Top 10 Planning Reforms You Need to Know in 10 Bullets or less!

In collaboration with our technical specialists, our Planning Lead Annabel Le Lohé has summarised the key planning reforms published in December 2024, with her commentary on implications for the development industry. We’ve selected the 10 core topics to reflect upon and listed under each bullet points of ‘need to know’ information. We like a challenge and distilling planning reform into a short format is certainly that, but we hope this quick guide can serve as your reference point as we bring 2024 to a close and leap forward into 2025. If you want to explore any of the content further, or have a site you’d like to discuss with our planning team, please contact Annabel by annabel.lelohe@brookbanks.com.

For those who want to delve into the nitty gritty, we’ve shared links to comparison version documents of the December 2023 NPPF vs December 2024 NPPF and the July 2024 Consultation NPPF vs December 2024 NPPF here. 

2. What is the Grey Belt?

• It’s been splashed across the headlines and definitions have been mooted in consultations and Ministerial Statements and now we have a clear definition in the published glossary of the NPPF 2024.  

• “‘Grey Belt’ is defined as land in the Green Belt comprising previously developed land and/or any other land that, in either case, does not strongly contribute to any of purposes (a), (b), or (d) in paragraph 143. ‘Grey belt’ excludes land where the application of the policies relating to the areas or assets in footnote 7 (other than Green Belt) would provide a strong reason for refusing or restricting development” 

• In the consultation version, ‘other’ Grey Belt land would have needed to be tested against all of the Green Belt purposes, whereas now the site is not tested for its performance against purposes c) safeguarding the countryside from encroachment and e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. 

• This definition can be considered helpfully broad for promoters/developers as there will be a wide range of sites that may be captured, subject to evidence testing their value against purposes (a) (b) and (d).  

• A critical change on this topic from the July 2024 consultation is that there is explicit confirmation that there will also be no requirement to demonstrate a Very Special Circumstances case for either PDL or Grey Belt sites as these are ‘not inappropriate’  (Footnote. 55 and Paragraph. 155). 

• Additionally, the Previously Developed Land definition has been amended to include hardstanding and reiterates the assumption that the land must have been lawfully developed. 

5. Housing Land Supply and Delivery? 

• The Standard Method once again is firmly in place to calculate Local Housing Need requirement, the calculation method itself has now changed. This is similar to the calculation method consulted on in July 2024 and is a simplified 2 stage approach, although step 2 has been adjusted so do not rely on the previous excel sheet provided by the government and be sure to check the new one here for the latest indicative figures; 
• Take 0.8% of the current housing stock of the area; 

• Apply an uplift, based on a five-year average of the median workplace-based affordability ratio. No adjustment is applied where the ratio is 5 or below. For each 1% the ratio is above 5, the housing stock baseline should be increased by 0.95%. 

• As part of the revision to the Standard Method calculation, the controversial and somewhat arbitrary urban uplift has been removed, seeing the requirements for 13 of the largest cities and urban centres plummet. 

• We have extracted the top 10 most impacted authorities (outside of London) in terms of changes to their LHN per annum, the top 5 increases and top 5 decreases per annum are noted in the below table. Noting the retention of the Duty to Cooperate and emphasis on Strategic Planning, it will be as critical as ever to look at these statistics in combination with neighbouring areas. 

Local Planning Authority/Joint Local Plan Area	Previous Standard Method	New Standard Method	Change
North Yorkshire	1,361	4,077	+2,716
Cornwall	2,707	4,421	+1,713
Wiltshire	1,917	3,525	+1,608
Cheshire East	977	2,461	+1,484
Bolton, Manchester, Rochdale, Oldham, Wigan, Trafford	10,446	11,869	+1,424
Nottingham	1,845	1,247	-598
Sheffield	3,036	2,390	-646
Leicester	2,435	1,557	-877
Coventry	3,081	1,388	-1,694
Birmingham	7,174	4,448	-2,726

• The December 2023 addition of a 4 year supply requirement has been removed and once again LPAs are required to demonstrate a 5 year supply regardless of the age of their Local Plan. 

• There is a new ‘6 year supply’ (20% buffer requirement) as per Paragraph 78(c) effective from 1st July 2026 for LPAs where their adopted housing requirement is less than 80% of the new Standard Method. 

• The implications of the Housing Delivery Test (HDT) have not been altered, although the 2023 HDT results have been released and so it is worth re-checking if there is a need for an Action Plan, Buffer or Presumption in your active areas or not. Some of the key changes in results that will force greater development pressure on these LPAs are summarised in the following table;  

Local Authority	HDT 2022 Implication	HDT 2023 Implication
Barnsley	None	Buffer
Birmingham	None	Buffer
Brighton and Hove	None	Buffer
City of Bristol	Action Plan	Buffer
Canterbury	Buffer	Presumption
Charnwood	Action Plan	Buffer
Cheltenham	None	Presumption
Chorley	None	Presumption
Derby	None	Buffer
Dudley	Action Plan	Presumption
Ealing	Action Plan	Buffer
Elmbridge	Action Plan	Buffer
Folkestone and Hythe	Action plan	Buffer
Halton	None	Buffer
Horsham	None	Presumption
Ipswich	None	Buffer
Islington	None	Buffer
King’s Lynn and West Norfolk	Action plan	Presumption
Lambeth	None	Presumption
Leicester	Buffer	Presumption
Medway	Buffer	Presumption
New Forest	Action plan	Buffer
Newham	Buffer	Presumption
North Norfolk	None	Buffer
Richmond upon Thames	Action plan	Presumption
Sheffield	None	Presumption
Southampton	Buffer	Presumption
Stockport	Action plan	Presumption

 

• There is no longer a policy requirement to bring forward First Homes as part of the affordable mix. The only reference remains in Footnote 31 which confirms that delivery of First Homes can continue where LPAs judge that they meet local need.