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NPPF Round Two
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Last week, over a coffee and croissant, Iceni Projects, Town Legal LLP and invited guests, sought to digest the NPPF Review. Seemingly a tall order for breakfast, but in reality does the NPPF round two actually suggest any radical divergence from the existing Framework?
Not unexpectedly, the lively discussion presented a mix of views on how far the NPPF Review actually goes in making changes. One thing that is agreed upon, though, is the fact that this review places the importance of the Local Plan at the heart, and arguably ahead of the NPPF; as Mary Cook at Town Legal put it, a reversal of the existing NPPF.
Getting an up-to-date Local Plan in place is going to be even more important moving forward, with greater weight placed on them when making planning decisions. There is a subtle change in the rhetoric the Review uses to test a Local Plan: no longer will it be necessary for authorities to demonstrate it is ‘the most appropriate strategy’, they simply will need to demonstrate that their Local Plan is ‘an appropriate strategy’. Does this mean we are witnessing a weakening of Local Plans? In reality probably not; for some time the Planning Inspectorate has been interpreting this test in the proposed revised wording.
This subtle change reflects what some see as the overall approach to the NPPF Review. Rather than any seemingly tangible changes, the NPPF Review is simply a refinement of language. A tinkering around the edges if you will. However, as demonstrated by the questions raised at our breakfast event, this is a far too simplistic assessment. The Review does more than play with the language, it actually introduces some interesting changes to process.
One of the key changes that has got many asking questions around practicality, is the introduction of the need to undertake viability assessments during the Plan-making process. This might seem like a logical approach to those developing the plans, but it contradicts the purpose of a Local Plan, which is to provide a framework for planning in an authority over many years; a plan for the future. A viability assessment on the other hand is a snapshot in time. Surely the two concepts cannot coexist in one policy? It might be a way of seeking to speed up the decision-making process by front-loading the evidence base, but in reality it will be inevitable that changes in circumstance will necessitate further viability work when the time comes.
Despite these niggling questions, timings suggest that the NPPF Review is unlikely to alter considerably before the final documents are published before the parliamentary Summer Recess (as anticipated). To help guide your way, our colleagues at Iceni Projects have trawled through the NPPF Review with a fine toothcomb and have offered their insights on the key areas they think matter: Plan Making; Green Belt; Build-to-Rent (a welcome introduction in the Review); Deliverability; Effective Design; and Viability. You can read our guide here; and if you have any questions or thoughts about the Review, we would love to hear from you.