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NPPF Consultation - A North East Perspective

Jennifer Nye 02 May 2018
Since the revised National Planning Policy Framework (NPPF) and related documents were published for consultation, like many others I have been pouring over the text to understand what the proposed changes could mean for the development industry. 
We’ve presented at public and private sector seminars to summarise the proposed changes and importantly, try and provide some analysis and insight into what these changes could mean, specifically for the north east of England. 
The consultation, amongst its many other objectives, is seeking to speed up plan making - with one proposed change relating to one of the tests of soundness shifting from requiring a plan to be “the most appropriate strategy” (paragraph 182) to “an appropriate strategy” (paragraph 36). But could this lead to a reduction in the quality of plans in an effort to speed up production?
The language used throughout the draft NPPF and accompanying consultation documents makes clear that housing requirements are ‘the minimum starting point’. Importantly it clarifies that plan making authorities should work to ensure that cross-boundary strategic matters, such as unmet housing need, are dealt with now rather than deferred. The newly introduced statements of common ground (SoCG) are intended to assist here (they will effectively support the Duty to Cooperate). 
Whilst this emphasis on housing numbers being the minimum starting point (Revised Draft NPPF paragraph 61) and the need to ensure strategic needs are planned for now (paragraph 36) are welcomed, it really isn’t clear how effective this approach will be. Ultimately, SoCG are not required in law and draft paragraph 11 (b) i and ii recognises there are constraints on meeting development needs.
Lichfields’ series of Insights and blogs on the revised draft NPPF summarise the proposed changes in more detail. 
Turning to what this could mean for the north east: what became clear from speaking at recent seminars was the inherent importance of ensuring that the region’s economic strategies and aspirations are supported by appropriate housing delivery. Critically the people involved in helping to realise these aspirations - now, more than ever - must ensure there is a holistic approach taken, with plan makers needing to ensure that policies realise and plan for the intrinsic and inextricable link between economic growth and housing. 
Whilst there have been no fundamental changes relating to the proposed standard methodology requirement for assessing housing need since the last consultation (‘Planning for the Right Homes in the Right Places’, November 2017), it is important to elaborate on how the housing requirements that will be generated by the methodology will only be a starting point. This is implicit in the Government setting a target of at least 300,000 new homes a year by the mid-2020’s. Yet the Government has been consulting on a standard methodology that would only deliver 87% of this total.
In the north east, delivering only the standard methodology requirement compared to the current local authority-produced assessments of housing need could lead to less land being allocated for housing delivery which could translate to around 1,370 fewer homes being built each year, as shown on figure 1. The biggest reductions would be in Darlington (60%), Middlesbrough (37%) and Newcastle upon Tyne (36%). The economic implications of this shift are potentially substantial. 
A reduced level of housing growth would not support the jobs’ growth sought in the two Local Economic Partnership (LEP) areas; they currently aim to create 25,000 new jobs in the Tees Valley by 2026 (Tees Valley Strategic Economic Plan (SEP)) and 100,000 in the north east LEP area by 2024 (North East SEP). 
The revision to the draft Planning Practice Guidance now refers to:
“Circumstances where an uplift will be appropriate include, but are not limited to; where growth strategies are in place…” (Draft PPG, page 26).
This is to be welcomed when compared to the previous ‘Planning for the Right Homes in the Right Places’ consultation which simply set out that:
 “Plan makers may put forward proposals that lead to a local housing need above that given by our proposed approach. This could be as a result of a strategic infrastructure project, or through increased employment (and hence housing) ambition as a result of a Local Economic Partnership investment strategy” (Planning for the Right Homes in the Right Places, paragraph 46).
However, the revised wording does not go far enough to require that objective assessment of need is sufficient to deliver the housing required to achieve economic-led strategies identified by local authorities or LEPs. Without this detail, the risk remains that local authorities may shy away from delivering the housing needed to support their economic aspirations.
Coupled with the Housing Delivery Test which only introduces sanctions if 5% of the housing requirement is not met, and most significantly a new route to the Presumption in favour of Sustainable Development if delivery falls below 75% of the requirement (following the transition period), this could mean that as a region, a further 340-1,690 homes would not be built each year (if only 95% or 75% of the standard methodology housing requirement were to be delivered). 
The economic ramifications of this are clear, as shown in table 1.
As many local authorities in the north east are currently preparing their plans, it is imperative that the LEPs scrutinise emerging policies and allocations, and they are closely engaged in their production, to ensure that the amount of housing planned for is sufficient to support the economic growth that this region so desperately needs.
If the north east is to achieve its economic aspirations, including job growth, then it is imperative that this happens. 

Lichfields will publish further analysis of the consultation on the revised NPPF and its implications. Click here to subscribe for updates.