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Comment on the revised NPPF 19 December 2023

Today’s NPPF has brought about a significant shift in the Government’s approach to housing delivery in England, which seeks to further promote urban intensification and limit greenfield development on the edge of settlements. The implications of these changes are wide-ranging and have significant implications for local planning authorities in terms of meeting local housing needs, delivering sustainable patterns of development, and addressing the UK’s Housing Crisis. The new NPPF introduces several changes that make it more challenging for local authorities to achieve these goals.

One of the key changes in the new NPPF is the rebranding of the Government's standard method for meeting housing needs as "advisory." While the standard method has always been the starting point for setting an authority’s housing requirement, the new language gives the impression that meeting the local housing need in full is no longer a priority, but rather an aspiration. This change in language has already led to numerous local authorities seeking to implement their own reduced housing need assessments this year, rather than the Government’s standard methodology. This has significant implications for housing delivery, as it will undoubtedly lead to a reduction in the number of new homes being built – compounding the housing crisis yet further.

Furthermore, the new NPPF introduces a requirement that the uplift of housing need in certain cities and urban centres should be met within those areas, rather than in neighbouring authorities. This change will likely lead to local authorities refusing to help accommodate unmet housing need from cities and will reduce the scope for cooperation on strategic cross-boundary issues, leading to a reduction in private and affordable housing delivery in areas where the need is greatest.he new NPPF also clarifies that there is no expectation for Green Belt boundaries to be reviewed during local plan-making, unless there are exceptional circumstances. This change, along with the introduction of a requirement to consider local character when planning for housing needs, gives greater weight to the views of those existing residents who oppose new development. This will inevitably result in a reduction in the supply of housing and further exacerbate the housing crisis.

Another significant change introduced by the new NPPF is the reform of the five-year housing requirements. LPAs are now no longer required to maintain a five-year land supply, if they have an adopted Local Plan that is less than five years old, and that Plan identifies a five-year supply of sites. Additionally, LPAs are only required to identify a four-year supply of housing land if their draft local plan has been submitted for examination or has reached Regulation 18 or 19 stages.

In conclusion, the changes introduced by the new NPPF have significant implications for LPAs in terms of delivering sustainable development, meeting local housing needs, and addressing the housing crisis. The rebranding of the standard method for meeting housing needs as "advisory" and the changes in the approach to strategic coordination and Green Belt boundaries make it more difficult for LPAs to plan for sustainable development and meet local housing needs. Additionally, the changes in the five-year housing requirements present a significant challenge for LPAs, especially considering the resource constraints that many of them face. These changes are likely to have a profound impact on housing delivery and may further exacerbate the housing crisis.

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