Consultation on National Planning Policy Framework (NPPF)
In September 2024 the Government ran a consultation on proposed changes to the National Planning Policy Framework. We submitted a detailed response to the questions which you can see here.
We welcome the opportunity to comment on the proposals for reform and recognise that there is an urgent need both to build more homes and to increase the amount of affordable and social housing. Our main disagreement with the proposals is the insistence on the new “standard method” of calculating housing targets for the highly variable environments of councils throughout the country. St Albans is probably at the extreme of variability as over 81% of the District is Green Belt and it is a commuter town where the majority of residents do not work there. The city itself has about 25% Conservation Area.
(September 2024)
Changes to Planning Rules
Just before Christmas 2023 the Government issued a revised National Planning Policy Framework (NPPF). What does this mean for St Albans? Michael Gove, in his Ministerial Statement, emphasised the importance of up to date Local Plans. As we know, St Albans’ Local Plan is the oldest in the country and St Albans was one of the Districts “named and shamed” by Michael Gove because of this. St Albans is in the process of developing a new Local Plan and the increased focus means that it is vitally important to complete this. League tables are also promised to monitor success in delivery against plans.
Does the revised NPPF provide requirements or opportunities to amend the draft plan to reduce the number of new houses required? There are two important changes that may do. Firstly the new guidance makes clear that the “standard method” for assessing local authority need is an advisory starting point and in exceptional circumstances a smaller number may be used. Secondly there is no longer a requirement for local authorities to review or alter Green Belt boundaries if this would be the only way to meet housing need.
The implementation arrangements say that these new policies will apply for the purpose of examining plans, where those plans reach Regulation 19 stage after 19 March 2024. St Albans draft plan has just gone through a Regulation 18 consultation and the plan is for the Regulation 19 consultation to take place in the summer of 2024. So it would seem that these new policies will definitely apply for the purpose of examining the St Albans District Plan.
80% of St Albans District is Green Belt which means that in practice, if the numbers produced by the Standard Method are to be planned for, then incursion upon the Green Belt is inevitable, as in the current Draft Plan. So is the extent of the Green Belt an exceptional circumstance that allows St Albans to reduce the number of new housing required? On its face it should be but in practice life is never simple. And is it going to be possible to retain all our Green Belt – where does that leave the generations struggling to find secure and affordable housing?
We also have to remember that there will be a General Election this year – before the Draft Plan is approved. if there is a change of Government then how will the planning world change yet again?
(January 2024)
At the beginning of March 2018 Theresa May revealed the first major overhaul in six years to the NPPF, aiming to support the “housing revolution” outlined in the Budget in November 2017. The revised draft sets out the Government’s planning policies for England and the way in which they are expected to be applied by local authorities. It states the Government’s requirements for planning and establishes a framework within which communities and their local authorities can produce their own local and neighbourhood plans (reflecting their distinctive needs and priorities). Driven by the critical shortage of homes, the tone and substance of the draft text reinforces the political messages of recent months that the Government intend to take a more ‘muscular’ approach in trying to increase the delivery of housing.
Some of the key points are: a presumption in favour of sustainable development; a new standardised methodology for calculating housing needs; a presumption of providing affordable housing; a ‘housing delivery test’ for authorities and greater clarity on the role of neighbourhood plans in delivering housing; a reiteration of the importance of the Green Belt while permitting the use of brownfield land in the Green Belt for affordable housing; enhanced protection for the natural environment with a presumption against development, which results in loss of ancient woodland or irreplaceable habitats; and the importance of the conservation of heritage assets.
While there is much to be welcomed in the revised NPPF, particularly on developer accountability, there also lacunae and concerns. It doesn’t tackle the imbalance of power between developers and local communities and their authorities. There is an over reliance on increasing housing numbers according to the demands of the market, while not properly tackling the issue of lack of affordable housing. Despite reassurances about preserving the Green Belt, we know in St Albans (according to the consultation on the Local Plan) that in in order to meet the target for new housing, 900 homes need to be built per year up to 2036, which would mean 9-10,000 houses in the Green Belt. Has the Government set up local authorities, in areas of high demand, to fail by imposing unachievable targets?
We all, surely, wish to see developments that are well-designed and meet our local needs but St Albans is vulnerable to being over-ruled by the Government’s agenda, which is firmly focussed on numbers!
The revised NPPF has been out for consultation and St Albans Civic Society has submitted our response available here, airing our concerns. The final version of the NPPF, which will become official planning policy, is due for publication “before the summer”.
(May 2018)