It is both a surprise and a disappointment that paragraph 14, relating to Neighbourhood Plans, remains unchanged. This is one of the few changes implemented by the previous government in a defensive move to appease anti-development MPs, which has survived the revisions.
When nothing was done to change paragraph 14 in the consultation, many had thought this an oversight. We expected to see the December 2023 changes, which extended the protection of Neighbourhood Plans to a five-year period, to be at least reduced back to two years or indeed deleted entirely to support the Government’s housebuilding aspirations. This may well lead to some local communities being left behind – without the benefit of the new homes and supporting infrastructure that their communities desperately need.
It is surprising and seemingly inconsistent that the ‘localism’ agenda seems to remain (in paragraph 14) alongside the introduction of top-down housing targets and a wider shift towards strategic planning, which, as has become clearer since the publication of the NPPF, will ultimately see strategic decision-making shift towards a new tier of regional governance.
Immediate impact of policy changes
In the short term, at least, an inevitable consequence will be an increase in speculative planning applications. Developers will put forward speculative planning applications with greater certainty of success because many local authorities are now in a position whereby they either have an adopted Plan that is more than 5 years old, requiring them to use a substantially increased housing need figure set out in the Government’s new standard methodology; or are preparing a new Local Plan to meet this increased housing need.
Invariably, planning committees will resist such development – particularly if it is at odds with their adopted Local Plan or if it runs against some councillors’ long-held views that no Green Belt land should be released. In such circumstances, we expect it very likely that the government will call in such applications and decide in their favour. Expect high-profile schemes to receive a positive determination from the Secretary of State – demonstrating to planning committees that NIMBYism must not trump housing needs as it did under the previous administration.
Expect also a rise in the number of planning permissions granted at appeal. Some local authorities, nervous of the political impact of increased development, will likely resist granting planning permission, and developers, more confident of success, will appeal in larger numbers. This will put increased pressure on the Planning Inspectorate, and the government may need to consider increasing resourcing and funding for the Planning Inspectorate to mitigate delay.
There may be a point in the future when planning policy is suitably changed to allow large-scale development to take place, but then what? In the last few years, supply lines have adapted to the number of homes currently being built, which is significantly below target. We don’t have enough construction workers, bricklayers, or roofers – let alone manufacturers and installers of air source heat pumps – to deliver a 50% increase in volume.
The government must not overlook the importance of Stage Two of the housebuilding revolution: addressing the capacity needs to deliver the consented homes.
Conclusion
Back to today: despite the publication of this key piece of planning policy, the government’s programme of planning reforms has only just begun: in 2025, we anticipate a Planning and Infrastructure Bill; a suite of National Development Management Policies (NDMPs) to streamline and accelerate the determination of planning applications, by avoiding the need for local plans to duplicated NDMPs, and decisions following a series of planning working papers, the first of which have recently been published. 2025 is certainly set to be an eventful year for planning and development.
