Episode 151 - *Bonus* Updated NPPF (Part 1)

This week is Part 1 of the updated National Planning Policy Framework (NPPF). This episode content meets PC3 - Legal Framework & Processes of the Part 3 Criteria.

Resources from today's episode:

Websites:

• https://www.architecture.com/knowledge-and-resources/knowledge-landing-page/changes-to-the-nppf?utm_campaign=Member Update 090125&utm_content=Birdseye view of a typical urbanised British area.&utm_term=&utm_medium=email&utm_source=Adestra
• https://www.gov.uk/government/publications/national-planning-policy-framework--2

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Transcript

Episode 151:

Hello and Welcome to the Part3 with me podcast. 

The show that helps part 3 students jump-start into their careers as qualified architects and also provides refresher episodes for practising architects. I am your host Maria Skoutari and this week is Part 1 of the updated National Planning Policy Framework. Todays episode meets PC3 of the Part 3 Criteria.

Given the extensive updates made to the NPPF, I will be covering them in 2 parts. In todays episode I will be covering Sections 2-10 and the remaining 7 under Part 2. 

So back in episode 126, I had mentioned that the newly elected government had launched a consultation for the proposed reform to be made to the National Planning Policy Framework which concluded in September 2024. 

Since the conclusion of the consultation, the government released the updated NPPF in December 2024. 

Now I covered the full document back in episodes 12 and 13 where I went through each section of the NPPF and briefly discussed what that section outlined. In today’s episode I will mainly focus on the updates made whilst briefly touching on each section. 

As I am sure you are already aware, the National Planning Policy Framework, is the framework that sets out the Governments planning policies for England and how these should be applied. Local planning authorities produce their local and neighbourhood plans for housing and other developments from within this framework and is a material consideration in planning decisions.

The NPPF retains its 17 sections within the latest updated version consisting of:

1. Introduction 
2. Achieving sustainable development 
3. Plan-making 
4. Decision-making 
5. Delivering a sufficient supply of homes 
6. Building a strong, competitive economy 
7. Ensuring the vitality of town centres 
8. Promoting healthy and safe communities 
9. Promoting sustainable transport 
10. Supporting high quality communications 
11. Making effective use of land 
12. Achieving well-designed places 
13. Protecting Green Belt land 
14. Meeting the challenge of climate change, flooding and coastal change 
15. Conserving and enhancing the natural environment 
16. Conserving and enhancing the historic environment 
17. Facilitating the sustainable use of minerals 

Starting with Section 2 - Achieving Sustainable Development: 

This section has largely remained unchanged still outlining that the planning system promotes sustainable development by meeting current needs without compromising future generations. It focuses on three objectives:

1. 1.Economic: Supporting growth with appropriate land and infrastructure.
2. 2.Social: Providing diverse housing and safe, well-designed spaces for communities.
3. 3.Environmental: Protecting the environment, enhancing biodiversity, and addressing climate change.

Plans should balance local needs with sustainable solutions, guided by a presumption in favour of sustainable development. 

For plan-making this means plans must support sustainable development, meet local and regional needs, align growth with infrastructure, improve the environment, and address climate change, unless protected areas or significant adverse impacts justify restrictions.

For decision making this means development proposals should be approved promptly if they align with an up-to-date plan. If relevant policies are absent or outdated, permission should be granted unless protected areas or significant adverse impacts clearly outweigh the benefits. Under this section, the updated NPPF also adds a note that plans and decisions should be made by having particular regard to key policies for directing development to sustainable locations, making effective use of land, securing well designed places and providing affordable homes, individually or in combination.

Next under Section 3 - Plan-making:

A number of iterations and additions have been made under this section mainly relating to maintaining effective cooperation. 

Generally, plan-making outlines that plans should provide a positive vision for the future of each area and the development plan must include strategic policies to address each local planning authority’s priorities for the development and use of land in its area, so this can be captured in the local plan or spatial development strategy. 

The Strategic Policies will need to outline a long-term strategy over a minimum 15 year period for the pattern, scale, and quality of development, addressing priorities like housing, infrastructure, community facilities, environmental conservation, and climate change. They should clearly distinguish between strategic and non-strategic matters, focusing on broad needs and leaving detailed issues to local plans. Policies should also allocate sufficient land to meet development needs, using tools like key diagrams and policies maps, and consider long-term projects like new settlements with a vision extending at least 30 years.

Now under the section outlining Maintaining effective cooperation under Plan-making, the new updates include that:

• Effective strategic planning across local planning authority boundaries will play a vital and increasing role in how sustainable growth is delivered, by addressing key spatial issues including meeting housing needs, delivering strategic infrastructure and building economic and climate resilience. Previously this note was not included and only focused on the local authorities duty to cooperate with each other. 
• They also added a new point outlining that strategic policy-making authorities should ensure their plans align with other relevant bodies and infrastructure providers unless justified otherwise. Plans should: Ensure consistency in planning major infrastructure and social facilities, address unmet development needs from neighbouring areas and manage cross-boundary allocations or designations collaboratively.
• And they reinforced the note relating to effective strategic policy making whereby authorities should prepare and maintain statements documenting cross-boundary matters, that now when  authorities are uncertain on the future direction and release of relevant development plans or plans of infrastructure providers, strategic policy making authorities and inspectors will need to come to an informed decision on the basis of available information rather than waiting for a full set of evidence from other authorities. 

So those are the updates under Maintaining effective cooperation. 

Under the parts of Non-strategic policies, Preparing and reviewing plans, Development Contributions and Examining Plans these remain broadly unchanged. Essentially outlining that Non-strategic policies guide local development, while neighbourhood plans allow communities to shape sustainable growth within strategic guidelines. Plans must be evidence-based, reviewed every five years, and demonstrate that they have been positively prepared and informed by agreements with other authorities, justified, effective in being deliverable over the plan period, and consistent with national policy.

Next moving on to Section 4 - Decision Making:

This section has largely remained unchanged still outlining that local planning authorities should proactively approve sustainable developments, leveraging tools like brownfield registers and encouraging early engagement with developers, communities, and consultees to streamline processes and resolve issues upfront. Decisions must align with development plans unless other considerations prevail, with emerging plans influencing decisions based on their progress and alignment with national policy. Flexibility in local planning can be achieved through tools like Local Development Orders and Neighbourhood Development Orders. Planning conditions and obligations should be kept to a minimum and only imposed where they are necessary, proportionate, and enforceable, with viability assessments adhering to national standards. And utilising Effective enforcement is critical for maintaining confidence, requiring proactive monitoring and action against planning breaches.

Next moving on to Section 5 - Delivering a sufficient supply of homes:

This section has had some significant updates made to it.  

Generally, Section 5 covered the fact that to meet local housing needs, Local planning authorities should ensure sufficient and diverse land is available for housing to meet various community needs, including affordable housing. Housing requirements should be assessed using the standard method, with provisions for urban areas and affordable home ownership. Policies should support small and medium-sized sites, community-led developments, and reuse of brownfield land. Large-scale developments should be planned with adequate infrastructure and in rural areas, housing should meet local needs, and isolated homes should only be allowed under specific conditions, such as for essential workers or exceptional design.

Now, the updated NPPF still emphasises that to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning practice guidance. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for. Within this context, the updated NPPF focuses on the delivery of Social Rent housing as well that falls under the affordable housing tenure, especially when it comes to major developments that they should deliver a mix of affordable housing in order to meet local needs identified.

Now the key addition under Section 5, is the introduction of the ‘Golden Rules’ for Green Belt development setting out that a specific affordable housing requirement should be set at a higher level for major developments involving the provision of housing and requiring at least 50% to be affordable housing, unless deemed unviable. Such developments can be developed either on land proposed to be released from Green Belt or which may be permitted on land within the Green Belt and the affordable housing requirement for land within or released from the Green Belt may be set as a single rate or be set at differential rates. They also proceed to mention and promote the benefits of mixed tenure sites which can include a mixture of ownership and rental tenures, affordable housing, older people housing and student accommodation, creating diverse communities and supporting timely build out rates which local authorities are urged to support through their policies and decisions.

Next, they add specific requirements relating the annual housing supply of local planning authorities, whereby they are required within their strategic policies to include a housing delivery trajectory and consider the expected rate of development for specific sites. Local planning authorities must annually update and identify deliverable sites to meet at least five years' worth of housing. This supply should include a buffer of 5% to ensure choice and competition in the market for land , or 20% if there has been significant under-delivery in the past three years, to improve future housing supply, or starting from 1st July 2026, a 20% buffer will apply for decision-making if a local authority's housing requirement is below 80% of the most recent local housing need figure. Local planning authorities must monitor housing delivery and take action when progress falls short of the required levels. If delivery is below 95% of the housing requirement over the past three years, an action plan should be prepared to address the under-delivery. If it falls below 85%, a 20% buffer should be added to the identified supply of deliverable sites. If delivery drops below 75%, the presumption in favour of sustainable development applies, along with the action plan and 20% buffer. These consequences apply following the publication of the annual Housing Delivery Test results. Additionally, authorities should consider imposing shorter start times for housing developments to ensure timely implementation, especially when previous permissions on the same site haven't been used.

And it concludes with the same requirements under rural housing, whereby in rural areas, housing should meet local needs, and isolated homes should only be allowed under specific conditions, such as for essential workers or exceptional design.

Next moving on to Section 6 - Building a strong, competitive economy:

This section has also had a few changes and updates made to it. 

Section 6 emphasised on Planning policies and decisions aimed at fostering conditions for business investment, growth, and adaptation, emphasising economic growth and productivity while addressing local strengths, weaknesses, and future challenges. Policies should support sustainable economic growth by outlining clear strategies, designating strategic sites, addressing barriers like infrastructure and housing, and allowing flexibility for evolving business needs. They should cater to specific sector requirements, such as high-tech industries or storage operations. For rural economies, policies should enable business growth, agricultural diversification, sustainable tourism, and the retention of community services, with a focus on sensitivity to the environment and sustainability. It also encourages and promotes the use of previously developed land near existing settlements.

So in addition to the policies setting out economic growth, identifying strategic sites and so on, the updated NPPF has also added that policies should pay particular regard to facilitating development to meet the needs of a modern economy, by identifying suitable locations for uses such as laboratories, gigafactories, data centres, digital infrastructure, freight and logistics. They also added that planning policies should address the locational needs of various sectors by facilitating: (a) clusters or networks for knowledge-driven, creative, or high-tech industries, such as data centers, (b) accessible storage and distribution facilities to support efficient supply chains, transport innovation, and decarbonisation and (c) the expansion or modernisation of industries critical to local, regional, or national economic growth and resilience.

And it concludes with the same requirements on supporting the rural economy. 

Next moving on to Section 7 - Ensuring the vitality of town centres:

This section remains unaltered. Outlining that planning policies should support town centres by promoting growth, adaptability, and vitality through a mix of uses, clear zoning, enhanced markets, and long-term site allocation for retail, leisure, and housing. Residential development should be encouraged to sustain vitality of centres. When considering edge of centre and out of centre proposals they must prioritise accessible town centre alternatives with flexibility in format and scale so that opportunities to utilise suitable town centre or edge of centre sites are fully explored. Developments outside town centres that exceed 2,500m² will require impact assessments on investments, vitality, and consumer trade. Proposals that fail these tests or harm town centres should be recommended for refusal. Small-scale rural developments are exempt from these rules.

Next moving on to Section 8 - Promoting healthy and safe communities:

A number of iterations and additions have been made under this section.

Under the previous version of the NPPF, Section 8 outlined that Planning policies should foster healthy, inclusive, and safe communities through well-designed spaces that promote social interaction, safety, and healthy lifestyles. To provide the social, recreational and cultural facilities and services the community needs, planning policies should plan for shared community facilities, guard against the loss of valued services, and integrate housing, economic uses, and community amenities. Local Planning Authorities should proactively support schools, public service infrastructure, and estate regeneration while addressing public safety, security, and defence needs. Open space and recreation are vital for the health and well-being of communities, planning policies should therefore put together robust and up to date assessments of community needs. Land designated as Local Green Space through local and neighbourhood plans allows communities to identify and protect green areas of particulate matter importance to them. Such sites should be protected for their local significance, provided they meet criteria such as proximity, community value, and manageable size, with development policies aligning with Green Belt principles.

Under the updated NPPF, it places greater significance to a healthy lifestyle. By introducing the requirement for Local Planning Authorities to refuse applications for hot food takeaways and fast food outlets that are within walking distance of schools and other places where children and young people congregate, unless the location is within a designated town centres. It also suggests to refuse such applications in locations where there is evidence that such uses are having an adverse impact on local health, pollution or anti-social behaviour. 

The updated Section 8, also places greater importance in planning policies and local planning authorities being proactive in providing sufficient choice of early years, school and post-16 places to meet the needs of existing and new communities. Local Planning Authorities also encouraged to provide fast delivery of new, expanded or upgraded other public services infrastructure such as health, blue light, library, adult education, university and criminal justice facilities when considering proposals for development. Whilst also promoting public safety and taking into account wider security and defence requirements by paying due consideration to the safety of children and other vulnerable users in proximity to open water, railways, and other potential hazards.

And it concludes with similar requirements to the previous NPPF version on Open Space and Recreation. 

Next moving on to Section 9 - Promoting Sustainable Transport:

This section has largely remained unaltered still outlining that Planning policies should prioritise sustainable transport and development from the start of planning processes. Development should focus on locations that minimise travel and offer transport options to reduce congestion, emissions, and improve air quality. Policies should support a mix of uses to reduce journey lengths and encourage walking, cycling, and public transport. The involvement of local transport authorities is vital, and infrastructure should cater to cycling, walking, and large-scale transport facilities. Local parking standards should consider accessibility and demand for electric vehicle charging. Development proposals should also ensure safe access, address transportation impacts, and prioritise pedestrians and cyclists while integrating public transport access. Developments that will generate significant amounts of movement should include travel plans and transport assessments in order for likely impacts of the proposal to be assessed and monitored.

In the updated NPPF, in addition to safe access, transportation impacts and so on, Section 9 also places the importance of prioritising sustainable transport modes whilst considering it in the context of the specific development sites vision, its type and location.  

Next moving on to Section 10 - Supporting high quality communications:

This section remains unaltered. Outlining that Planning policies should support the development and expansion of advanced communication infrastructure, such as 5G networks and full fibre broadband, to promote economic growth and social well-being. Policies should prioritise full fibre connections and ensure their delivery and upgrading over time. The number of radio and electronic communication masts should be minimised, with existing structures encouraged for new capabilities. Local authorities should avoid blanket bans on such developments and ensure they do not interfere with other services, including air traffic and electrical systems. Applications for new developments must include necessary evidence, such as consultations and adherence to safety guidelines, especially for mast installations near sensitive areas like schools or airports. Local planning authorities must determine applications on planning grounds only and should not seek to prevent competition between different operators, question the need for an electronic communications system, or set health safeguards different from the International Commission guidelines for public exposure. 

To sum up what I discussed today:

In December 2024, the updated NPPF was released making a number of various amendments and additions, namely regarding the Grey Belt, the Golden Rules and housing targets. 

• Section 02 Achieving Sustainable Development outlines how the planning system supports sustainable development by balancing economic, social, and environmental objectives, ensuring future needs are met while prioritising well-designed places, effective land use, and affordable housing.
• Section 03 Plan-Making states that plans must set long-term strategies for development, allocate land to meet housing and infrastructure needs, and distinguish between strategic and non-strategic policies while considering large-scale, long-term projects.
• Section 04 Decision-Making states how Local authorities should proactively approve sustainable developments, streamline planning processes, and enforce regulations while ensuring conditions are necessary, proportionate, and enforceable.
• Section 05 Delivering a Sufficient Supply of Homes outline how authorities must allocate diverse housing land, prioritise affordable housing, set higher Green Belt affordable housing targets, and monitor delivery through housing supply buffers and annual assessments.
• Section 06 Building a Strong, Competitive Economy sets out how policies should support business growth, modern industry needs, and strategic economic sites, facilitating sectors like high-tech industries, logistics, and rural economic development.
• Section 07 Ensuring the Vitality of Town Centres state that town centres should be revitalised through mixed-use developments, flexible retail zoning, and impact assessments for large out-of-town proposals while encouraging residential developments.
• Section 08 Promoting Healthy and Safe Communities set out how policies should foster social interaction, prevent loss of community facilities, restrict unhealthy food outlets near schools, enhance public service infrastructure, and improve public safety measures.
• Section 09 Promoting Sustainable Transport state that development should prioritise sustainable transport options, reduce congestion, integrate public transport, and enhance cycling and walking infrastructure while considering site-specific needs.
• Section 10 Supporting High-Quality Communications outlines how planning should facilitate the expansion of digital infrastructure like 5G and full-fibre broadband while minimising mast proliferation and ensuring compliance with safety and planning regulations.