Thoughts from the Shovel Face: Thoughts on England’s new National Planning Policy Framework


Paul Nathanail, managing director of Land Quality Management Ltd, discusses the National Planning Policy Framework, the issues with housing projects and how by failing to plan, you plan to fail

A personal view and guest blog written for Argyll Environmental by Paul Nathanail, managing director of specialist environmental consultancy, Land Quality Management Ltd

Tuesday, 24 July 2018: #schoolsout! Parliament’s last day before the summer holiday (aka summer recess) saw a flurry of announcements from many ministries and departments: public sector pay rises, permission for hydraulic fracturing in Lancashire, the reallocation of responsibilities for “Brexit”, release of surplus land from the Defence Estate and of course the long awaited, and much consulted upon, update of the National Planning Policy Framework (NPPF) – NPPF2018.

As a material consideration, NPPF2018 can in some circumstances be used to override the local development plan.  This may well become important in cases where the local plan was produced under the ‘old’ NPPF.

Sustainable development

“Sustainable development”, and the presumption in its favour, remains centre stage.  Its economic dimension focuses on using land for competitiveness, innovation and infrastructure. The social dimension embraces the tensions of more housing, better design, open spaces and access to services. The environmental dimension brings together a wide range of aspirations including moving to a low carbon economy – something that could be a powerful motive for development that reduces car reliance – and improving biodiversity.  Even dear old prudence makes a comeback – this time in how we use natural resources.

Local plans

Non-compliance with the local plan – including any neighbourhood plans, as the Department reminds us – is grounds for refusal unless material considerations dictate otherwise.

Building in line with the new National Planning Policy Framework Neighbourhood plans are given a special, time stamped diluted status that flies in the face of them being part of the local plan once they are made.  Accelerated housing delivery is the goal and NPPF2018 does its bit to ensure planning does not get in the way. So having a robustly determined housing requirement that translates into homes on the ground at a realistic build-out rate is key.  Delivery less than 45% of requirement over the past 3 years? Less than a three year supply of deliverable sites?  Not quite got the 5 year housing supply? Neighbourhood plan more than two years old? All these would weaken the weight any policies in a neighbourhood plan.

Local plan making and decisions require objectively assessed housing needs.  But, there is a Lorax-friendly ‘unless’… Various land and habitat designations can restrict the scale and distribution of development in an area. Such designations include green belt, local green spaces and flood prone areas.

Supplying housing

The outcome of Sir Oliver Letwin’s review of housing delivery [] needs to square cornucopian permission granting with lagging delivery. He has already recognised that changes to the current system are needed to ensure new homes are built faster alongside training some 15,000 more British bricklayers over the next five years to help meet the government’s target of moving from 220,000 to 300,000 new homes a year [].  Local planning authorities control the number of sites with planning permission but their plans are neutered if the houses are not built – something outwith their control. The builders’ use of absorption rates to control prices locally is seen by Sir Oliver as the main cause of delays [].  He urges house builders to offer greater variety of homes and in more distinct settings so that overall build out rates could increase.

The pursuit of variety is discussed in the new NPPF in the context of identifying land suitable for housing.

Small sites are particularly encouraged. Indeed the NPPF includes a strong recommendation to planning authorities that at least 10% of housing requirement be met on sites smaller than 1 hectare.  But it is the large sites – in the form of new settlements or large urban extensions – where the NPPF sees the biggest potential and where the provision of variety, seen as essential by Letwin, can best be met.

There is more that could be – and no doubt will be – written, said and discussed. In the meantime, the NPPF2018 edition can be downloaded, and then searched for your pet keyword(s) from:



A personal view and guest blog written for Argyll Environmental by Paul Nathanail, managing director of specialist environmental consultancy, Land Quality Management Ltd.


Please enter your comment!
Please enter your name here