The new draft NPPF introduces a new Chapter 11 - "Making effective use of land".
This chapter sets out a range of requirements that policies should include in order to promote the effective use of land. It is clearly linked to finding more ways to increase the delivery of homes through brownfield land and it states that
"Strategic plans should contain a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously developed or brownfield land".
This requirement is consistent with the stated aims of increasing housing and the protection of the greenbelt and will mean that local authorities will have to demonstrate that all of the land in their area has been properly assessed when their policies are considered.
The chapter includes the expected proposal to support higher density housing where required. In addition to these requirement, the chapter sets some other positive policy requirements to support the principle of making effective use of land. These include both greenfield and brownfield land and are aimed at ensuring that the right development takes place at the most suitable locations. They include
- keeping the allocated use of land under review to see if an alternative use would be better where development does not come forward;
- giving substantial weight to the value of using brownfield land;
- promote and support the development of under-utilised land and buildings (especially to meet identified housing need where land supply is constrained);
- recognising what roles undeveloped land could play;
- encouraging mixed uses and habitat creation to achieve net environmental gains;
- taking a pro-active role in identifying and bringing forward land suitable for public needs (such as sites in public ownership); and
- Making more effective use of land already providing community services.
Whilst these proposals mention both brownfield and greenfield land, it seems that there is a real focus on ensuring that all brownfield space is considered as the first option to minimise the need for greenfield development.
Achieving appropriate densities -
The draft NPPF includes a changed approach to determining appropriate densities for new development. The existing NPPF requires authorities to set out their own approach to housing density to reflect local circumstances. The revised NPPF proposes that plans and decisions should support development that makes efficient use of land, taking into account issues such as:
- identified housing need;
- market conditions and viability;
- availability and capacity of infrastructure;
- the desirability of maintaining existing character compared to regeneration/change; and
- the importance of well-designed attractive places.
It is identified that where there is either an existing or anticipated shortage of housing both policies and decisions should avoid homes being built in low densities to ensure optimal use of land. Where there is such a shortage:
- plans should contain policies to optimise the use of land in the area, including minimum densities for areas where there is good public transport. It is expected that these will seek an uplift on existing densities in those areas, unless there are strong reasons otherwise. These policies will be tested robustly at examination;
- use of minimum density standards should be considered for other areas, with the possibility of a range of standards linked to the accessibility of the areas covered by the plan;
- applications should be refused where they fail to make efficient use of land taking into account the policies in the framework and when considering applications for housing, authorities should take a flexible approach in applying policies or guidance relating to daylight and sunlight.
These proposals place great importance of first identifying the objectively assed need in the area and the wider goal of achieving optimum efficiency of land use. Development at higher densities will inevitably provide less on site infrastructure and therefore place greater pressure on existing infrastructure. It seems that the assessment of existing capacity and finding solutions to make these developments feasible will be critical if higher density schemes are to be successful. The effective use of planning obligations and CIL will be essential although higher density schemes could in theory create the higher revenues needed to provide and or improve the necessary infrastructure.
As with the policy requirements being introduced to ensure effective use of land, the proposals for greater density could also been seen as further protection mechanism for the green belt.