Agenda item

The report of the Chief Planning Officer outlines that on the 30th of July 2024 the Government launched an 8-week consultation on proposed changes to the National Planning Policy Framework (NPPF) and a series of wider national planning policy reforms. The report summarises the key proposed changes as part of this consultation, such as a new standard method for calculating Local Authority housing requirements and, in conjunction with Appendix 1, highlights the proposed response of officers across a range of Council departments.

The report of the Chief Planning Officer outlined that on the 30^th of July 2024 the Government launched an 8-week consultation on proposed changes to the National Planning Policy Framework (NPPF) and a series of wider national planning policy reforms. The report summarised the key proposed changes as part of this consultation, such as a new standard method for calculating Local Authority housing requirements and, in conjunction with Appendix 1, highlighted the proposed Council response, collated in conjunction with a range of Council departments.

The Group Manager for Policy and Plans presented the report, providing Members with the following information:

• On the 30^th of July 2024, the Government had published a proposal detailing revisions to the NPPF and wider planning reforms, alongside a consultation on its contents, with responses due by the 24^th of September 2024. Appendix 1 outlined the draft response, which was to be reviewed, subject to Members comments, and submitted by the Chief Planning Officer, in consultation with the Executive Member for Economy, Transport and Sustainable Development.
• The key changes proposed by the reforms were highlighted as the revised approach to calculating housing numbers and new policy for green and grey belt land.
• Housing number reforms proposed that Local Authorities were to make best efforts to allocate land to meet the needs of housing targets using new methodology for calculating overall housing stock and an affordability multiplier which generated a figure for Leeds as 4,159 new housing units per annum.
• The new calculated housing number raised challenges given that in previous years housing number targets had not been met and also had implications on the development of new local planning policies, including Leeds Local Plan 2040 (LLP2040).
• Leeds held an excess of the 5 year land supply requirement, however, this was to be reduced by the new housing number target but would still remain as an excess.
• Paragraph 10 of the report noted that the draft response supported a number of measures proposed by the reform, but concerns regarding deliverability were raised as it was developers, and not planning authorities that built housing units. The onus should be on developers to deliver housing, where sound policy and permissions were in place in order to not create additional pressures on land release and a risk in public trust, undermining local plan making, was outlined.
• The draft response also noted that greater weight should be given to affordable housing numbers given that affordability was a major element of the of new calculation method.
• The proposed reforms noted a clear requirement for housing needs to be considered an exceptional circumstance for land release from green belt. A green belt review was being undertaken alongside LLP2040.
• A new definition for grey belt land had been provided as any land within green belt that had been previously developed or that make limited contribution to the five purposes of green belt. These measures weakened protection of green belt against the interest of housing provision and other development.
•  Concerns for the decision making process supporting development of green belt land were raised in the draft response as allowances were made outside of the plan making process.
• Paragraph 17 of the report detailed other changes proposed by the reforms, with the draft response supporting the affordable housing changes, removal of the term beauty, renewable energy, highways, previously developed land, planning fees, duty to co-operate and broad design measures.
• Further information was requested for economic development, infrastructure levy changes, renewable energy, energy efficiency and reviewing or revoking the Written Ministerial Statement, as part of the draft response.

Members discussed the following key matters:

• As the reforms were understood to create pressures on the functions of green belt land, an approach to prioritise higher value green belt or in areas where its overall size was limited was needed. In response it was outlined that national policy did not add weight to any of the five purposes of green belt over one another, but where limited green belt was available, the function of preventing settlements from merging was significantly weighted.
• The green belt review was an appropriate vehicle for identifying higher value green belt land where larger segments could be grouped and then assessed against the five purposes, to inform suitable site allocation. Prior to the release of green belt, other sources of land were to be satisfied first, however, green belt was performing a spatial function within the context of the five purposes and a strategic, consistent approach was needed to determine land supply against character and function.
• It was outlined that the Conservative Group were submitting their own response to the NPPF reforms.
• There was concern expressed for the additional pressures the reforms placed on Local Authorities to increase housing numbers, whereas there was limited influence over developers carrying out planning permissions within quicker time frames. The reforms reflected a need for an increase in houses built but required greater focus on affordability and there was a risk in releasing additional land without increasing housing delivery or whole system change as the planning system was only one part of the solution.
• A greater enforcement model was needed to bring planning permissions into fruition and in addition, the idea that building more houses would decrease house prices was limited by an often fixed market approach on developer profit margins.
• The proposed national methodology for determining housing numbers was supported as a broad principle but there was some confusion as to how local planning policies were to hold up the methodology in principle, alongside land supply capacity and the housing target within the core strategy now being 5 years old. There was some ability to dispute NPPF housing numbers using specific exemptions.
• Clearer definitions for green belt exemptions and grey belt land were requested as the increased housing number targets created significant pressure on land supply. Previous definitions and exemptions had been vague to allow decision maker discrepancy, but the reforms provided a measure for release to meet housing needs.
• Mandatory national targets for affordable housing for all sites was required in order for public needs to be met. Current material considerations of viability were often barriers to widespread affordable housing provision.
• A well considered review was needed to create a sound approach to infrastructure levy’s and associated CIL contributions, to ensure enough infrastructure was in place to support new developments.
• It was suggested that the response needed to be bolder in order to be clear what policies and processes Local Authorities needed to support the delivery of high quality development. It had been too common for viability to be a major material consideration for decision making bodies and greater weight should be available to local needs in policy terms.
• Reflecting on the housing affordability crisis, the ability for Local Authorities to inform the percentage of affordable houses required, as well as the focus on social rent levels were supported. The draft response, alongside partnership working with Homes England, provided a welcome opportunity to provide a meaningful impact on tackling the housing crisis and any additional mechanisms available to increase truly affordable housing was essential.
• The removal of first homes requirement from the NPPF was supported as this approach did not address the reality of housing needs.
• Methods for enforcing the implementation of planning permissions were discussed, including a suggestion regarding reducing the timeframes offered to developers.
• Members supported the response for the approach to energy efficiency and associated targets.
• The definition of affordable housing was required to be reviewed in order to provide truly affordable housing across all areas. An arbitrary rent reduction was not enough for meeting needs and addressing the housing crisis.

RESOLVED –That the contents of the report and Appendix 1, along with Members comments on the proposed response to the National Planning Policy Framework consultation, prior to the Chief Planning Officer submitting these in consultation with the Executive Member for Economy, Transport and Sustainable Development, be noted.