December 2015
Consultation on Proposed Changes to National Planning Policy

The Government has recently announced a consultation on a series of proposed changes to the National Planning Policy Framework (NPPF).

In summary, the proposed amendments cover the following areas:-

  • Redefining affordable housing;
  • Increasing residential density around commuter hubs;
  • Supporting sustainable new settlements, development on brownfield and small sites and the delivery of housing agreed in Local Plans;
  • Supporting the delivery of starter homes in unused employment land, mixed use development and in rural areas;
  • Enabling communities to identify starter home sites in the Green Belt; and
  • Evaluate the policy position on brownfield development in the Green Belt.

The consultation runs for 8 weeks from Monday 7th December to Monday 25th January 2016.

Redefining affordable housing

The proposed amendment will continue to include a range of affordable products for rent and ownership for households whose needs are not met by the market but without being constrained by the parameters that have been used in the past which risk stifling innovation. Some of these products may not be subject to ‘in perpetuity’ restrictions or have a recycled subsidy.

Increasing residential density around commuter hubs

The consultation calls for higher density development around commuter hubs. It proposes to define a commuter hub as:-

  1. A public transport interchange (rail, tube or tram) where people can board or alight to continue their journey by other public transport (including buses), walking or cycling; and
  2. A place that has, or could have in future, a frequent service to that stop. They envisage defining a frequent service as running at least every 15 minutes during normal commuting hours.

The Government does not envisage introducing minimum density requirements, they consider it important that these should be set at a local level.

Supporting new settlements

The Government plans to provide a more supportive approach for new settlements within locally led plans. Local Planning Authorities (LPA’s) should take a proactive approach to planning new settlements where they can meet national policy objectives of sustainable development, including taking into account the need to provide additional homes.

Supporting housing development on brownfield land and small sites

The Government has ambitions to have 90% of brownfield land deemed suitable for housing to have planning permission by 2020. They propose to clarify that substantial weight will be given to using brownfield land and also to clarify that development proposals for housing on brownfield sites should be supported unless overriding conflicts with the Local Plan or the NPPF can be demonstrated and cannot be mitigated.

Ensuring housing delivery on allocated land

The Government proposes to introduce a housing delivery test comparing the number of homes that LPA’s set out to deliver in their Local Plan against the net additions in housing supply in their area.  In areas of consistent under-delivery, action will be taken to address this. One approach could be to identify additional sustainable sites, including new settlements, if the existing approach is demonstrably not delivering the required housing.

Unviable and underused commercial employment land

Amendments are proposed to paragraph 22 of the NPPF to clarify that unviable or underused employment land should be released unless there is significant evidence justifying its retention.

Alongside these proposals, the Government wishes to clarify and widen the scope of the current exception site policy for starter homes by incorporating other forms of unviable or underused brownfield sites such as land previously used for retail, leisure and non-residential institutional uses in order to increase the land available for starter homes.

Encouraging starter homes within mixed use commercial developments

The Government is keen to understand if there is potential to encourage a greater proportion of general housing and starter homes within mixed used developments. In cases where mixed use commercial development contains unlet units, these could be converted into housing, including starter homes.

Encouraging starter homes in rural areas

The Government proposes that starter homes on rural exception sites should be subject to the same limits on resale (5 years) as other starter homes to ensure local people are able to maximise the value and secure a long term place in the local housing market. They also propose that LPA’s would have the flexibility to require a local connection test – reflecting the needs of some rural areas where local connections are important and access to the housing market for working people can be difficult.

Enabling communities to identify opportunities for starter homes

The consultation proposes to amend national policy so neighbourhood plans can allocate small-scale sites in the Green Belt specifically for starter homes, with neighbourhood areas having the discretion to determine the definition of a small-scale site.

Brownfield land in the Green Belt

The Government proposes to change policy to support the regeneration of brownfield sites in the Green Belt allowing them to be developed in the same way as other brownfield sites, providing they contribute to the delivery of starter homes. It is also proposed to amend the current policy test in paragraph 89 of the NPPF preventing development of brownfield land where there is any additional impact on the openness of the Green Belt.


The proposed amendments have the potential to help facilitate greater housing growth.   

Developers will welcome the broader definition of affordable housing which could assist in making schemes more viable and also the relaxation of paragraph 89 to give greater flexibility for the redevelopment of brownfield sites in the Green Belt, which currently face the challenge of overcoming tests on openness.  

The proposed amendment to paragraph 22 of the Framework is also significant, which seeks to add greater emphasis and flexibility to the principle that brownfield sites, including non-employment ones, should not be retained in their last recognised use unless there is significant justification to do so. 

Whilst the Government proposes to give substantial weight to the development of brownfield land, the proposals stop short of returning to previous policies which expressed a clear preference for brownfield over Green Field development.

Following the consultation period it will be interesting to see if these amendments remain as currently proposed, as their impact has the potential to be significant.

If you have any queries or require further information, please get in touch.

Richard Barton
T: 0161 831 5876 E:
Christopher Bradshaw
T: 0161 831 5870 E:
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