The National Planning Policy Framework must recognise the rural economy

The proposals contained in the National Planning Policy Framework (NPPF) consultation miss the opportunity for an enhanced recognition of rural areas within national planning policy, particularly regarding the rural economy and rural housing, the CLA says in its response.

At the end of July, Angela Rayner, Minister for Housing, Communities and Local Government, announced proposed updates to the NPPF that were in line with the Labour party’s pledges for planning reform, specifically housebuilding.

With proposals to revise green belt policies, including the introduction of a new benchmark land value, the CLA is making the Ministry of Housing, Communities & Local Government (MHCLG) aware of the potential consequences this could have for rural communities and landowners.

The CLA has provided feedback on a proposed new ‘grey belt’, changes to the calculations for housing need, the delivery of more affordable homes, economic growth and how planning policy can support clean renewable energy and the environment.

As part of its wider ambitions for devolution, the new government wants to implement cross-boundary strategic planning. Amendments have been proposed to the NPPF to ensure greater collaboration between local authorities for local plans and minerals and waste plans. The CLA is supportive of improvements between local planning authorities as cross-boundary strategic planning provides the opportunity to address regional issues within rural areas. This can include the loss of services and facilities, need for affordable housing and support for agricultural development and diversification.

There is an opportunity for the NPPF and planning system to recognise that the provision of new housing in one community could enable the revival of that settlement’s sustainability and the sustainability of the adjacent settlements.

We have repeatedly referred to the need for better acknowledgement of the differences in sustainability credentials for rural areas versus urban areas throughout the NPPF consultation response. For example, enabling new housing in one small settlement could keep the village school open, which serves children from four adjacent villages. If housing does not come forward, the service or facility provided in one village (but serving those from nearby villages) will be lost. This will ultimately reduce the sustainability of a wider rural area and reduces the chances of future housing coming forward.

While a large part of the NPPF consultation focussed proposals to reform green belt policy, it also proposed the highly anticipated definition of a new ‘grey belt’.

This new tier of green belt land will comprise areas of previously developed (brownfield) land or land that makes a limited contribution to the purpose of the green belt. It is proposed that a sequential approach to development in the green belt should be undertaken, looking at previously developed (brownfield) land in the first instance, then grey belt and finally, ‘higher performing’ green belt sites that have the opportunity to become more sustainable.

The CLA would be supportive of a sequential approach to development in the green belt; however, there must be a recognition of the type of development that members are likely to deliver, such as farm diversifications, small village extensions and rural affordable housing.

We have therefore proposed the following:

• Include an addition to the exceptional development allowed in the green belt and support reasonable development for the diversification of rural or agricultural businesses.
• Undertake a review of green belt boundaries, avoiding the release of land adjacent to large settlements but releasing smaller rural settlements that are washed over by the designation. Settlement boundaries as they exist in local plans should be introduced and appropriate small scale development that would represent the ‘rounding off’ of a settlement should be introduced.
• To enable the delivery of rural exception sites, ensure that up to date local housing need assessments are considered as very special circumstances.

These three askes have been informed by discussions with CLA members and through liaison with a CLA working group with a representative from each region focusing on the green belt as a whole.

As set out within the consultation, the proposed definition for the grey belt will be previously developed land and any other parcels/areas of land that make a limited contribution to the purposes of the green belt. The definition is explicit in its exclusion of habitat sites, Sites of Special Scientific Interest, local green spaces, National Parks and Landscapes, irreplaceable habitats, designated heritage assets and areas at risk of flooding or coastal change.

While the CLA supports the exclusion of areas of importance, the exclusion of National Parks and Landscapes (formerly known as AONBs) and designated heritage assets places further restriction on development in areas that are already significantly hindered. There will be instances of grey belt sites in National Parks, and the redevelopment of these sites must be encouraged. If the redevelopment of a heritage asset could be achieved, it must be supported.

The definition also makes reference to ‘urban land uses’ and ‘substantial built development’, with little indication of what these explicitly mean in planning terms.

The CLA is calling for not only a better explanation but also a recognition that there are redundant agricultural sites in the green belt that must fall under the grey belt definition as well. Alongside other stakeholders, the CLA is also calling for clearer guidance surrounding the new definition and designations. It must not be left for case law to decide what constitutes grey belt land, a clear definition is needed at the time of publication of any new planning policies.

The government also proposes to allow the limited use of viability assessments in the green belt but restrict the inflation of landowner or developer profits ‘at the expense of public good’. The use of viability assessments is proposed where negotiation is genuinely needed for development to come forward, particularly in relation to affordable housing requirements.

While the proposal to introduce benchmark land values is green belt specific, there is a risk that it could eventually trigger their use for all development. Any use of benchmark land values must acknowledge the true cost for both a landowner and developer in terms of putting land forward for development and achieving planning permission. The proposals within the NPPF consultation appear to err on the side of caution and risk interfering with a market that has the potential to deliver many more homes than it currently is.

The proposed NPPF has the opportunity to implement planning reform that will make a difference, especially alongside the proposed Planning and Infrastructure Bill. Therefore, the CLA is calling for wider issues with the planning system to be addressed before such a proposal is explored further.

With the new government seeking to deliver the biggest increase in social and affordable housing in a generation, the NPPF provides an opportunity for the CLA to lobby for several of our rural housing policy asks.

While the draft NPPF does not propose any amendments that will enable more affordable rural housing to come forward, the consultation specifically seeks views on the best approach for supporting affordable housing developments within rural areas. As part of our response, we are calling for the amendment of the definition affordable housing to enable landlords to become registered providers of affordable housing and able to deliver these types of scheme. We are also continuing to recommend the use of a ‘Planning Passport’ for rural exception sites.

The consultation is aware of the need to increase homes in rural areas and asks broad questions on how best to deliver; however, it fails to acknowledge that the rural economy has a vital role to play for the economy as a whole. There needs to be acknowledgement that in addition to agriculture and other land-based rural businesses requiring development and diversification, new rural businesses need the opportunity to start up in rural areas.

Greater guidance needs to be provided within the NPPF and planning practice guidance on these types of developments at the same time as improved skills and training of local authorities on rural issues and agricultural matters. The better understanding of what these needs are, the more support these proposals may receive.

Alongside the changes to the NPPF, the consultation also asked for views on increasing planning application fees, specifically for householder development. It is undeniable that further increases to some planning fees would ensure adequately resourced local authority planning departments, but only if they are ringfenced. However, for planning reform of any kind to work, ringfencing of the application fees must be introduced, as a lack of dedicated funding for these departments undermines any reform to improve the application process.

It is also evident from the consultation that this government intends to utilise existing tools for planning reform, specifically National Development Management Policies (NDMPs), which were legislated for within the Levelling Up and Regeneration Act 2023.

The CLA continues to monitor the progress of the Planning and Infrastructure Bill, which was announced in the Kings Speech. This bill is expected to cover: compulsory purchase, streamlined delivery for critical infrastructure, modernisation of planning committees, strategic planning, methods to increasing local authority capacity and the speeding up of housebuilding.