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On 19 February 2019, Ministry of Housing, Communities and Local Government (MHCLG) published:
Today, 20 February 2019, an update to the National Planning Policy Guidance (NPPG) has arrived, reflecting yesterday’s announcements and amending paragraphs 001, 004 to 018, 020, and including new paragraphs 028-034 regarding ‘Economic Need’.
This long expected update follows the consultation undertaken in October 2018 regarding proposed clarifications to national planning policy on housing land supply, the definition of “deliverable”, and appropriate assessment for habitats sites.
All other elements of the NPPF remain as per the July 2018 version.
In summary, the main changes are as follows:
A ‘compare and contrast’ tool which shows the amendments made between the July 2018 and February 2019 versions of the NPPF can be seen here.
The Government’s response to its autumn consultation on the standard method provides a welcomed degree of certainty for the purposes of development management (Five Year Housing Land Supply). Despite only 36% of respondents agreeing with it, the Government has implemented a ‘quick fix’ which reverts to the 2014-based household projections.
Recognising the longer timescales involved in plan-making, however, the ‘quick-fix’ has not grappled with the ‘weaknesses’ in the method identified both by the MHCLG and the National Audit Office (NAO) in Planning for new homes (February 2019). These include an acknowledged reliance on trend-based projections, which have proven to be volatile and present a circularity in projecting forward need, and the “limited flexibility to reflect local circumstances”. The NAO confirmed that large parts of the country, primarily the north and midlands, have as a result seen a notable fall in ‘calculated need’. It is also important to acknowledge that the ‘fix’ still falls short of supporting the Government’s ambition to deliver 300,000 homes per annum. This is more of a sticking plaster then, than a solution to the shortcomings.
Plan-makers can take comfort in the Government’s confirmation that the current method must be viewed as the “starting point for the planning process”. For many parts of the south this provides a clear mandate to embrace higher targets and develop positive planning policies for housing. For other parts of the country, however, addressing the weaknesses identified by the NAO means that a revised method must work to establish more realistic, and higher, housing need figures. This is an important consideration in the generation of plans being produced in the context of the 2019 NPPF.
In our view there remain inherent issues with this approach. We face a further review in the next 18 months whilst the Government review the formula and the way it is set using National Statistics data with a view to establish a new approach that balances the need for clarity, simplicity and transparency for local communities with the Government’s aspirations for the housing market.
Wherever the review takes us we strongly agree that it must create certainty and support the Government’s aspirations to boost the supply of housing to 300,000 homes a year. A cursory glance at the ‘yo-yoing’ housing requirement figure debated in the on-going Guildford Local Plan Examination highlights that there must be a better way to plan for the new homes that the country needs.
Keep an eye on this page for updates concerning the NPPF and NPPG. Should you have any queries about the updated NPPF, please contact Tim Burden.
20 February 2019
Senior Planner, Economics