Unpacking the impact of the revised NPPF on housing delivery

The revised NPPF was published at the end of last year. This piece looks to highlight key relevant changes and provide a view of how they may impact housing delivery. Disappointingly, and despite the government establishing an independent Older People’s Housing Taskforce last year, there are still limited references to specific policies on older persons or specialist housing so this blog is limited in this regard. However, there are changes that will impact the delivery of all forms of housing and not necessarily positively!

The key change, in terms of housing, is the revised NPPF allows local authorities not to objectively assess their housing need by downgrading the ‘requirement’ to do so to it being ‘advisory’ to do so. In essence, this means that it is not a requirement for the planning system to plan for housing that meets the needs of local communities. It is likely to lead to the withdrawal of more Local Plans to allow revisions to deliver fewer homes and will particularly impact the delivery of social housing, so desperately needed.

Further to the above, a requirement for uplifts in housing supply in certain cities and urban centres states that this should be met within those areas - effectively ending the duty to cooperate in relation to unmet need for housing supply in certain areas. This will likely lead to a further reduction in private and affordable housing delivery in areas where it is most needed. This is proposed on the backdrop of green belt review being actively discouraged.

There is a small, but potentially significant change concerning the older person’s sector under Section 5. This states that the delivery of a sufficient supply of homes of the size, type and tenure required for different groups in the community should be assessed and reflected in local planning policies. This has previously and continues to include older people as a distinct group but, encouragingly, the revised NPPF further defines this in terms of typologies listing retirement housing, housing-with-care, and care homes separately. As a result, it should be expected that the need for these different typologies should form part of Local Plans which should help to provide clarity on where development of specific buildings will be supported.

Beyond housing delivery, much was made of the Local Authority’s delivery of planning decisions within statutory determination timescales and the publication of a league table of performance for applications determined within 8 or 13 weeks depending on the type of application. The loophole of extension of time after extension of time agreements is also being closed as the league table will seek to prevent these requests from being granted in the first place. Given the limited resources available in Local Authority planning departments it is likely that this could make planning more adversarial with an increase in the number of refusals. Given the huge cost and risk of submitting a major application, negotiation with officers is generally welcomed and these changes could lead to less collaboration between applicants and Local Authorities.

Following the announced increase in planning fees, it was indicated that this revenue must be spent on improving the planning service for developers which would be beneficial, but it remains to be seen if this money will be ringfenced, it was certainly not going to be so when the application fees increases were confirmed.

Perhaps one of the greatest benefits of the updated document is the placement of restrictions on planning committees’ ability to block developments that have been approved in principle by officers. This is often a source of frustration in the planning process and simply leads to increased appeals. This is a welcome step.

Overall, the revised NPPF seems like a step back for housing delivery and whilst there are welcome proposals to the day-to-day planning application process the approach to wider strategic planning is disappointing. There is a distinct undertone of bowing to backbench pressure in the revised NPPF and a lack of bold leadership to deliver what the country needs, which is more housing, including more specialist housing for older people.

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WWA is proud to sponsor Housing LIN’s online planning portal, Planning Homes and Communities for Older People, where you can find a range of useful resources on national guidance, strategies and tools, and examples of local planning practice for an ageing population.