Today, as we expect a new consultation on a revised National Planning Policy Framework, Public Policy Officer Laura Mason takes a look at what we’re hoping to see in these latest planning policy reforms.
When the National Planning Policy Framework (NPPF) was first introduced, we called for a system that ensured development is steered to the most appropriate places. This means planning development should not be weighted in the interests of purely economic development, but integrate the needs of people, places and the economy. It should safeguard the special places we all cherish, and allow space for nature to thrive. Local people, who know their communities best, should be at the heart of the planning system and shape development to fit their aspirations.
The NPPF had potential, but it hasn’t delivered on these ambitions – as several select committee reports have shown. We believe the revised NPPF needs to deliver the right number of homes, in the right places, with high quality design and access to the full range of infrastructure.
2017’s Housing White Paper signalled a shift in the Government’s approach, placing more emphasis on character of development and the importance of a well-resourced planning system. Nevertheless, the Government faces a real challenge to deliver a promised 300,000 new homes a year while protecting our natural and cultural heritage.
The right number of homes
The number of homes that a Local Authority needs to build is currently determined independently, using opaque calculations that are frequently subject to legal challenge. Without a consistent methodology, councils are struggling to demonstrate they have a five year land supply for new homes – even when Local Plans have been adopted. Without these crucial figures, Local Plans cannot be considered up to date and the presumption of development applies. We’re concerned this creates a ‘free for all’ on greenfield sites, and undermines the democratic Local Plan process.
It was therefore welcome that the Government proposed a standard way to calculate housing need, but we argued it needed some tweaks to be effective. This is because the method includes adjustment for market prices, meaning Local Authorities in more expensive areas will have to allocate more land for development – but we aren’t convinced this will help.
Our analysis shows that some of the areas facing the largest increases under this new methodology have been granting more permissions already, but these aren’t translating into new homes. For example, Epping Forest potentially needs to find land for 400 more homes under the formula – but it granted planning permission for nearly a hundred more homes in 2017 than in 2015. This hasn’t resulted in an increasing number of homes though: fewer houses were built there this year than in either 2015 or 2016. We struggle to see how forcing councils in this position to allocate yet more land will resolve this issue, which is fundamentally connected to problems around ‘land banking’.
Since 2010, we’ve been granting over 60,000 more permissions each year than there were housing starts. Local Government Association (LGA) research suggests that there are more than 423,000 unimplemented planning permissions in England, and on average, it takes more than four years to complete a new development. This clearly needs to change if councils are to have any chance of achieving their existing targets, let alone new ones. The new NPPF is likely to contain some new powers for councils to address this, including more robust compulsory purchase powers, but we’ll need to wait for the outcome of Sir Oliver Letwin’s Build Out Review for more radical measures.
Last year, Shelter launched a campaign calling for a new generation of civic housebuilding to deliver good quality, well-planned homes that meet local needs. If we continue to see under-delivery in the housing market then these innovative proposals deserve more consideration by Government.
Building in the right places
The reason the methodology for calculating housing need is so significant is because, if not carefully designed, it’s likely to have knock-on effects for our countryside.
The National Trust exists to protect some of the country’s most special places forever – and for everyone. As our founder Octavia Hill recognised, we all benefit from access to fresh air and open spaces. We think the right places for development are those allocated by local communities through the Local Plan making process. We aren’t opposed to the principle of development, and indeed our early supporters were advocates for the Town and Country Planning Act, which became law in 1947.
But we do believe it should be through a plan-led system that truly integrates economic, environmental and social concerns, and it should prioritise brownfield land first. The current NPPF hasn’t delivered this. Where Local Authorities haven’t been able to demonstrate a five year supply of land, they’ve been under pressure to approve developments on greenfield sites, and more applications have been approved at the appeal stage. Since 2010, the number of homes approved at appeal has more than doubled from 16,000 to 36,000.
We’ll be looking for the NPPF to address this problem. It is welcome that Ministers have been clear about maintaining protections for the Green Belt. However, we are concerned the new methodology could undermine this commitment, and particularly impact areas with a large amount of land within the Green Belt, National Parks, Areas of Outstanding Natural Beauty or Sites of Special Scientic Interest. Fifteen councils have 80% or more of their land designated, and under this proposed new methodology, and on average, they will need to identify space for 20% more homes. We believe this will place pressure on these protected areas.
The same is true with some of our most historic places. Canterbury, for example, has nearly a hundred designated historic Conservation Areas – but it faces a potential 37% increase in homes if this methodology is introduced as proposed. We also know that these areas can struggle to deliver their targets as it is. Just three of the seventeen Local Authorities with over 80% of their land designated met their existing housing target last year – and on average, just 18% of their homes were affordable.
We argued that it should instead be based on projected household growth, but should also consider the realistic availability of unconstrained sites, not just market demand. This would reduce pressure on Local Authorities, and ensure that we do not end up with a ‘free for all’ on greenfield sites whilst councils struggle to identify sites and swiftly adopt a Local Plan.
High Quality Design
The new NPPF is likely to include measures to improve the quality of homes built, which is something we wholeheartedly support. We welcome measures to consult local communities and set out clear design expectations in neighbourhood plans. We believe this will help communities shape development in their areas and ensure it is in keeping with local style and character. Very occasionally, the National Trust releases land for development, but only where the land has been given to us for investment purposes (not to protect for its special qualities) and where the site is identified by the Local Authority (for instance through its Local Plan) as suitable for development.
We firmly believe that when we release land, new homes should be built in harmony with the local environment, both built and natural. We look to respect local distinctiveness and believe that a good planning system would see all developers try to do so. Whilst we understand the pressure to deliver more homes, we hope that proposals to support higher density housing do reflect the ‘character, accessibility and infrastructure capacity’ of an area. We would be particularly concerned if any historic assets or their settings were threatened by building upwards.
A Full Range of Infrastructure
We also want to see the new NPPF recognise the value of green infrastructure as an essential part of new development. We welcomed the publication of the 25 Year Plan for the Environment, which includes commitments on green infrastructure that could drive up the quality of development. This included a pledge that new development ‘will happen in the right places, delivering maximum economic benefit which taking into account the need to avoid environmental damage’. The publication of the revised NPPF will be a test of the cross-government working that will be essential to realising the 25 Year Plan: we’ll be examining the NPPF closely to see if it lives up to that principle.
The 25 Year Plan also included an ambition for high environmental standards for all new builds – something we have sought to deliver in our own developments. At Stamford Brook in Cheshire, for instance, we created new public open space and naturalised 1.8km of the Sinderland Brook. This benefits wildlife and provides a semi-natural urban drainage system, as well as giving the Stamford Brook housing development a special character and its residents access to a beautiful natural environment.
We welcome the proposal for new standards for ‘good’ green infrastructure, and the potential to ‘retro-fit’ developments. We have a key role on the Parks Action Group, and will actively contribute so new developments include more accessible green spaces. Recent research for Natural England has shown that where people have good access to green space, they are 24% more likely to be physically active. If the whole population had equitable access to green space, the estimated saving to the NHS could be in the region of £2.1 billion in England alone – proving Octavia was right that access to fresh air was of immense benefit.
Green infrastructure can also be of benefit to the natural world. The 25 Year Plan’s commitment to consult on a mandatory ‘net gain for nature’ could be game changing, if implemented well. Wherever possible, development must still seek to avoid or mitigate harm, but we look forward to contributing our experience of development that also delivers for nature. At Pyrland in Somerset, we propose to set aside a large proportion of green space on the site for public access, ensuring it benefits wildlife as well as people.
Last year, we surveyed 1,200 ward councillors with the Local Government Information Unit (LGiU), and 72% of them said they felt the system was too weighted in favour of developers. The revised NPPF is a chance to redress the balance, and we hope to see the Government deliver a framework that lives up to its ambitions.
So, we look forward to seeing today’s consultation, and will share our response on this blog.
Laura Mason, Public Policy Officer, National Trust