The new NPPF and the effect on delivering social housing
13/12/24Introduction
The National Planning Policy Framework (NPPF) sets out the Government’s planning policies for England and how these should be applied. This insight will focus on some of the specific changes that would affect delivering affordable and social housing.
Proposed reforms to the NPPF were published on 30 July 2024 and the Ministry of Housing, Communities and Local Government sought views on those changes during the consultation period.
The new NPPF was published and took effect on 12 December 2024 and largely retains many of the proposed reforms albeit with some further clarity, save for plan-making whereby the preparation of certain local plans have a 3 month grace period until 12 March 2025.
Standard Method for Assessing Housing Need
- Mandatory housing targets have been restored and as such a revised standard method for assessing housing needs has been introduced which better aligns with the Government’s aspirations for the housing market.
- This aims to support the Government’s ambition to:
- Deliver 1.5 million new homes over the next five years;
- Increase certainty through more stable and predictable housing numbers;
- Increase the balance of distribution of homes across the country by directing homes to where they are most needed and least affordable; and
- Be easy to understand and apply so the method can be replicated and updated in line with recent data and reduce time plan making.
- This would require local authorities to decide how and where in their authority the housing need figure would be best met according with national policy, providing the basis for plan making rather than the final housing requirement.
- The standard method aims to:
- Use a baseline percentage of 0.8% of existing housing stock levels to drive a level of delivery proportionate to the existing size of settlements;
- Increase this baseline in proportion to price pressures by focusing on areas with the highest affordability pressures; and
- Remove arbitrary caps and additions so the approach is driven by an objective assessment of need.
Grey Belt
- The intention to identify grey belt land within the Green Belt has remained.
- A revised definition of “Grey belt” land has been inserted into the NPPF 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 reference to land that does not “strongly contribute” is no doubt open for interpretation.
- Development on ‘grey belt’ land within the Green Belt is allowed where there is a demonstrable unmet need for the type of development proposed, the development would be in a sustainable location and would not fundamentally undermine the remaining Green Belt.
- However, Green and grey belt sites can only be built on if they meet the Government’s new ‘Golden Rules’ for major development that:
- high levels of affordable housing delivery (being 15% above existing affordable housing requirements up to 50%)
- the plans enhance the local environment; and
- necessary infrastructure is in place;
Social Rent
- A greater emphasis has been placed on the delivery of Social Rent tenures and is now a defined term within the Annex 2 Glossary
- The expectation is for most areas to prioritise Social Rent in the affordable housing mix they seek, in line with their local needs to deliver more genuinely affordable housing tenures.
- However, it is ultimately for local leaders to determine the balance that meets their communities’ needs to ensure that delivery of Social Rent is increased yet local planning authorities still have control over place-making and tenure balancing where required.
Removal of Minimum Requirement of Affordable Homes and First Homes
- The requirements to deliver at least 10% of homes on major sites as affordable and at least 25% of affordable housing units secured through developer contributions to be First Homes has been removed;
- Notably the concept of First Homes still exists (i.e. it remains an option for delivering affordable housing where local planning authorities believe this is appropriate for local needs) however the definition of both First Homes and Starter Homes have been deleted from the Annex 2 Glossary
Conclusion
- The new NPPF takes the prospect of delivering 1.5 million new homes over the next five years incredibly seriously
- By re-introducing mandatory housing targets and revising the standard housing method this will help to boost housebuilding in areas most in need and in turn help more people rent and buy homes.
- Whether the 3 month transitional period linked to submission of local plans will thwart this remains to be seen
Our specialist local government advice is cost-effective and strategic, complemented by practical knowledge of your daily challenges. We are experts on all aspects of compliance with these new legal requirements and can advise on the broader changing landscape of the planning law.
If you have any queries around what is discussed in this article, and the impact on your organisation, please speak to the Planning Team to find out more about how Capsticks can help.