Episode 152 - *Bonus* Updated NPPF (Part 2)

This week is Part 2 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 152:

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 2 of the updated National Planning Policy Framework. Todays episode meets PC3 of the Part 3 Criteria.

Make sure to stay until the end for todays scenario.

Last week I covered section 2-10, in today’s episode I will be covering Sections 11-17. 

The NPPF sections I will covering today includes:

1. Making effective use of land 
2. Achieving well-designed places 
3. Protecting Green Belt land 
4. Meeting the challenge of climate change, flooding and coastal change 
5. Conserving and enhancing the natural environment 
6. Conserving and enhancing the historic environment 
7. Facilitating the sustainable use of minerals 

So starting with Section 11 - Making effective use of land:

This section has largely remained unaltered.

Under the previous NPPF, Section 11 outlined that Planning policies should promote efficient land use to meet housing and other needs, while safeguarding the environment and ensuring healthy living conditions. Key strategies include utilising previously developed or 'brownfield' land, encouraging mixed-use schemes, and promoting net environmental gains such as habitat creation or improved public access. Policies should prioritise using under-utilised land, such as converting space above shops or service yards, support the development of airspace above existing buildings such as upward extensions. The previous NPPF placed more weight in mansard roof extensions in particular on suitable properties where their external appearance harmonises with the original building. Under the updated NPPF, although mansard roofs have been retained, the importance on beauty and a harmonious appearance has been removed although it does still mention for it to be consistent with the prevailing form of neighbouring properties and to be well designed. 

The remaining terminology under Section 11, is largely unaltered between the previous and updated NPPFs, which outlines that authorities are encouraged to proactively identify suitable sites, including brownfield registers and public land, and facilitate land assembly to meet development needs. Regular reviews of land availability should inform plan updates and support alternative uses where necessary. Policies should also support efficient land use with a focus on density, considering local needs, market conditions, infrastructure, and environmental factors. In areas of housing shortage, minimum density standards are set to optimise land use while maintaining character. Development proposals are also encouraged to avoid low-density projects and make optimal use of land, while also ensuring the resulting environment is attractive and sustainable. 

The only alterations is that the updated NPPF, removed previous reference that significant uplifts in the average density of residential development may be inappropriate if the resulting built form would be wholly out of character with the existing area and that such circumstances should be evidenced through an authority-wide design code which is adopted or will be adopted as part of the development plan. Essentially the previous NPPF placed greater emphasis on beauty and design. The updated NPPF is more focus on larger and faster delivery of housing with less consideration on design.

Next moving on to Section 12 - Achieving well-designed places:

The key difference in this section is its amended title from Achieving well-designed and beautiful places to Achieving well-designed places. As mentioned previously, again indicating that the revised NPPF isn’t as focused on designing beautiful spaces but delivering more housing. 

Apart from that change, the information within this section remains larger unaltered, outlining the importance of high-quality, sustainable, and well-designed developments that enhance communities and reflect local character. Design policies should develop clear design policies with communities so they reflect local aspirations, and are grounded in an understanding and evaluation of each area’s defining characteristics. They should also use design guides and codes to ensure functional, attractive, considerate to the local character and history, optimised and inclusive places. Developments should prioritise safety, health, environmental sustainability, and the integration of trees and green spaces. Poorly designed projects should be refused, while innovative or sustainable designs that align with local aspirations are encouraged. Authorities must maintain design quality from approval to completion and ensure advertisements are appropriately sited to protect amenity and public safety.

Next moving on to Section 13 - Protecting Green Belt Land:

This section has been the one that has been the most extensively updated. 

It starts by outlining the great importance government attaches to Green Belts which policy aims to preserve and prevent urban sprawl by keeping land permanently open. It proceeds to outline, similar to the previous NPPF, the five purposes the Green Belt serves, which includes:

• to check the unrestricted sprawl of large built-up areas; 
• to prevent neighbouring towns merging into one another; 
• to assist in safeguarding the countryside from encroachment; 
• to preserve the setting and special character of historic towns; and 
• to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. 

Then it continues to state, again similar to the previous NPPF, that new Green Belts should only be created in exceptional cases, justified by strategic policies demonstrating necessity, sustainability, and alignment with broader planning objectives.

Now this is where additions have started to be made to this section, where it previously stated that there is no requirement for Green Belt boundaries to be reviewed or changed, the updated NPPF has amended this to say that Green Belt boundaries should only be altered where exceptional circumstances are demonstrated and justified through the preparation or updating of plans, providing more flexibility to the review of the boundaries. Generally, however, both NPPF’s state that strategic policies should determine the need for Green Belt boundary changes, ensuring their long-term permanence beyond the plan period, while detailed amendments can be addressed through non-strategic policies like neighbourhood plans.

Next, the updated NPPF adds that Green Belt boundaries may only be altered in instances where an authority cannot meet its development needs elsewhere, unless it would severely undermine the Green Belt's purposes. Then both NPPF’s state that before altering Green Belt boundaries, authorities must demonstrate they have explored all other reasonable options for meeting development needs. This includes utilising suitable brownfield sites, optimising development density, and engaging in discussions with neighbouring authorities to consider accommodating some of the development needs. These factors will be assessed through the examination of its strategic policies.

Then the updated NPPF removes and replaces the note stating that  when reviewing or setting Green Belt boundaries, strategic authorities should consider how development can be sustainably distributed and that they should prioritise previously-developed land or locations well-served by public transport for development, particularly when Green Belt land is needed. Additionally, plans were required to include measures to offset the loss of Green Belt land through environmental improvements and enhanced accessibility to the remaining Green Belt. So instead, the note now states that when releasing Green Belt land for development, priority should be given to previously developed land, followed by grey belt, and then other Green Belt areas and strategic authorities must assess the sustainability of development patterns when reviewing Green Belt boundaries, focusing on the appropriateness of site locations in line with the framework's guidelines. Development should be directed towards urban areas within the Green Belt, towns and villages within it, or locations outside its boundary, based on the sustainability of the development.

Then, both the updated and previous NPPF, continue to say that when defining Green Belt boundaries, plans should align with sustainable development goals, avoid unnecessary open land inclusion, and safeguard areas for long-term development needs. These boundaries should be clear, based on permanent physical features. Green Belt inclusion is necessary for villages that significantly contribute to openness, while other protections should be applied to those needing preservation for reasons other than openness. Planning authorities should enhance Green Belt benefits, like recreation, biodiversity, and landscape quality. The updated NPPF then adds the additional note that if Green Belt land is released for development through plan preparation or review, guidelines like the 'Golden Rules' should apply. 

Then it continues to state that development in the Green Belt should generally be deemed  inappropriate unless it meets specific exceptions, such as agricultural buildings, facilities for outdoor activities, extensions or alterations to existing buildings, replacement of a building like for like, or small-scale infilling in villages. Other exceptions include affordable housing, redevelopment of previously developed land, and certain infrastructure projects, as long as they preserve the Green Belt's openness. Any harm to the Green Belt must be carefully considered and outweighed by other factors for approval.

The updated NPPF, then also adds that development in the Green Belt may not be considered inappropriate if certain conditions are met, including the use of grey belt land, a demonstrable unmet need for the type of development proposed, is in a sustainable location, and complies with the "Golden Rules" for major housing development. These rules include contributions for affordable housing, infrastructure improvements, and accessible green spaces for new residents. Affordable housing should be at least 15% above existing requirements, with a cap of 50%. Development that meets these conditions should be given significant weight in approval. Additionally, green space improvements should support nature recovery and align with local or national standards. 

And lastly it states that renewable energy projects in the Green Belt may require very special circumstances to proceed as they are deemed to be inappropriate development. As such, they will need to demonstrate environmental benefits from increased energy production.

Moving on to Section 14 - Meeting the challenge of climate change, flooding and coastal change:

Similar to the previous section, Section 14 has also had a number of updates made to it in the latest NPPF. This section focuses on the fact that the planning system should aid the low-carbon transition by reducing greenhouse gas emissions, improving resilience to climate change, reusing resources including existing buildings, and supporting renewable energy and infrastructure. The updated NPPF, adds here that the planning system should support the transition to net zero by 2050 and address overheating, water scarcity, storm and flood risks and coastal change. 

Then it continues to state that Planning for Climate Change, should aim to develop plans to address climate change by mitigating long-term risks like flooding, coastal changes, and biodiversity loss while supporting infrastructure resilience. Here the updated NPPF adds that the need to mitigate and adapt to climate change should also be considered in preparing and assessing planning applications, taking into account the full range of potential climate change impacts. 

Then it proceeds to cover new developments and how they should avoid increasing vulnerability to climate impacts, prioritise green infrastructure, sustainable drainage systems and reduce greenhouse gas emissions through sustainable design and location. 

Now, the previous NPPF, stated that for renewable and low-carbon energy, plans should provide strategies to maximise opportunities, identify suitable locations, and encourage community-led initiatives. The updated NPPF removes this statement.

Then it continues that planning authorities should approve projects with acceptable impacts, prioritise repowering existing sites, and support energy efficiency upgrades. The updated NPPF adds here that when determining planning application for all forms of renewable and low carbon energy developments, local authorities should not require applicants to demonstrate the overall need for renewable or low carbon energy, and give significant weight to the benefits associated with renewable and low carbon energy generation and the proposal’s contribution to a net zero future, recognise small scale community led projects in cutting greenhouse gas emissions and give significant weight to the benefits of utilising an established site for repowering and life-extension of existing renewable sites. It also adds that, once suitable areas for renewable and low carbon energy have been identified in plans, local planning authorities should expect subsequent applications for commercial scale projects outside these areas to demonstrate that the proposed location meets the criteria used in identifying suitable areas. 

It then moves on to Planning and Flood risk, outlining that flood risk management requires directing development to low-risk areas, applying sequential and exception tests, safeguarding flood management land, and using sustainable drainage systems. Here the updated NPPF adds that the sequential test applies to areas at current or future flood risk, unless a site-specific flood risk assessment shows no development or access routes within the site will be at risk from any source of flooding, now or in the future. It then moves on to stating that development in flood-prone areas is only allowed with measures ensuring safety, resilience, and minimal risk elsewhere. 

The previous NPPF stated that major projects must integrate sustainable drainage systems, incorporating local advice, maintenance plans, and multifunctional benefits. The updated NPPF amends this to applications in general impacting site drainage must use sustainable drainage systems to manage runoff, improve water quality, enhance biodiversity, and provide amenity benefits. For major developments, these systems should follow guidance from the Lead Local Flood Authority, meet operational standards, and include maintenance plans for long-term functionality.

And lastly under Section 14, it states that in coastal areas, planning should align with marine policies, avoid inappropriate development in vulnerable zones, and designate Coastal Change Management Areas. Development in these areas is only allowed if it is safe, sustainable, and does not harm the coastal environment or access. Authorities should limit the lifespan of such development to manage future risks.

Moving on to Section 15 - Conserving and enhancing the natural environment:

This section has largely remained unaltered.

It outlines that Planning policies and decisions should aim to enhance the natural environment by protecting valued landscapes, biodiversity, and soils, while promoting the economic benefits of agricultural land, trees, and woodlands. Development should minimise environmental impacts and contribute to biodiversity net gains, including the protection of priority species. In areas like National Parks and Heritage Coasts, development should be limited and only allowed in exceptional circumstances when it serves public interest. Additionally, policies should safeguard wildlife habitats, particularly irreplaceable ones like ancient woodlands, and require mitigation for any negative impacts on biodiversity. The suitability of land for development should also account for ground conditions, contamination risks, and pollution impacts, ensuring that development does not harm health or the environment. Furthermore, any development should comply with pollution limits and contribute to improving air quality, managing noise, and protecting tranquil areas.

Moving on to Section 16 - Conserving and enhancing the historic environment:

This section also remains largely unaltered. 

Focusing on Heritage assets, ranging from locally significant sites to globally recognised World Heritage Sites, are irreplaceable and must be conserved according to their importance. Planning policies should promote the conservation of these assets, especially those at risk, while considering their social, cultural, and economic value. Development should contribute positively to local character and heritage. When assessing development proposals affecting heritage assets, local authorities must evaluate the significance of the asset and its setting, ensuring that any harm or loss is justified. Substantial harm to important heritage assets should only be allowed if public benefits outweigh the harm, and less significant harm should be balanced against the proposal's public benefits. Local authorities should also ensure that new developments in Conservation Areas or World Heritage Sites enhance or reveal the asset’s significance.

And lastly, looking at Section 17 - Facilitating the sustainable use of minerals:

This section again remains largely unaltered. 

This section focuses on the importance of minerals for infrastructure and goods, stressing the need for sustainable extraction and conservation due to their finite nature. Planning policies should prioritise local and national resources, promote the use of recycled materials, and protect mineral resources from non-mineral development. Environmental impacts, including noise, dust, and emissions, must be controlled, and restoration of worked land is required. Planning must ensure a steady supply of aggregates and industrial minerals, while avoiding development in Mineral Safeguarding Areas. For oil, gas, and coal, careful planning and environmental considerations are essential before granting extraction permissions.

To sum up what I discussed today:

• Section 11 - Making effective use of land, the updated NPPF retains most of the previous guidance on efficient land use, prioritising brownfield sites, mixed-use developments, and optimal density, but shifts focus from beauty and design towards larger and faster housing delivery.
• Section 12 - Achieving well-designed places,  Under this section, the updated NPPF removes "beautiful" from the section title but maintains the importance of high-quality, sustainable, and locally reflective design but places less emphasis on aesthetic considerations.
• Section 13 - Protecting Green Belt Land, this section introduces greater flexibility in Green Belt boundary alterations, prioritising brownfield and "grey belt" land for development, and adding new conditions under which development may be considered appropriate, including sustainable locations and unmet housing needs.
• Section 14 - Meeting the challenge of climate change, flooding, and coastal change, under this section the updated NPPF strengthens commitments to net zero by 2050, adds resilience to climate risks and introduces stricter flood risk assessment requirements and sustainable drainage system policies.
• Section 15 - Conserving and enhancing the natural environment, this section outlines protections for landscapes, biodiversity, and air quality while ensuring that development minimises environmental harm and contributes to biodiversity net gain.
• Section 16 - Conserving and enhancing the historic environment, this section emphasises on the protection and conservation of heritage assets, balancing development with public benefits and ensuring that heritage sites are safeguarded.
• Section 17 - Facilitating the sustainable use of minerals, this section outlines the importance of sustainable mineral extraction, resource conservation, and environmental protections while ensuring a steady supply of essential minerals.