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GVA Welcomes National Planning Policy Framework

Tuesday, 27 March 2012

Alistair Andrew, associate at GVA, comments:

On viability and deliverability:

"We are in strong support of the inclusion of paragraph 173 - which recognises that we are still operating in a challenging economic climate and that in many cases, unreasonable demands continue to be placed on developers and house builders, creating a serious constraint on the delivery of new schemes. Indeed, it is the need to identify truly deliverable housing sites, together with the challenge of viability and the lack of development finance, that remain as the biggest obstacles to new development in a post-NPPF world."

On housing supply:

"The requirement on local authorities with a proven track record of housing delivery to identify a five year housing supply with a 5% buffer is a strong indication of Government's commitment to increasing the rate of housing delivery going forward. Those with a record of 'persistent under delivery of housing' will have to provide a 20% identify buffer. Government needs to provide more detail on how it intends to monitor and enforce this rule upon authorities - and there will be a debate over how this record of under delivery will be quantified and interpreted."

On town centres first:

"As expected after the much-lauded Portas Review, Greg Clarke has taken the opportunity to firm up the pro town centre policy stance in the new National Planning Policy Framework.

The NPPF advocates a plan led approach, and encourages local authorities to promote competitive town centre environments. However, following last week's Budget there is still no substantive Government response to the challenges to town centres identified by Portas, or concrete measures to address the viability of new town centre development.

The document highlights the importance of viability in plan making, but does not clarify how the suitability, viability and availability of town centre sites is to be assessed when planning for new development. Nor does it comment on how the current viability challenges facing many town centre schemes are to be taken into account when considering less central alternatives.

The NPPF advocates that local authorities should continue to allocate sites to meet retail, leisure and office needs in full and ensure a sufficient supply of sites. However, it fails to clarify what constitutes a reasonable timescale for forecasting and meeting identified needs. 

As a significant departure from the Draft NPPF, the final document advocates local authorities allocating town centre and edge of centre sites to meet identified needs, but pulls back from suggesting that out of centre sites should be allocated-instead suggesting criteria based polices i.e. the sequential approach and impact assessment.

As predicted, the NPPF also reinforces the sequential approach. It reintroduces offices as a 'main town centre use', and as a consequence requires sequential site assessments and impact assessments for all but small scale rural offices.

The 'preference' for town centres set out in the Draft is gone. Instead, local authorities should require applications to be in town centres or, if sites are not available, edge of centre sites. It also reintroduces the requirement for applicants and local authorities to demonstrate flexibility on issues such as format and scale.

The NPPF retains the two key impact tests from the draft, and also reintroduces policy EC17 from PPS4, stating that where an application fails to satisfy the sequential test or is likely to have a significant adverse impact it should  be refused.

Given this was probably the most draconian aspect of the old PPS4, its retention appears to suggest that as far as town centres are concerned, the intention appears to suggest no significant change of policy direction. Inevitably, the key issue will be how the sequential approach and impact tests are applied in practice."