Revised NPPF: Key takeaways you need to know

Key changes to green belt and housing policy

The revised National Planning Policy Framework (NPPF), part of the Government’s manifesto commitment to deliver 1.5 million homes, introduces significant changes which seek to accelerate planning reform and address Britain’s housing shortage. Whether you’re a housing developer or land promoter, these updates are a wake-up call to revisit your strategies and ensure you’re ready to navigate the evolving planning landscape.

Game-changing updates which re-engage the ‘tilted balance’

The revised NPPF reverses some of the detrimental impacts of the 2023 version and focuses on meeting housing needs including;

• Standard method changes: Updates to the Local Housing Need (LHN) figures will lead to reassessments of housing requirements by LPAs. The increases are most significant in the South East.

See what the updated NPPF means for the number of new homes planned for each local authority compared to the summer consultation >

• Tilted balance engagement: Paragraph 11d now requires ‘strong’ reasons to refuse development in protected areas/Footnote 7 cases. Paragraph 11d now also adds specific ‘key policies’ to consider when having regard to the policies in the NPPF taken as a whole. How these clarifications impact on decision taking in Section 78 appeals will be interesting to monitor.
• Housing delivery test (HDT): Results published in December 2024 (2023 Measurement) will hold LPAs accountable. LPAs that miss delivery targets may face a 20% buffer under paragraph 78(b), putting additional pressure on meeting housing needs.
• The ‘6-year’ requirement from 1st July 2026: a 20% buffer applies in the case of adopted plans which meet less than 80% of the LHN, where plans were examined under previous versions of the Framework.

Developers and land promoters should undertake a review of their LPA’s five-year housing land supply as soon as possible, reflecting the implications of new housing requirements and associated paragraph 78 buffers, to identify whether the tilted balance is now engaged under NPPF11(d).

What this means for local plans

For local plans currently under preparation, timing and compliance are critical to avoid delays. Paragraphs 234-237 are crucial.

• On or before 12 March 2025: Plans which have reached Regulation 19 stage which meet at least 80% of the Local Housing Need, or plans that have already been submitted (at Regulation 22 stage), will be exempt from meeting the policies in the new NPPF and will be examined under the ‘relevant previous version’ of the Framework.
• Implications for emerging Plans which meet less than 80% of the Local Housing Need: If a Plan has been submitted on or before 12 March 2025 and it meets less than 80% of the Local Housing Need, then work on a new Plan is needed to address the shortfall. Plans at Regulation 19 stage which meet less than 80% of the Local Housing Need have 18 months to rectify this and proceed to examination (or 24 months if they need to return to a Regulation 18 preferred options stage to plug the land supply gap).
• A return to strategic planning: The NPPF gives a renewed emphasis on strategic planning, further bolstered by the Government’s Devolution White Paper Power and Partnership: Foundations for Growth.

Developers and land promoters should review the status of the LPA’s local plan in light of these transitional arrangements. Which NPPF a Plan is to be examined under could have significant implications at examination.

Radical changes to Green Belt Policy – introducing the Grey Belt

One of the most significant shifts in the revised NPPF is the treatment of Green Belt land, including the introduction of the much vaunted ‘Grey Belt’. This seems to coincide with the fact that the new housing requirements increase in the South East, an area heavily constrained by Green Belt. To meet these needs a more flexible approach to Green Belt was clearly needed.

• LPA Green Belt Reviews: Green Belt should only be altered where exceptional circumstances exist, fully justified through the preparation of or updating of Local Plans. Paragraph 146 sets out what these exceptional circumstances could be, including where an authority cannot meet its identified need for homes, commercial or other development through other means.
• A hierarchy for Green Belt land release: paragraph 148 prioritises previously developed land in the Green Belt, then Grey Belt, and then other Green Belt locations. There is no more mention of establishing sustainable patterns of development when reviewing Green Belt boundaries.
• Defining Grey Belt: Annex 2 introduces Grey Belt as land that does not ‘strongly contribute’ to Green Belt purposes (paragraphs 143a, b, or d), which may or may not include previously developed land. This will have fundamental implications for both plan-making and decision-taking. F
• Development in the Grey Belt is not ‘inappropriate development’: if a site in the Grey Belt, its development is acceptable under NPPF policy (paragraph 153). This also applies to previously developed land. ‘Very special circumstances’ do not need to be justified.
• Any housing development in the Green Belt (Grey Belt, PDL or otherwise) is subject to the Golden Rules: the Golden Rules apply a site allocated or subject to a planning application. The only exceptions are where consent has already been granted or a site has already been allocated prior to publication of the NPPF.

Golden Rules for Development on Green Belt Land

For developments within the Green Belt, the NPPF introduces three Golden Rules that must be met:

1. Affordable housing: complex provisions which, fundamentally require higher provision of affordable housing (50%, or could be higher if via a Plan Review). It is worth reviewing the Planning Practice Guidance on Viability – also updated on 12th December – which seeks to dismiss those attempting to run a viability case to negotiate reduced affordable housing levels. This is no doubt part of the Government’s trade-off to relaxing Green Belt rules – if you want to build there, we want more.
2. Infrastructure improvements: Enhancing local infrastructure to support development.
3. Green spaces: The provision of or enhancements to green spaces as well as towards a site’s surrounding landscape setting.

Paragraph 158 gives significant weight to proposals meeting these rules, creating opportunities for sustainable, well-planned developments.

Could your Green Belt site now qualify as Grey Belt? Does it make a ‘strong contribution’ to purposes a, b or d? This review may unlock development potential previously overlooked, particularly with development in the Grey Belt now permissible under paragraph 153.

Well-designed places – efficiency over beauty

The revised NPPF shifts its focus from ‘beauty’ to land use efficiency, density, and innovation.

• Maximising land use: Paragraph 130 prioritises higher-density developments and innovative community designs to maximise land efficiency.
• Brownfield redevelopment: Preference is given to brownfield sites, balancing growth with sustainability.
• Design codes: Localised design codes are now mandatory, requiring developments to reflect the local character. While this promotes place-based design, it also poses challenges in consistency and resourcing.
• Sustainability priorities: The NPPF continues to emphasise biodiversity net gain and improved access to green spaces to promote high-quality, resilient design.

Sustainable design and innovative approaches will play a key role in balancing density and community benefits.

Flooding and the sequential test – a revised approach

A notable change in paragraph 175 seeks to simplify the process as to whether a sequential test is required. Where a site-specific flood risk assessment demonstrates no built development (and other development listed in the paragraph) will occur in flood zones, the sequential test is no longer required.

This change potentially removes a significant hurdle for carefully assessed sites, streamlining the process for development proposals in areas prone to flooding. However, there remains an element of planning judgement that will need to be applied in the interpretation and application of this new paragraph. A corresponding update to the Planning Practice Guidance is also expected.

What does this mean for you?

If you are bringing forward land for development, now is the time to reassess your strategy. Key questions to consider include:

• What are your LPA’s housing requirements?
• Can they demonstrate a five-year housing land supply, and is the tilted balance engaged?
• What do the latest Housing Delivery Test results show?
• If your site is within the Green Belt, could it now be classified as Grey Belt?
• Can your development meet the Golden Rules for Green Belt land?
• What transitional arrangements apply to the Local Plan being examined, and what are the timescales?

Don’t wait—identify opportunities now to align your project with the new NPPF framework.

Now is the time to revisit your planning strategies

The revised NPPF introduces both challenges and opportunities for developers, land promoters, and LPAs. Understanding how these changes affect your land or project is essential to staying ahead in this evolving planning environment.

With key deadlines approaching, there’s no time to lose. Contact our expert team today to refine your planning strategy and unlock your site’s full potential.