NPPF In Force December 2024 - Updated 24/12

14 December 2024

Consultation Response

Aftert the period of consultation the Government has published a final National Policy Planning Framework (NPPF) plus its summary of the consultation and it its reponses.  The new NPPF will require Guildford to deliver 1170 dwellings per annum as opposed to the current 562 dwellings.

The Responses as published on the 9th December 2024 can be found on this Link

This was accompanied by a statement from the Minister of Housing, which can be found on this Link

The new NPPF is now published and is in force See Link and also Link is at foot of this post.

Key points are that under the revised planning rules.

A) Councils will be told to play their part to meet housing need, with new immediate mandatory housing targets for councils to ramp up housebuilding and deliver growth across the country putting more money in working people’s pockets.

B) Areas with the highest unaffordability for housing and greatest potential for growth will see housebuilding targets increase, while stronger action will ensure councils adopt up-to-date local plans or develop new plans that work for their communities.

C) A new common-sense approach will be introduced to the greenbelt. While remaining committed to a brownfield first approach, the updated NPPF will require councils to review their greenbelt boundaries to meet targets, identifying and prioritising lower quality ‘grey belt’ land.  

D) Any development on greenbelt must meet strict requirements, via the new ‘golden rules’, which require developers to provide the necessary infrastructure for local communities, such as nurseries, GP surgeries and transport, as well as a premium level of social and affordable housing.

E) To further tackle the housing crisis, councils and developers will also need to give greater consideration to social rent when building new homes and local leaders have greater powers to build genuinely affordable homes for those who need them most.  

Housing Numbers

The mandatory number given to Local Authorities for the Housing to be provided by a revised Standard Method.

Our current Local Plan adopted in 2019 has an annual target for housing of 562 Dwellings.  Note this 2019 figure has been determined by a previous method that is not the Standard Method.

The Standard Method is now implementing 1170 Dwellings for Guildford Borough

The Standard method uses a formula based on:

  1. A Baseline calculated as 0.8% growth per annum on the Current Housing Stock in the LPA Area.
  2. An ajustment to take account for Affordability. This uses the 5 year average of the median workplace-based affordability ratio. 
  3. If this afforadability ratio is above 5 then the baseline figure calculated in 1 will be adjusted by 0.95% for each 1% the ratio is above otherwise the adjustment factor is abated to Zero. 

London boroughs now have to meet lower housing targets – mainly due to urban uplift disappearing.  Average 4% lower.  Boroughs bordering London Green belt outside the circle have to provide more housing.  Surrey is 63% extra.

Housing Numbers are complex and the devil is always in the detail of what has been delivered and/or consented.  Guildford Borough Council prodce annually two useful reports on housing performance in the borough.  Attched to foot of post.

Impact on Guildford

Guildford is in a situation where the Council decided on the 21st February 2025 to, following review, initiate a update of the local plan.  Reasons for initiating an update include:

  • The level of local housing need based on Government’s standard method calculation, which differs significantly from the LPSS housing requirement
  • Changes in the economy
  • Slower progress, than anticipated on delivery of several strategic sites
  • Changes in planned delivery of supporting infrastructure notably the A3 as it runs through Guildford.

Although the Local Plan is subject to an update, it is understood that the revised manadatory housing number needs to be adopted from April/May 2025. 

The Standard Method will probably overstate demand for housing in Guildford as the Median Income used to calculate the adjustment will miss out a number of highly paid commuters who will be collected statistically where they work. 

The revised housing number will be a major challenge to the Council as in addition to allocating extra sites the housing supply that has to be demonstrated as achievable for the next 5 years will be difficult to achieve.  If a housing supply cannot be demonstrated, it allows developers to argue that sites should be released for development to ensure the allocation can be met.  Local Authorities can lose control of planning in this circumstance.  

Greenbelt

Now has to be reviewed when Local Plans are prepared.

The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence. Green Belt serves five purposes:

  1. to check the unrestricted sprawl of large built-up areas;
  2. to prevent neighbouring towns merging into one another;
  3. to assist in safeguarding the countryside from encroachment;
  4. to preserve the setting and special character of historic towns; and
  5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

Greybelt

The NPPF introduces the concept of Greybelt which are identified areas in the Greenbelt that can be considered for development.  Grey Belt is mentioned very little in the NPPF and the definition is only apparent from looking at the glossary.

Definition of Grey belt from NPPF: For the purposes of plan-making and decision-making, ‘grey belt’ is 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 purposes a) (to check the unrestricted sprawl of large built-up areas); b) (to prevent neighbouring towns merging into one another); d) (to preserve the setting and special character of historic towns); in paragraph 143 of the NPPF.  ‘Grey belt’ excludes land where the application of the policies relating to the areas or assets in footnote 7 (other than Green Belt) would provide a strong reason for refusing or restricting development.

Affordable Housing

The government is using the NPPF to an extent encourge affordable housing, but significantly it has reduced the original proposals for affordable housing in released greenbelt land.

Permited Development Rights

Disapointingly the government despite promising in opposition to revise the policy have done nothing on Permitted Development Rights. This still allows conversion to housing of unsutable buildings.  Many office blocks have deep floor plans, little external space and poor locations. The Guardian has an article on this subject 

 

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