In recent months we have seen the Government begin to piece together its plan to deliver 1.5 million new homes over the next five years. Previously we looked in detail at the draft NPPF and planning reform consulted upon in the summer and how the revised 'Standard Method' for housing need affects regional housing requirements and local authorities.

Is it a box? Is it a package? No, it is an unmistakably shaped National Planning Policy Framework (‘NPPF’). Changes to the NPPF are becoming a customary Christmas gift from the Government and one that is often accompanied by anticipation, exclamation, and excitement [for those planners amongst us]. The festive unveiling of these most recent changes is certainly a moment filled with intrigue.

Building on our previous analysis, we will unwrap the extent of change and reform proposed by the Government in a bid to accelerate housebuilding and deliver 1.5 million homes over this Parliament in the coming days / weeks. For now, however, just as the classic ‘Twelve Days of Christmas’ carol counts down, here are twelve things to look out for within the revised NPPF.

The Grey Belt is now defined as land in the Green Belt comprising previously developed land and / or any other land that, in either case, does not strongly contribute to any of following three purposes:
- to check the unrestricted sprawl of large built-up areas;
- to prevent neighbouring towns merging into one another; and
- to assist in safeguarding the countryside from encroachment.
It should be noted that the definition of Grey Belt excludes land where the application of the policies relating to sites of protected assets would provide a strong reason for refusing development. These protected assets include SSSIs, Local Green Spaces, National Landscapes and Parks, Irreplaceable Habitats, Designated Heritage Assets, and areas of flood risk or coastal change.
The principle of Grey Belt development is now firmly established through paragraph 155a) of the NPPF, which confirms that development is considered appropriate where it utilises Grey Belt land (as defined above) and does not undermine the purposes (when taken together) of the remaining Green Belt area.
More generally, development within the Green Belt will not be regarded as inappropriate where (a) there is demonstrable unmet need for the type of development, (b) the development would be in a sustainable location, and (c) the following “Golden Rules” are met:
- The affordable housing contribution is 15% above the highest existing affordable housing requirement which would otherwise apply, subject to a cap of 50% or a default contribution of 50% is no pre-existing requirement exists;
- Necessary improvements to local or national infrastructure are safeguarded; and,
- New or improved green spaces which are accessible to the public are provided.
Paragraph 158 confirms that development that complies with the Golden Rules should be given significant weight in favour of the grant of permission.
The 2023 results of the Housing Delivery Test have now been published alongside the new NPPF and the consequences of the HDT results are mapped here. The consequences of the Housing Delivery Test remain triggered where delivery falls below 75%, 85% and 95% of the three-year requirement. The results and their consequences will apply from 13th December 2024.
The standard methodology for calculating local housing need (as published here) must be used, and in re-iterating the “Duty to Cooperate”, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for. This reverses the change made to the NPPF in 2023 whereby the outcome of the standard method was to be used as an advisory starting point for establishing a housing requirement.
The revised overall standard method figure results in a 0.3% difference against that consulted upon over the summer, with the revised figures reflecting the re-distribution of need to those areas with the highest unaffordability for housing and greatest potential for growth will see housebuilding targets increase. All regions are still subject to an increase except for London, although both London and the southeast will be required to deliver the biggest uplifts in housing compared to delivery over the past three years.
Green Belt boundaries should be altered through the plan process in fully evidenced and justified exceptional circumstances, which notably now includes instances where an authority cannot meet its identified need for residential, commercial, or other development.
More weight is accorded to renewable and low carbon energy developments. Paragraph 168a) stating that Local Planning Authorities should give ‘significant weight’ to the benefits associated with renewable and low carbon energy generation and the proposal’s contribution to a net zero future.
Paragraph 109 requires that a ‘vision-led’ approach to identifying transport solutions should be considered from the earliest stages of plan-making and development proposals. This is suggestive of a move away from a traditional predict and provide approach and is reflective of a behavioural shift towards the utilisation of sustainable transport.
Annex 1 of the NPPF sets out the transitional arrangements for the purpose of its policies in the context of plan-making. Paragraph 234 confirms that policies of the NPPF will apply from 12 March 2025, other than where one or more of the following apply:
- the plan has reached Regulation 19 stage (pre-submission stage) on or before 12 March 2025 and its draft housing requirement meets at least 80% of local housing need;
- the plan has been submitted for examination under Regulation 2284 on or before 12 March 2025;
Paragraph 236 confirms that where paragraph 234b) applies, if the housing requirement in the plan to be adopted meets less than 80% of local housing need the local planning authority will be expected to begin work on a new plan, under the revised plan-making system provided for under the Levelling Up and Regeneration Act 2023 (as soon as the relevant provisions are brought into force in 2025), in order to address the shortfall in housing need.

Paragraph 237 confirms that those local plans that reach Regulation 19 (pre-submission stage) on or before 12 March 2025 and whose draft housing requirement meets less than 80% of local housing need should proceed to examination within a maximum of 18 months from 12 December 2024, or 24 months of that date if the plan has to return to the Regulation 18 stage.
Whilst policies in respect of town centres and related uses are largely unchanged, Paragraph 97 of the NPPF identifies that local planning authorities should refuse planning applications for hot food takeaways and fast food outlets where they are: a) within walking distance of schools and other places ‘young people congregate’ (unless outside of a defined town centre); or b) in locations where there is evidence that a concentration of such uses is having an adverse impact on local health, pollution or anti-social behaviour. The policy follows the introduction of supplementary planning documents across a number of local planning authorities to control the location of hot food takeaway uses. Whilst it is envisaged that the above national policy requirement will be broadly welcomed by some LPAs, the policy as worded is open to interpretation (in particular, in respect of how to define a location where young people congregate). It remains to be seen whether further direction will be provided by an update to the PPG.
Changes made to Paragraph 86c) of the NPPF requires that planning policies give particular regard to facilitating development to meet the needs of a modern economy, including by identifying suitable locations for uses such as laboratories, gigafactories, data centres, digital infrastructure, freight, and logistics. Paragraph 87 recognises the importance of making provision for the expansion of modernisation of other industries of local, regional, or national importance to support economic growth and resilience.

With the changes unveiled, we will begin to delve into the detail in the coming days and weeks.

Of course, the proof will be in the pudding, and time will only tell as to whether the changes made to planning system and NPPF offers the gift of opportunity to tackle the chronic housing crisis once and for all…