As the consultation closes on the draft revised National Planning Policy Framework (NPPF) IM Land’s Strategic Land Director Jonathan Dyke gives his take on the proposed new policy and whether it will deliver.
Like many in the industry we’ve been poring over the proposed changes to the NPPF with great interest. The draft framework is designed to bring forward “more land in the right places” and help England deliver 300,000 new homes a year. It gets to the heart of many of the issues that have dominated the debate around housebuilding and recommends a way forward. But does it go far enough?
Well, the answer is yes and no. There is much in the draft framework to be commended. The increasing emphasis on well designed places is something that echos our approach at IM Land. For us it makes total sense for local authorities to set out clear expectations on design and for importance to be placed on pre-application discussions. I’d like to see this go a step further with design policies developed in collaboration with local communities. I’d also like to see additional support for local authorities to embed visual tools such as design guides and codes in their plans. If this could happen it would go a long way to improving design quality across the board and giving local councillors reassurance on the end product they will get.
We also welcome the Housing Delivery Test. For IM Land, deliverability is at the heart of tackling the housing crisis. It’s not just about land, policies also need to ensure that homes are built. We do however think that the Housing Delivery Test threshold is too low to really impose an incentive on local authorities. If it’s going to work then the threshold needs to increase and also take into account any shortfall from previous years.
Tackling the housing crisis will require a range of solutions and flexibility. At times there is a danger of unintended consequences in the draft framework that could actually stymie the market. Take the plans to encourage greater use of small sites to encourage the number of schemes that can be built-out quickly. Expressing the threshold in number of homes rather than as an area would ensure a range of sites that are both deliverable and accessible for small to medium builders.
We also need to talk about viability. Recent research by Newgate Communications showed that 60% of councillors surveyed believe that viability assessments are used by developers to avoid planning obligations. Clearly this is something that the industry would dispute but the answer isn’t to try and tackle viability at the plan making stage. It’s too blunt an instrument that doesn’t allow for site specific investigations or changes in development economics over time. Perhaps what’s needed is more discussion around the viability assessment process so that councillors and local communities can have confidence that they are designed to underpin delivery and not to avoid obligations.
When it comes to the Green Belt creating a national approach to how the policy is applied would help ensure that it fulfils its role to create sustainable patterns of development. Changing planning policy will only go so far in boosting housing numbers. It’s going to take the private and public sector working together with a resolute focus on delivery. At IM Land we’re certainly looking to do just that.