The National Planning Policy Framework (NPPF) has been revised by the government. It is designed to give Councils the authority to challenge poor quality and unattractive development. They seek to get homes built in the right places in a way that is more sustainable to the environment.
This includes further strengthened guidance on the use of Sustainable Drainage Systems (SuDS) We review the new rule book and see if it is up to the test.
The ambition is to build 300,000 new homes a year by the mid-2020s. To meet this, the new rules will see many of the proposals set out in the housing white paper and Budget being implemented.
Following a public consultation earlier this year, the revised NPPF focuses on:
- promoting high quality design of new homes and places
- stronger protection for the environment
- building the right number of homes in the right places
- greater responsibility and accountability for housing delivery from councils and developers
Promoting high quality design of new homes and places
Communities will have a greater and earlier say in how the new development on their doorstep will be designed and integrated with the environment. This will extend to build quality and visual appeal, reflecting community expectations on how it will contribute to the area.
Local Planning Authorities (LPAs) will apply this policy, based on their understanding of an area’s unique character.
Stronger protection for the environment
These changes seek to align the NPPF closer to Defra’s 25 Year Environment Plan. This includes more protection for habitats, and places greater importance on air quality when deciding development proposals. Planning policies and decisions should account for Air Quality Management Areas (AQMAs) and Clean Air Zones (CAZs) to improve air quality at a strategic level when plan-making.
It provides strengthened protection for ancient woodland across England, ensuring they can be retained for the benefit of future generations.
Councils have far more flexibility to make the most of their existing brownfield land. This includes adding more local affordable housing as long as it doesn’t cause “substantial harm”. They must also exhaust all other reasonable options for development before looking to alter a Green Belt boundary.
With a renewed focus on brownfield land assets, these will be promoted as designated sites to generate quicker, higher density and more affordable property. Developers will need to ensure that a full assessment of land quality is undertaken as part of project viability. GeoSmart’s EnviroSmart suite of Phase 1 desktop reports, site survey and planning history options ensures that superficially attractive options don’t hold a dirty secret.
Building the right number of homes in the right places
A new methodology has been introduced to deliver more homes in the places where they are most needed. Councils will be given more confidence to refuse applications that don’t provide enough homes.
The calculation of housing need in an LPA’s strategic plan to include the shortfall in neighbouring authorities will be welcomed by developers. It should improve the chances of a successful application for development on un-allocated land, if it will meet a shortfall in supply in a neighbouring authority.
From 2020, the presumption in favour of sustainable development will apply where delivery is below 75% of the LPA’s housing requirement.
The NPPF also confirms that planning conditions should be kept to a minimum, and that agreeing conditions early is beneficial to all parties involved in the process. Conditions that must be discharged before development commences should be avoided, unless there is a clear justification.
Greater responsibility and accountability for housing delivery from councils and developers
From November 2018, councils will have a Housing Delivery Test focused on driving up the numbers of homes actually delivered in their area, rather than how many are planned for.
This will need to be supported by the necessary infrastructure and affordable housing for balanced communities.
In theory, developers should know what is expected of them up front, before they submit a planning application. Councils will have greater power to hold them to these commitments.
Strengthened SuDS requirements
There has been a welcome strengthening of requirements to review sustainable drainage. In paras 163c and 165, developers are advised to:
- Take advice from the Lead Local Flood Authority (LLFA)
- Have appropriate proposed minimum operational standards
- Have maintenance arrangements in place
- Where possible provide multi-functional benefits.
This will only apply to major developments but the guidance does stress that:
“We would observe that all developments (major and minor) can include SuDS, providing multiple benefits contributing to many of the other NPPF policies – climate change, healthy and safe communities, well-designed places, conserving and enhancing the natural and historic environment.”
Meeting the Requirements
Site suitability for SuDS will vary by geology, soil type, slope profile and groundwater conditions, as well as the LPAs specific guidance on runoff calculations, adoption and maintenance.
It is important that developers, planners and architects engage early with LLFAs to understand what SuDS can be used on site. This will help to address the “multiple benefits” quoted explicitly in the policy.
GeoSmart’s range of SuDSmart reports will help assess site drainage and infiltration conditions so that the most appropriate solution can be applied to meet LLFA and LPA requirements.
For more information on our environmental and drainage reports, contact us on 01743 581 415 or email us at firstname.lastname@example.org
- CPD webinar: Understanding Groundwater Flood Risk – 28th February 2019 ( 14th January 2019 )
- Wales: SuDS now Mandatory for New Development ( 7th January 2019 )
- Understanding Environmental Constraints on Site Development – A Guide for Architects, Planners and Developers ( 21st December 2018 )
- CPD webinar: An introduction to Flood Risk Assessments – 13th February 2019 ( 12th December 2018 )
- SuDS: Biodiversity Net Gains could become Mandatory for Developers ( 10th December 2018 )
- What is a Flood Risk Assessment? ( 4th December 2018 )