Proposed reforms to National Planning Policy Framework.
I have taken the time to review the proposed changes to the National Planning Policy Framework. The key changes have been simplified and are detailed below. The 
important section for consideration are proposed changes to the 5-Year Housing Land Supply (5YHLS), which will undoubtedly affect housing proposals across the Bradford District, as was the case at Sun Lane, Burley in Wharfedale.
Bradford’s housing target detailed in the Core Strategy of 2017 was set at around 42,000. These homes were originally scheduled for delivery by 2030. Within Local plan documents, are details for 21,928 new homes of which:
- 8,924 were planned on Previously Deloped land (PDL) or brown field sites (666 within 5-years, 8,258 in the years that follow).
- 5,999 on Greenfield, (648 within 5-years, 5,340 in the years that follow).
- 5,183 on Green Belt, (621 within 5-years, 4,562 in the years that follow).
- 1,833 from Mixed use land (976 within 5-years, 857 in the years that follow).
- Many sites are still to come forward, and only 21,311 homes are on the preferred site list.
That’s a total of 21,928 of the approximate 42,000 requirement. Bradford are still trying to complete their Regulation 18 Local Plan, and this is overdue. It appears that we will have to start work on Regulation 19. I’ll keep updating as matters progress.
Summary of the proposed framework.
The Green Belt and the Grey Belt
The draft National Planning Policy Framework (NPPF) introduces significant updates regarding the Green Belt, marking a necessary step forward. While I believe there’s still more to be done, these changes represent the most substantial reforms for the Green Belt since its inception.
Defining the Grey Belt
The draft NPPF officially defines the “grey belt,” a term first introduced by Keir Starmer in October 2023. According to the new definition, grey belt land comprises previously developed land within the Green Belt and other areas contributing minimally to the five Green Belt purposes, excluding particularly important assets. Developments on grey belt land can proceed as long as they do not compromise the overall function of the Green Belt.
Green Belt Reviews
Paragraph 142 of the NPPF states that adjustments to Green Belt boundaries are permissible only under exceptional circumstances, which must be well-evidenced. This remains consistent with previous guidelines. However, new exceptional circumstances include situations where local planning authorities (LPAs) are unable to meet housing or commercial needs through alternative means. In such cases, LPAs should reassess their Green Belt boundaries, proposing alterations only if clear evidence shows these changes would not fundamentally undermine the Green Belt’s function.
Moreover, the draft NPPF mandates that LPAs must review Green Belt land when preparing or updating plans. When considering land for development, LPAs should prioritize:
- Previously Developed Land (PDL) in sustainable locations
- Grey belt land
- Other sustainable Green Belt locations
Development Requirements
Paragraph 155 outlines conditions for major developments on newly released Green Belt land. Key requirements include:
- At least 50% of new housing should be affordable, with a portion designated for social rent, depending on viability.
- Necessary improvements to local and national infrastructure.
- Creation or enhancement of accessible green spaces for the public, ensuring that new residents can access quality green areas within a short walk.
This inclusion of affordable housing and accessible green spaces reflects a holistic approach to development, reinforcing the Green Belt’s integrity and shifting the narrative around building in these areas.
Broadened Green Belt Exceptions
The definition of exceptions for Green Belt development has been revised. Previously, limited infilling or redevelopment of previously developed land required demonstrating that new developments would not significantly impact the Green Belt’s openness. The updated paragraph simplifies this to allow development if it does not cause substantial harm to the Green Belt’s openness, eliminating the previous size requirements and affordable housing considerations.
New criteria in paragraph 152 state that developments in the Green Belt are not considered inappropriate if they utilize grey belt land in sustainable locations, provide the necessary contributions specified in paragraph 155, and do not fundamentally undermine the Green Belt’s overall function.
Presumption in Favour of Sustainable Development
The presumption in favour of sustainable development has been clarified, indicating that it applies when plan policies are outdated or absent. The updated NPPF emphasizes integrating locational and design policies alongside those related to affordable housing, ensuring that the presumption does not lead to low-quality development. This change aims to improve the effectiveness of this presumption as a failsafe for housing supply while introducing safeguards against poor-quality projects.
Local Housing Need Assessment
The national housing target has been raised to an ambitious 370,000 homes per year, up from 300,000—an unmet goal for over 50 years. To achieve this target, mandatory housing requirements have been reinstated, with councils now obligated to follow a standardized method for setting these targets. Reductions in housing requirements can only occur with substantial evidence of local constraints, such as national parks or flood risk areas.
Restoring the 5-Year Housing Land Supply
The recent changes to the 5-Year Housing Land Supply (5YHLS) will be reversed. LPAs must demonstrate a 5YHLS, regardless of when their local plan was adopted. Bradford hasn’t had a 5YHLS since the early 2000s. This entails updating the supply of deliverable sites annually, ensuring sufficient land for housing for the next five years. A failure to demonstrate a 5YHLS can be grounds for Green Belt development approval, especially when coupled with other significant factors like affordable housing needs.
Transitional Arrangements for Emerging Plans
For councils currently developing local plans, transitional arrangements will apply. Plans in the examination stage will be evaluated under the current NPPF. If a new local housing need figure exceeds the existing requirement by 200 homes or more, a new plan will need to be prepared. Similarly, plans in the Regulation 19 stage can continue under the existing framework, provided the difference in housing figures remains below 200.
Industry Responses
The housing industry has largely welcomed the reforms introduced in the draft NPPF. Melanie Leech, Chief Executive of the British Property Federation, noted the government’s commitment to delivering more homes through a multi-tenure approach. Neil Jefferson, Chief Executive of the Home Builders Federation, echoed this sentiment, highlighting the hope these changes bring to the homebuilding sector.
Even organizations like the Countryside Alliance have acknowledged the reclassification of some land as grey belt, recognizing the need to balance development with countryside protection. It’s encouraging to see a growing understanding of the Green Belt’s purpose, paving the way for rational discussions about land use and development.
