Proposed Revisions to the NPPF: impact on the land market by Ian Barnett, National Land Director Leaders Romans Group (LRG)
Bringing forward land for development requires strategic planning. The term ‘strategic’ does not only refer to this early, pre-planning application stage: it describes the nature of the approach – one which is long-term and closely aligned to both local and national strategic objectives.
But any ‘strategic’ element to our future planning system seems to have been abandoned the day that the Government lost the Chesham and Amersham and consigned its 2020 Planning White Paper to the expansive planning policy dustbin.
Strategy, by its very nature, must be top-down, providing the considerable advantages of being able to benefit the country as a whole, disseminate nationally agreed policies and create consistency. But today’s ‘bottom up’ approach, the result of surrendering to local residents and MPs anxious to gain their support ahead of the next general election, runs counter to this.
Unfortunately this is reflected in the recent iteration of the National Planning Policy Framework, published for consultation in late December. In its prioritisation of neighbourhood planning, street votes and design codes through to the removal of the Duty to Cooperate, it demotes any element of strategy to a local level.
Yet we desperately need a return to regional and national strategic spatial planning if we are to grow the economy, improve our national infrastructure and solve the national housing crisis.
The UK is the only major European country that lacks a national or regional spatial plan. A national vision or a structured regional planning system, which has been shown to work in countries such as the Netherlands and Germany, produces a more consistent and less adversarial approach to planning and development.
Such a plan would identify suitable locations for growth. Promotion of land through the strategic planning process would then be smoother, and could be linked with new and existing infrastructure. It would also provide a spatial framework for development across the county while allowing for local involvement in the detail. Fostering a more positive, joined-up and pro-development approach to the housing crisis, it would build on the NPPF's presumption in favour of sustainable development and enable land to come forward more easily.
This could resolve the two central problems with the local plan process: that often too little land is allocated for development, and local councillors can be disproportionately influenced by anti-development politics, which then takes precedence over the need for development. A more recent phenomena appears to be local planning authorities (LPAs) planning to accommodate a smaller proportion of their housing needs and then banking on neighbouring authorities accommodating any surplus.
Counter to this, the proposed removal of housing targets in the revised NPPF conflicts directly with what remains of a national objective – the aspiration to build more houses. This perhaps the most significant of the proposed changes, because it is the foundation upon which strategic planning is built.
‘New flexibilities to reflect local circumstances’ in the way that LPAs apply Whitehall-set targets ends their obligation to maintain a rolling five year land supply for housing, providing their Local Plan is up-to-date.
The Secretary of State, in his letter to MPs setting out the nature of this about-turn, stated that ‘Local housing need should always be a starting point – but no more than that – and importantly, areas will not be expected to meet this need where they are subject to genuine constraints’. The nature of ‘genuine constraints’ is not specified but based on recent experience I would suggest that it refers to political disquiet or a particularly vocal group of NIMBYs.
Already many LPAs ignore housing targets, and they will be less likely to follow mere ‘guidance’. Planning works best when there is a vision with targets and structure. Strategic planning is very much in need of a strategy.