Agenda item

To update members on the Government’s consultation on proposed reforms to the National Planning Policy Framework and other changes to the planning system which took place between July – September 2024 and to identify potential implications for the Kirklees Local Plan update.

 

 

Contact: Johanna Scrutton Group Leader Planning Policy and Strategy.  Tel: 01484 221000

 

 

Johanna Scrutton, Group Leader Planning Policy and Strategy advised the Panel that consultation on the reforms came out between July to September 2024, and there were 106 questions across the topics within the current National Planning Policy Framework (NPPF).  The Panel was then presented with highlights on some of the key implications for the Local Plan.

 

In summary, the Panel was informed that the government has maintained its focus on having a Local Plan, which must be produced at pace, and must be kept up to date.  For local authorities in the same position as Kirklees, there is a December 2026, submission requirement.  That is in advance of Kirklees’s published local plan development time to scale, which was already ambitious for March 2027.

 

The Panel was informed that a new standard housing method has been introduced, which will increase local housing figures, and if the standard method is introduced within the National Planning Policy, it will increase the figures by thirty percent. There will be a greater focus proposed on strategic planning for those who are part of the core strategy. Originally, similar to the regional spatial strategy, there will be a body for West Yorkshire guiding strategic decisions and local authorities.

 

When requirements are being looked at for land, there is also a need to look at the land take required to deliver economic growth and the numbers will depend on local ambitions. The reforms also introduce Brownfield First and a new land allocation called Grey Belt.

 

The government’s objectives for the planning reforms which is included in their consultation document, is all about delivering specifically 1.5 million homes over the next five years.  There is also a focus on supporting the economy, and within that getting high quality places and affordable homes. The key message is getting Britain building again. There is also a big focus on climate change renewable energy sources and clean energy.

 

The Panel was informed that in terms of setting the scene on how the government plans to achieve these objectives, the initial proposals are that:

 

-     there will be a revised NPPF in December 2024, or early next year.

-     Some of the reforms reversed the changes that were introduced in 2023, and some are additional changes.

-     this is the first step in a number of consultations.

-     Following the finalised NPPF there is an intention to produce the planning and infrastructure bill, and then the publication and consultation on national development management policies. That will be a suite of national policies that all local authorities will be required to follow.

-     There have also been some indications that they may revise the planning policy for waste and for travellers’ site.

-     While there is an indication of some of the jigsaw puzzle pieces the complete picture has not yet been revealed, and therefore there will be an expectation to report back to the panel.

 

The Panel was informed that there are transitional arrangements for other authorities based on where they are in the planned system and their housing requirements. The Panel’s attention was drawn to a set of slides which outlined the current local plan timetable as follows:

 

Timetable and milestones

 

November 2024 - Early engagement phase 1: - issues, vision, what policies you want to see in the Plan. Going out to the community and partners asking views on what they consider to be the challenges and opportunities for Kirklees moving forward.

-         Respond to early engagement and raise awareness

-         Outline any evidence to support local issues and policies (reports or your own consultations)

-         Review existing policies and scope of any new areas

-         Outline any good practice

 

April – May 2025 - Early engagement: phase 2: development levels, draft options

-         Further opportunities to scope whether the development                         strategy supports active communities

 

Sept – Nov 2025 – Draft plan Consultation

-         Get involved in and contribute to public consultation and help raise awareness

 

Sept – Nov 2026 – Publication Draft Consultation

-       Get involved in and contribute to public consultation and help raise awareness

-       Provide supporting evidence when required in a form that can be used in the Examination in Public process

 

March 2027 – Submission to the Secretary of State

-       Where appropriate attend examination and assist the council with supporting the Local Plan proposals

 

The Panel was advised that the government is looking to shorten that time scale, and there will be a meeting with the Planning Inspectorate and the Planning Advisory Service to get some guidance on that.

 

The Panel was informed that in terms of what the NPPF are proposing, it is proposing a new standard method for determining housing requirements. The current method is based on housing projections, and it is an advisory starting point for looking at housing numbers. The new standard method if it comes in is based on housing stock which is adjusted to reflect housing affordability. That standard method would be mandatory and there would be no choice but to follow it if it comes in. The current method does outline some exceptional circumstances, and in the new method it will remove those exceptional circumstances.

 

The Panel was provided with information which outlined the implications for Kirklees of this new standard model, it would increase the housing requirement by thirty percent.  The plan currently sets out a requirement for 1595 dwellings per annum, this figure was uplifted to 1730 for economic growth.  If this new method goes forward, the expectation would be 2000 new homes.  In terms of the role of Strategic Planning, if that is introduced, they will have a role in determining how unmet need is delivered.

 

The good news from the reforms is there is a grow to focus on authorities being able to determine the levels and types of affordable homes, it also includes social rented which is welcomed.  Views are currently being sought through a Strategic Housing Market Survey, which will provide more information to inform those needs.  All members should have received an invitation to a Teams meeting on the 14^th November 2024, where there will be an opportunity to ask the consultants directly about the work they are doing.

 

As a reminder, the Panel was informed that on top of that figure, consideration needs to be given to employment and what will be required to fulfil the growth ambitions for Kirklees as this will affect the land requirements going forward. All this must be considered in the context of the development constraints, for example, typography, environmental designation, flood risk areas and part of the national park and this will influence where can be developed and the types of development.

 

In respect of strategic planning there is a new focus on this, Kirklees currently do ‘duty to cooperate’ with adjoining authorities, and the need to work with neighbouring authorities is part of the examination process. Strategic planning looks at reinforcing that, and one of the benefits could be joined up and considered infrastructure for West Yorkshire.  Although not confirmed, it has been suggested that there may be a white paper on this in the autumn, with consultation followed by legislation.

 

In respect of brownfield, grey belt and green belt, there is a big focus within the reforms about how developments can be brought forward and where it can be developed. The principles are a brownfield first approach and then release low quality grey belt land.  On these grey belt sites there will be implications for ‘golden rules’ where at least 50% must be affordable including social rent, infrastructure and improvements to accessible local green space, and not impact on green belt function.

 

The implication for Kirklees is that 68% of Kirklees is green belt. There is a brownfield register which currently shows there is insufficient capacity to provide future land requirements just solely on brownfield land.  There will also be a need to look at the grey belt sites.  To inform this process, consultants have been commissioned to undertake revised guidance on green belt parcel analysis.  It is hope that the information will be back by February 2025, and that will be used to inform the way forward.

 

The reform also looks at reforming planning fees, looking at proposals to increase the fees for householder applications to meet cost recovery levels.  There are two main elements of that, it is choice whether planning fees are set nationally or at a local level.  The concern regarding setting it at a local level is that there would need to be ongoing evidence to justify those costs and that would need to be kept up to date.  It may also lead to a position where adjoining authorities may have lower fees which may draw development away from Kirklees.  The feeling from development management colleagues is that at the moment the preference is for those reforms to be set at a national level that would ensure consistency.

 

The Panel was informed that there are a raft of other changes to the NPPF, many are around design, with a move away from a district wide design code, to looking more specifically at local design.  There term beautiful has been removed because it was considered to be very subjective, and they have invited further views on design with those reforms.  There is also a focus on supporting economic growth in key sectors particularly within data centres, giga factories and laboratories. Those need to be considered with local priorities and the Inclusive Economic Strategy which is currently being redeveloped and will look at the key sectors that Kirklees wants to pursue.

 

Skills is an important part of that, with the aim to improve skills and access to higher paid jobs within the district.  There is a move towards a vision-led approach to transport, rather than predict and provide, and work is being undertaken with the Transport Strategy Section through their emerging transport strategy to look at how the plan can help deliver that.  Delivering community needs, healthy communities and energy efficiency and work is being undertaken with Public Health and Environmental Strategy colleagues to look at future and new improved policies.

 

The Panel was provided with information which outlined the implications of the reform on the Local Plan process.  Ms Scrutton advised that there would be a need to look at the timetable, and what can realistically be produced within the timescale that is high quality and meets all the requirements to develop a plan which is sound and will go through the examination process. Significant work has been undertaken this year, gathering up-to-date guidance and evidence which will help to shape the strategy and policies.

 

Cllr Graham Turner, Cabinet Member for Finance and Regeneration, thanked Johanna Scrutton and her team for the amount of work they have undertaken on this, stating that it is a significant consultation that has come from the government with proposed changes to the planning system, many of which are well overdue.  Cllr Turner advised that it is worth noting that there will obviously be a wait and see to understand what the final decisions are.  Trying to do a Local Plan alongside this is a huge piece of work and once again the team should be thanked.

 

 

 

In response to the information presented the Panel and attendees made comment and asked questions including some of the following:

 

-     With regard to land banking and a minimal start to a development which leaves it open with no end date.  Does the council have any input to try and address these issues?

-     How will the council deliver on the new mandatory target when it has not been able to meet the target set under the previous local plan, which was actually increased for the delivery of economic ambitions which seemed unrealistic and too ambitious

-     In respect of brownfield and grey belt site, there is no mention of greenfield in that, and that needs to be considered before starting to think about greenbelt.  The purpose of greenbelt is to prevent the merger of settlements, therefore developing grey belt in green belt will actually detract from the purpose of greenbelt, which could have implications in the future for further development in the green belt. What was the council’s response to the consultation on that?

-     How does the council plan to ensure that the local communities have a meaningful voice and role in the process of the development of local plan?

-     What is the council doing to ensure developers will build affordable homes?

-     In reference to data centres and giga factories, in terms of design, what powers will the council have to make sure those are as green as possible?

-     What scope is there within the new plan to improve our strategy for housing for care leavers?

-     In terms of undeveloped allocations, the developers have no incentive to build unless central government addresses this, for example impose a penalty on non-development of land.

-     When the council made is submission to the NPPF consultation, were the views of elected members represented?

-     In terms of the unmet needs and the gaps in housing requirements, is there any information available about the gaps in terms of need and what the numbers might be?  In addition, in terms of social housing, what are the unmet needs there?

-     With regard to the shortages of planners, is there an initiative to train and recruit them locally to actually deliver this plan?

-     Having recently seen appeals allowed for greenbelt, have there been any in Kirklees and can any of these appeals be used as benchmarks for how Kirklees assess greenbelt.

-     With regard to additional changes to the NPPF, post-16 educational places, are there any details on how that may be implemented?

 

RESOLVED:

 

That Johanna Scrutton be thanked for providing an update on the proposed national Planning Policy Framework reforms consultation and other changes to the planning system.