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February 7, 2024

New developments in land supply targets have raised some issues in need of clarification. Our Senior Associate Town Planning Consultant Adam Bennett, explains more:

“Further to the Government’s public consultation on suggested changes to the National Planning Policy Framework (NPPF) in December 2022 which introduced the premise of a lower bar for Local Planning Authorities (LPAs) to demonstrate four years’ supply of housing which could demonstrate a sufficiently advanced emerging local plan, it was notable that within the September 2023 revision of the NPPF that any changes in this regard were absent.

However, the more fleshed out December 2023 NPPF update saw the formal introduction of Paragraph 226 and its new support which bolsters the position of LPAs which are in the process of preparing a new local plan in terms of lowering the bar against which they need to demonstrate a deliverable supply of housing from five years’ supply to just four years’ supply.

The NPPF states that this four year supply position will apply for the purposes of decision making where LPAs have emerging local plans submitted for examination of where they have been subject to a Regulation 18 or Regulation 19 (Town and Country Planning (Local Planning) (England) Regulations 2012) consultation which included both a policies map and proposed allocations towards meeting housing need, and the housing requirement as set out in strategic policies has become more than five years old in the extant plan.

 The provisions of Paragraph 226 are noted to apply for a period of two years from the publication date of this version of the NPPF (December 19, 2023); coming in to force immediately from the publication of the NPPF.

One of the questions within the planning sector; on which there are differing views, has been whether the four years’ supply test is to be considered against a four, or a five year housing requirement; i.e. whether there is need to show that 100% of this need; i.e. four years’ supply against four years’ of need, or 80% of this need; i.e. four years’ supply against five years’ of need, respectively can be met.

We now understand that DLUHC is due to public new guidance ‘shortly’ to resolve the confusion over the imposition of this new lower four year target and the implications it has particularly for applications and appeals within the system.”

We will keep you updated about developments but in the meantime please contact us to find out more and how your plans or project may be affected.