Spot the difference: What does the new NPPF mean for planning and community engagement?
After much anticipation, the revised NPPF has been published. While it is fair to say that there are no drastic changes from the draft for consultation that was published in March, there are a number of elements that have attracted comment. These include beefed-up text on the importance of good design, new references to garden city principles for strategic schemes, and the reinstatement of social rent in the definition of affordable housing.
The section of the NPPF that has most relevance to community consultation, titled Pre-application engagement and front-loading ‘remains largely unchanged. Most significantly, the section is given greater prominence due to its location in the document: it now begins at paragraph 39 rather than the previous 188.
Positional changes aside, there have been two minor additions to the text about pre-application engagement. New paragraph 40, which deals with an applicant’s engagement with LPAs and communities, includes a new clause encouraging developers to liaise with “statutory and non-statutory consultees” before submitting applications. Also, new paragraph 41 cites infrastructure and affordable housing improvements as examples of issues that should ideally be resolved prior to the submission of a planning application.
It’s fair to say that neither of these changes are likely to be considered game-changers for community consultation in planning. The first addition simply adds reference to a practice that is already de rigueur for major development, while the latter does nothing more than add obvious examples to an existing policy.
It would, however, be a mistake to conclude from this that the NPPF is unlikely to have a significant impact on communities or decision-makers. The effects of the revised framework are likely to exceed the sum of its constituent revisions. For example, initial reporting of the new framework has focussed on the greater emphasis placed on high quality design; this may have an impact on what communities and politicians believe is acceptable for a development proposal.
The impact of the new NPPF on the politics of the Conservative Party is also worth considering. Many Tory councillors, particularly in the South East, reacted badly to the publication of the draft standardised housing need assessment in March, believing that it punished local communities for what they believed to be developers’ failure to deliver homes at fast enough rates. It is, of course, unfair for councillors to blame housebuilders for slow delivery, particularly in districts where planning committee members are happy to overturn strong officers’ recommendations to approve, but the ratification of the standardised needs assessment may only reinforce a sense of ‘us versus them’ between developers and Conservative members. Relations between the Tory grassroots and the government are currently very poor following Theresa May’s Brexit Chequers deal, which is seen by many party members to be a betrayal of the party’s red lines. It seems unlikely that the perceived imposition of thousands more homes will help heal divisions between different elements of the party.
This article was written by Richard Parry, Associate Director at MPC.