Expert Insights

Expert Insights

Part 2: Consultation on revisions to the NPPF

Some of the other key takeaways from the proposed changes to the NPPF

In this section, we summarise some of the other key takeaways from the proposed changes to the NPPF.

Older persons housing

In considering the needs of older people, particular regard should be had to retirement housing, housing-with-care and care homes, and a taskforce on older people’s housing is proposed.

Affordable housing

It is proposed to attach more weight to social rented units in policies and decision making, which could affect the planning balance in some cases.  “Community-led developments” would be defined and locally-led affordable homes, including on exception sites, supported.  Views are sought on whether affordable housing for rent could be provided by bodies which are not registered providers.


LPAs must already seek to accommodate at least 10% of housing requirement on sites of up to 1 hectare and use tools such as area-wide design assessments and local development orders for smaller sites.  Views are sought on how this could be strengthened, particularly for delivery of affordable housing, to assist SME builders.


Controversially, the government is consulting on whether irresponsible planning behaviour should be taken into account on applications.  It is a longstanding principle that decisions should be based on planning merits, although personal circumstances can be taken into account on occasion.  The government considers irresponsible behaviour could become a material consideration or a reason to decline to determine applications.  Given this would not stop the trading of land with planning permission, it seems disproportionate and subjective.

Build out

The government wants developments to be built out as soon as possible once permission is granted.  The Bill includes requirements to notify LPAs of proposed delivery trajectories and streamlining of completion notices, but these merely result in permission lapsing after a certain period (although also potentially more discretion on further applications), so may not result in faster delivery.

The government also proposes to publish data on larger developers where they fail to build out as planned; require consideration of diverse tenures to maximise sale rates; and highlight that delivery can be a material consideration (so applications with slow delivery rates may be refused).  A separate consultation on a financial penalty for developers who build out too slowly is proposed.  It remains to be seen whether this could capture landowners.


Yet more references to the subject term “beauty” are proposed.  Conditions should secure plans and drawings providing “visual clarity” about design and materials.

Mansard roofs

It is proposed that LPAs must take a positive approach to well-designed upwards extensions.  At a bizarrely detailed level, the amendments would clarify that mansard roof extensions should be allowed in certain circumstances, and a condition of simultaneous development across a terrace should not be imposed unless there is exceptional justification.

Net gain

The government is reviewing policy to ensure that the biodiversity net gain proposals due to be introduced from November do not result in developers clearing sites before applying for permission to lower the baseline (although there are provisions in the Environment Act already that could take account of this).  Small scale changes to enhance biodiversity are to be encouraged – the use of artificial grass in new developments is to be considered adverse.

Agricultural land

The NPPF already states that poorer quality land is preferred to higher quality land for development; it is proposed to add that the availability of land used for food production should also be considered in deciding what sites are appropriate for development.

Levelling Up

The government is keen to hear about what policies could help achieve levelling up.  In addition, the wider review of the NPPF is intended to reshape policies on the economy to align more closely with the levelling up mission including by requiring local plans to support new business investment and growth of existing businesses; supporting sectors and businesses that drive productivity including life sciences and spreading financial capital and investment to places that need it most.  The government is consulting on whether national policy could further encourage development on brownfield land in city and town centres, to encourage gentle densification.  It also wants to know whether there is support for the wider review considering policies to make sure women, girls and other vulnerable groups feel safe in public spaces (for example on lighting).

Carbon impact assessment

The wider review of the NPPF will consider climate change mitigation and adaptation and a separate consultation is planned on the approach to measurement and reduction of embodied carbon.  The government seeks views on how a carbon impact assessment could apply in planning policy and decision making.

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