It’s six years since the first National Planning Policy Framework (NPPF) was published, a document that revolutionised planning by condensing thousands of pages of national guidance to just 65. The revised NPPF, released on 24 July, is no less radical in seeking to set out national policy for the next decade, but this time its focus is firmly on housing delivery.
James Brokenshire’s launch statement to the Commons may have implied that the government’s priority was achieving quality design. In reality, the primary focus of the NPPF is to implement the housing white paper and making good its commitment to increase the delivery of new homes. This is understandable given our housing crisis and last year’s Budget pledge to deliver 300,000 new homes every year until the mid-2020s.
It is a real masterstroke by the government to design the NPPF in a way that gives councils greater powers to promote housing but at the same time will punish those who don’t deliver through the presumption in favour of sustainable development.
The difficulty is that most authorities, cash-strapped by cuts, have severely downsized planning teams. Few have the resources to consider complex proposals and many will be unable to process the number of applications needed to deliver the new homes needed.
The new housing delivery test means that if councils don’t meet their housing targets, they are likely to be shut out of the decision-making process entirely. This will put even greater pressure on councils to approve developments of increasing density or risk without hesitation, leaving the door open to even more resource-hungry appeals.
But what is not accounted for is the Planning Inspectorate’s capacity to deal with such appeals expeditiously. Present delays in determinations and shortages of inspectors make for a similarly depressing read. The NPPF is duly silent on how this increased workload will be handled centrally.
Where the revised NPPF lacks ambition and foresight is on the structural changes occurring to our town centres, commerce and industry. For a document aimed at predicting the next 10 years, including Brexit, the NPPF doesn’t address the future-proofing or flexibility required by predicted structural changes in how we shop and work.
While there is cursory mention of strategies to enable future town centre growth and support for residential as part of the town centre mix, there is little recognition of the radical restructuring of town centres that is required. This includes the need for successful towns to move towards either ‘convenience’- or ‘experience’-driven roles; for enhanced investment; and to ensure that time spent in shops, restaurants and other facilities is as high quality as possible. There is also no sign that our 30-year-old classification of use classes will change much or be more flexible.
There is greater alignment with the government’s Industrial Strategy, notably referencing a need to provide for new tech and distribution warehouses, but the revised NPPF lacks clarity and guidance on modern uses such as co-working, flexible mixed uses and ‘meanwhile’ development. The document reads, with few exceptions, as though our town centres and workplaces haven’t evolved – with policies whose DNA is still rooted in the 1990s.
It is a missed opportunity that this forward-looking document lacks the dynamism needed for our high streets and industry. ‘Meanwhile’ plots and co-working provide start-ups and SMEs with low-risk access to prime town centre real estate, often temporarily, enabling a continually evolving experience for consumers. Importantly, they also boost local shopping provision and vitality.
Will the NPPF last 10 years? The key question is whether it will last five.
Ian Anderson is a partner in Cushman & Wakefield’s planning and development team