Lawrence Turner of planning consultants Boyer discusses how the revised NPPF aims to meet Labour’s ambitious housing targets, from brownfield passports to grey belts.
Following Angela Rayner’s promise in July 2024 to spearhead a ‘decade of renewal’ with an ambitious housebuilding programme, the development sector was pleased to see the publication of a revised NPPF in December 2024.
In the wake of the Labour Government’s ambitious plan to build 1.5 million new homes by mid-2029, the NPPF has come under significant scrutiny and the Government’s vision appears increasingly challenging to fulfil. As the Home Builders Federation (HBF) recently reported, new build completions saw a significant decline, to just 198,610 in 2024, illustrating a substantial gap between the Government’s ambitions and the current trajectory of housing supply.
Furthermore, financial constraints stemming from high inflation and diminishing affordability has put a strain on first-time buyers’ access to the housing market and the HBF has urgently called for targeted Government interventions.
Housing targets
The new NPPF retains the majority of the Government’s proposed reforms to national planning policy. The most important of these, fundamental to increasing housebuilding, is the change to the ‘Standard Methodology.’ This increases local housing need figures and puts a greater onus on local authorities in city regions to meet their housing need – effectively delivering the outcomes of the failed Duty to Cooperate. Furthermore, the NPPF strengthens the requirement for local authorities to use the Standard Method and then to “meet an area’s identified housing need.”
A significant addition to the NPPF is that found at paragraph 78c, which requires that (from 1 July 2026) a 20% buffer be applied to an LPA’s housing land supply where its annual housing requirement (adopted under a previous version of the NPPF) is 80% or less of the most up to date local housing need figure calculated using the standard method.
PASSPORT TO Brownfield
Further emphasis has been placed on putting brownfield development first, with reference to brownfield ‘passports’ and the strengthening of NPPF paragraph 125, which states that brownfield proposals should be “approved unless substantial harm would be caused.” Closely following previously developed land, is the important role of ‘grey belt’ sites in meeting the Government’s 1.5 million home target.
Green Belt
The Government has made significant changes in relation to green belt policy. Notably the new NPPF includes a requirement for an authority unable to meet housing needs without altering a green belt boundary to undertake a ‘green belt review.’ The concept of ‘grey belt’ land will be fundamental to meeting our housing needs. The NPPF provides clarity on what land would qualify as a grey belt.
The Government’s proposed “golden rules” for releasing Green Belt land remain: however the NPPF has been updated at paragraph 67 to require LPAs to set specific affordable housing requirement for major housing development on land which is proposed to be released from the Green Belt, or which may be permitted on Green Belt land. This percentage requirement should be higher than land outside the Green Belt and require at least 50% affordable subject to viability. Until these local plan policies are adopted, paragraph 157 requires a 15 percentage point top-up on the Plan’s currently adopted affordable policy, capped at 50%.
Need for government intervention in housebuilding
To streamline the planning process, the Government has also announced proposals to modernise planning committees, including the possibility of limiting the number of councillors involved in decision-making and a two-tier system of planning committees.
Meeting the 1.5 million homes target will inevitably create a significant challenge and a pressing need for effective Government intervention in plan-making and decision-taking. As various local authorities have expressed scepticism about the achievability of new housing need targets, proactive measures will be required for the Government to even get close to its target.
One of the challenges for the Government will be to decipher which local authorities are deliberately stalling in their plan-making, and which are failing because of a chronic lack of resources and funding.
In response to these challenges, the NPPF’s transitional arrangements were updated at paragraph 234. As of 12 March 2025, the NPPF came into full effect, marking the start of its new planning policies for local authorities.
Local Planning Authorities (LPAs) were required to have progressed their Local Plans to the Reg. 19 stage by 12 March, provided the draft housing requirement met at least 80% of local housing needs (previously, the benchmark was for a Plan to be within 200 dpa of the local need figure) or had submitted their Plan to the Secretary of State. Many LPAs are now revisiting their housing land supply to ensure that their plans align with the new criteria.
Paragraph 236 introduces consequences for LPAs that submitted Plans under the transitional arrangements but failed to meet at least 80% of the identified housing need. For those LPAs that reached the Reg. 19 stage before 12 March with a draft housing requirement below 80%, they are now required to proceed to examination within 18 months of 12 December 2024 – or face potential intervention by the Secretary of State.
Immediate impact of policy changes
In the short term at least, an inevitable consequence will be an increase in speculative planning applications. Developers will put forward speculative planning applications with greater certainty of success because many local authorities are now in a position whereby they either have an adopted Plan that is more than five years old, requiring them to use a substantially increased housing need figure set out in the Government’s new standard methodology; or are preparing a new Local Plan to meet this increased housing need.
Invariably planning committees will resist such development – particularly if it is at odds with their adopted Local Plan; or if it runs against some councillors’ long-held views that no green belt land should be released. In such circumstances, we expect it very likely that the Government will call in such applications and decide in their favour. Expect high profile schemes to receive a positive determination from the Secretary of
State – demonstrating to planning committees that NIMBYism must not trump housing needs as it did under the previous administration.
Expect also to see a rise in the number of planning permissions granted at appeal. Some local authorities, nervous of the political impact of increased development, will likely resist granting planning permission; and developers, more confident of success, will appeal in larger numbers. This will put increased pressure on the Planning Inspectorate and the government may need to consider increasing resourcing and funding for the Planning Inspectorate to mitigate delay.
There may be a point in the future when planning policy is suitably changed to allow large-scale development to take place, but then what? In the last few years supply lines have adapted to the number of homes currently being built, which is significantly below target. We don’t have enough construction workers, bricklayers and roofers – let alone manufacturers and installers of air source heat pumps – to deliver a 50% increase in volume.
Conclusion
Back to today: despite the publication of this key piece of planning policy, the government’s programme of planning reforms has only just begun: in 2025 we anticipate a Planning and Infrastructure Bill; a suite of National Development Management Policies (NDMPs) to streamline and accelerate the determination of planning applications, by avoiding the need for local plans to duplicate NDMPs, and decisions following a series of planning working papers, the first of which have recently been published. It is certainly set to be an eventful year for planning and development.
Lawrence Turner is director of Boyer (part of Leaders Romans Group)