Real Estate:UK has described the updated National Planning Policy Framework (NPPF) as a “broadly supportive step towards a clearer, more delivery-focused planning system, but said further improvement is needed in some areas.
RE:UK, which represents the £950bn commercial property sector, published an extensive analysis of the NPPF today (21 August) following its publication on Monday.
“We are particularly pleased that the government has listened to concerns about proposed changes to viability and retained the flexibility necessary to accommodate large, complex and uncertain multi-year developments,” said Danny Pinder, director of policy at RE:UK.
“The clearer framework for strategic sites, changes to Spatial Development Strategy timeframes, stronger recognition of employment and logistics uses, and more nuanced approach to housing tenure and density will all help create the conditions to deliver homes, workplaces and infrastructure together.”
Local Plan Making
During consultation, RE:UK had urged the government to avoid seeking spurious accuracy on elements of a development not known up front when evaluating viability and developer contributions at plan-making stage, arguing that viability circumstances can change.
The organisation said it was “pleased” the final framework reflected these concerns, explicitly recognising that sufficient flexibility is needed at application stage and site-specific viability assessments may still be justified in specific circumstances outlined in the policy document.
Strategic Planning
RE:UK welcomed the new definition of a strategic site, with around 1,500 homes as a guide, as a “much-needed clarity for large, long-term developments”. The organisation added. “Clearer links between long-term spatial strategies and local plans should give investors and infrastructure providers more confidence.”
Spatial Development Strategies
RE:UK welcomed the strengthened approach to longer-term regional plans known as Spatial Development Strategies (SDS). The extension of the SDS planning horizon to 25 years should “provide greater long-term certainty for planning, infrastructure delivery and investment,” it said.
Developing more homes
RE:UK said it supports the intensification of residential development on brownfield sites around stations and welcomed the removal of the proposed fixed 150-home threshold for mixed-tenure requirements.
However, it said the removal of build-to-rent (BTR) as a requirement in any mixed tenure policy was a negative step and urged the government to “recognise the essential role that BTR can play in meeting the government’s target of 1.5 million new homes”.
The NPPF’s reduction in national density requirements from 40-50 to 35-45 dwellings per hectare should provide “greater flexibility for bringing forward large schemes”, RE:UK said, but it expressed concerns that national density requirements “may prove overly rigid”.
Supporting high streets
RE:UK said it supported the retention of the sequential test to protect high streets and the removal of wording that could have forced developers to split a retail proposal across several sites to meet the town-centre sequential test.
Greater flexibility on parking standards for large retail and similar regeneration schemes should also make it easier to invest in high streets and town centres, RE:UK said.
RE:UK called the new 12-month protection for pubs against a change of use “well-intentioned”, but said the policy failed fails to address the main reason many pubs close: unsustainable operating costs.
“Preventing a new use from coming forward could leave empty pubs unused for longer, increasing the risk that they fall into disrepair and blight the high streets the policy is meant to protect,” RE:UK said.
Sustainability
RE:UK welcomed the stronger emphasis on tackling climate change as a central part of plan-making.
However, it said it was “disappointed” that the government was not proceeding with plans to limit local energy efficiency standards. It added that greater consistency between local standards would reduce delays and costs and make the planning process simpler.
Looking beyond planning reform
Pinder concluded: “With the Autumn Budget nearing, the government mustn’t lose sight of the fact that planning reform alone will not fix the viability challenges the sector faces. To unlock delivery, the government must take serious stock of the accumulation of tax and regulatory changes crippling delivery, and take meaningful steps to address these pressures and support delivery.”
