A consultation on changes to the National Planning Policy Framework, published earlier this week by the Department for Communities and Local Government, sets out the government’s thinking on its proposed housing delivery test, first announced in last month’s Spending Review.
The consultation says that the proposed test would work by "comparing the number of homes that local planning authorities set out to deliver in their local plan against the net additions in housing supply in a local planning authority area".
According to the consultation document, the government proposes to amend planning policy to make clear that where significant under-delivery is identified over a sustained period, action needs to be taken to address this. "One approach could be to identify additional sustainable sites if the existing approach is demonstrably not delivering the housing required," the consultation says.
In a statement, the Campaign to Protect Rural England (CPRE) said that the test is likely to lead to more green fields being released for development as councils either plan for more development in advance or have to find new sites to develop when existing targets are not met.
CPRE welcomed the consultation’s measures to encourage brownfield development, but added: "We believe that the delivery test in its proposed form will allow developers to cherry pick greenfield sites, letting the brownfield sites go to waste."
CPRE planning campaign manager Paul Miner said: "This consultation is really concerning. Instead of addressing the current difficulties in bringing forward the right sites for the right homes, it proposes to release yet more land for development, often in the countryside and possibly in the green belt."
Responding to the proposal, the Royal Town Planning Institute (RTPI) said that local authority planning departments have suffered significant and disproportionate cuts, and this lack of resources is impacting negatively on local plan-making, planning performance and development in some places. "This issue will need to be addressed in relation to these proposals."
The RTPI also expressed concern over the consultation's proposed transitional arrangements, under which local planning authorities would be given between six to 12 months to consider making amendments to their local plans to reflect changes to the NPPF’s definition of affordable housing.
The RTPI said: "It seems likely that these changes will place extra duties on local authorities which are already struggling to meet the requirements for handling planning applications and writing local plans."
Margaret Baddeley, planning director at consultancy Nathaniel Lichfield and Partners, said that the NPPF would be "dramatically changed as a result of these policy measures".
She said: "The burden will now fall on local planning authorities in large part, to assimilate the implications of the changes for their local plans, regardless of what stage they are at – the government’s current view is that only the NPPF’s new affordable housing definition would warrant a transition period."
Roger Tustain, managing director at consultancy Nexus Planning, welcomed proposals to amend national planning policy so that neighbourhood plans can allocate appropriate small-scale sites in the green belt specifically for Starter Homes, but called for the government to "lead a debate on how parts of the green belt can be used to deliver all types of homes, not just Starter Homes, to plug the massive national housing shortfall".
He said: "Increased national planning policy support for community-led development in the green belt to deliver starter homes would be a step in the right direction, but to really deliver homes in the volumes required we need to have a full and frank debate about the purpose and function of the entire green belt around our key cities."