A new NPPF — Is this the biggest strategic land opportunity in our lifetime?
The NPPF consultation document has been published and the consequences of the suggested changes are vast. The new standard method calculations, if carried on, will almost certainly require large rewrites of any local plan that isn’t currently already at, or very close to, Examination.
A large amount of the spotlight will be on those Local authorities immediately affected by the potential changes, essentially, those that don’t have an up to date plan and don’t have one in its final few stages. However, your focus should almost certainly be wider.
We’ve looked at each local authorities’ current land supply and compared it to what the new standard method would require. The results? Complete carnage. Our research shows that only 25% of local authorities would be able to demonstrate a five year housing land supply if they had to measure their existing anticipated housing supply against the new standard method.
Most authorities that currently have an up to date plan will within a few years be subject to the new calculations. The key is that, historically, land allocated in the previous local plan would still be providing adequate land supply within the new plan. Now, in a large number of cases, the land previously allocated isn’t close to being enough. In specific cases, authorities could be close to starting from scratch with their new plans.
Most authorities building new local plans will therefore have to allocate a considerably larger amount of land than previously planned in order to not fall foul of the presumption in favour of development.
Just how much land? Which local authorities are most affected? We’ve built an interactive map of all the data, so you can compare the two. Take a look at our research here.
If they had to measure against the new standard method now, 20 percent of local authorities would loose 3 years or more from their five year housing land supply figure.
The stats are stark, but specific examples are even more so. We picked out a couple interesting examples from our research.
Stratford-on-Avon council have been a historically, pragmatic and over-performing local authority. As per their last AMR, they suggested a 14.5 year housing land supply. With the new Standard Method and their current land supply allocation, they would be measured at 2.6 years land supply.
Crucially, they would be suffering from a more niche clause in the new standard method, namely:
We are also proposing to remove the wording on past oversupply in paragraph 77, which was introduced to set out that previous over-supply could be set against upcoming supply. Given the chronic need for housing we see in all areas, we should celebrate strong delivery records without diluting future ambitions.
They historically overdelivered on housing, to the tune of building 2,699 more homes in the previous plan period than required. It might be worth asking about incentives at this point, does this cause the local authorities to see over delivery incredibly negatively? We will have to wait and see.
The consequence will be this, within their current Stratford-on-Avon Site Allocations Plan, they will almost certainly need to allocate considerably more land, so get in touch with your landowners there, or go and find some!
Dorset is a complicated authority, although being unitary since 2019, the local plan is currently still at Preferred Options stage. As such, it is difficult to estimate it’s five year supply. The figures above are taken from combining each of the AMRs from each of the individual old local authorities: East Dorset, North Dorset, Purbeck, West Dorset, Weymouth and Portland.
As you can see, Dorset looks to be significantly affected by the standard method changes. Every adopted plan within the district is out of the five year threshold. So, their land supply figures will need to be calculated against the standard method.
Fundamentally, they will need to allocate a considerable amount of land within their current Regulation 18 plan to even get close to a five year supply. This is a district worth looking at!
There has undoubtedly been a shift of focus from South to North, or more specifically, a national rebalance. A much more even distribution of housing need will naturally bring with it a requirement for more land to be allocated.
Westmoreland and Furness is an interesting example, with a Joint Plan in its earliest stages and each of the 3 local authority plans either out of date or in a similar position as the Joint one, the new Unitary authority will need to look to allocate a significant amount of land.
