Chelgate Local Newsletter – January 2024

NPPF reforms


Welcome to our New Year 2024 issue of Planning ahead


We enter 2024 with some trepidation: the economy is in the doldrums, we have the NPPF reforms and the prospect of a General Election, probably in the autumn. There is too much uncertainty which no one likes.

At Chelgate Local, we finished 2023 on a high note with several new projects started, with more in the pipeline. We have welcomed three new colleagues with three further appointments to announce in the coming months.

This New Year issue of Planning Ahead has a political overview, a review of some of the NPPF reforms, a look at local consultation and how to mobilise the silent majority, how park homes could help with housing supply, and profiles of our new colleagues.


The Economy, NPPF and Elections

Good and bad news for the economy: a further drop in inflation and interest rates held again are the good, but amendments to growth figures showing that the economy is perilously close to recession is the bad.

The outlook is that any recession is likely to be shallow and short-lived, bolstered by the prospect of reductions in interest rates as early as the spring. But the economy is not likely to move ahead until after the General Election, which could be in the spring or could be in the autumn (more likely autumn). Labour thinks it will be the spring, according to The Times (29 Dec). There may be some clarity after the Budget on 6 March, which promises pre-election give-aways such as a reduction in inheritance tax and greater incentives for first time buyers.

At long last the government’s response to the NPPF consultation has been published. Michael Gove MP left it late, choosing to make a speech on the last day of parliamentary business before


Christmas (19 December). He has watered down housing delivery targets and introduced measures to ensure all councils have up to date local plans.

Confirming that housing targets were now officially ‘advisory’, he said that that this had always been the case. This was, however, “not a route to the evasion of responsibilities”. He was confident the government will meet the manifesto pledge of building 300,000 new homes per year.

Michal Gove added: “Local authorities must provide rigorous evidence justifying their departure from assessed housing needs. They must do everything to identify other lands suitable for development. While the planning inspectorate will respect well-made cases, it will not accept undershooting that is not firmly rooted in environmental or other safeguards. This is about sensitive adjustment in housing targets, not their abandonment.

Labour immediately said it would reverse the changes to the NPPF on its first day in government. Building magazine (20 Dec) understands that if councils use the reforms announced to reduce their housebuilding targets, they run the risk of having to make their plans anew.

Joanna Aveley, the government’s chief planner, said: “…there will also be a ‘sister’ document (to the NPPF response) on NDMPs, which will sit above local plans and will create a framework for them, an overarching framework. That work is ongoing. You have to do these things in parallel. There will be two documents.

NPPF Reforms

We are not going to go into huge detail about the NPPF changes as this is the role of planning consultants, but we have picked out some key areas.

Michael Gove MP made his speech about the NPPF consultation response on the day Parliament rose for the Christmas break (19 December), and the government published its long-awaited revision of the NPPF.

As we predicted, some of the proposals have been softened from what was consulted upon at the beginning of last year. But there is still criticism from developers that this will make housebuilding more difficult and will certainly not help the government achieve its 300,000 homes per year manifesto promise – not so good in a year when there is likely to be a General Election.

George Clerk

A key element in the revisions is that there is no requirement on councils to review their green belt boundaries. The new text does not say that this trumps the requirement on a council to meet housing need. It does say that councils can choose to change the boundary where exceptional circumstances exist, but does not detail what those circumstances could be and whether meeting housing need is one of them.

This provision is to address significant pressure from mainly Conservative councils in the south east which are bearing the brunt of development and is impacting on political support.

Another key element is that councils with an up-to-date local plan (less than five years old) need not demonstrate a five-year housing land supply. The 5 and 10 percent buffers have been scrapped, but the 20 per cent buffer applied for subsequent failure to hit targets remains in place.

A further area of contention is the calculation of housing need. The revision confirms that the housing need calculated by the standard method is advisory, as it has always been, apparently. An alternative approach can now be used in exceptional circumstances, but its example reinforces that the exceptional circumstances are just that. The government is also reviewing the ONS data used in the standard methodology, saying it will look at using the 2021 census data, but pointed out that this is not published until 2025.

A selection of other changes include:

  • The test of soundness remains,
  • Previous over-delivery can now be taken into account in plan making,
  • The question of density has been amended to ensure new development is in-keeping with existing communities,
  • Plans require councils to support small sites for community-led housing and self-build,
  • The 35% uplift in the 20 largest towns remains,
  • Specific mention is made of meeting the needs of retirement housing, housing-with-care and care homes,
  • Require for clear detail in a scheme’s design and materials,
  • Promote mansard roofs, and
  • Poorer quality agricultural land should be given preference over ‘best and most versatile’.

The government says this is very much work in progress with a lot more to come later this year, and Labour has said it will scrap the changes the day it comes to power. It is set to be an interesting year!

If you would like to know more information on NPPF reforms o please contact Michael Hardware


Motivating the silent majority

The secretary of state, Michael Gove MP, has said he wants to see local communities involved more in planning policy and planning application decisions. This brought a sharp intake of breath from developers and councillors alike as most communities appear opposed to anything to do with development. This is because only those opposed are motivated enough to participate in consultations, thus giving that perception publicly and with politicians.

Consultation is inherently biased against development and not truly reflective of wider community views. If the whole community was to be involved, if the usually silent majority could be motivated to participate, it is thought that more balanced and helpful opinions would come forward to assist politicians and developers in understanding the true feelings and aspirations of the

Planning market research


Chelgate is currently working with Survation, one of the country’s leading political polling and market research companies, to explore this further. Survation is currently undertaking a survey of all 19,000 councillors in England to find out their views on local consultation: whether they think residents should be more involved in planning, whether they consider the outcomes of developer consultations to be biased, whether they survey their constituents, and whether they think independent research into public opinion locally would be useful.

Any local plan or planning application is accompanied by a plethora of reports and assessments, all completed in detail to exacting standards with evidence bases, and often voluminous. But when it comes to the public consultation and political engagement there is practically nothing, with little or no scientific rigour to how it should be conducted or how the results are analysed.

Applicants and politicians alike make decisions based on their perception of responses and community views, which is not right and can lead to misguided and poor decision making.

Undertaking independent market research will provide unequivocal data representing the true views of the wider community, including those hard-to-reach groups. Understanding real community views provides a basis for proper development-specific consultation instead of relaying on perceptions and hearsay. Applicants, ward councillors and planning committees, as well as the wider communities themselves, would all benefit from such data.

We will be reporting the outcome of the Survation councillor research in the next issue of Forward Planning.


Green belt, rural and protected landscapes

Chelgate Local, the leading public affairs specialist for planners and developers, has further strengthened its team with new public relations and stakeholder engagement expertise for clients working in greenbelt, rural, and protected landscapes.

NPPFJonathan Ray, a Chelgate senior advisor in issue and reputation management, has joined the firm from National Parks UK where he led external engagement, national campaigns, and media relations. He was previously Head of Communications at Oxford University.

Ray has led communications and public affairs for both large scale urban and greenfield infrastructure projects both at home and overseas. This has included new build universities in the Gulf and Asia, advanced research institutes and laboratories, major student housing developments, sports facilities, and public art installations. On behalf of the fifteen National Parks of the UK he oversaw campaigns with a strong focus on sustainability issues, planning and development in rural communities, land management, nature restoration, and management of the rural tourism economy.

Earlier this year the Government revealed plans to extend certain permitted development rights into protected landscapes. The Guardian recently reported comments by the chair of Natural England, stating that development and protection for green spaces and wildlife “should not be seen as opposites”.

Michael Hardware, who leads Chelgate Local said: “Landscape protections are absolutely essential – but well-explained development projects which take vital account of biodiversity and sustainability can make progress, enhancing rural communities by creating homes or economic opportunity. I am very pleased that Jonathan will be working with our clients. Few issues inflame public and political feeling more than development which impacts green spaces. Campaigners are impassioned, and developers without positive engagement strategies and strong, credible narratives in support of nature recovery and the environment can quickly come unstuck.”


Park homes could help solve the housing crisis

Park Homes are becoming increasingly popular. According to the House of Commons Library there are 85,000 park homes on 2,000 licensed sites across the country. Despite their popularity, almost no councils make provision for park homes in their local plans. This despite them being an acceptable form of development in the countryside and outside settlement boundaries, very deliverable, sustainable and affordable. More park homes would contribute to the housing supply numbers and make a valuable contribution to addressing the housing crisis. They will also increase diversity and choice of housing options in the market and provide specialist housing for older people.

Park homes, or mobile homes as they are also known, are modern, bungalow-style detached homes. Occupiers enjoy all the usual amenities, such as gardens, sheds and patios, as well as paying council tax. But they are certainly different in terms of planning; in terms of the local plan process, the planning system itself and the approach to Permitted Development (PD) rights.

Park homes offer an opportunity for independent edge of settlement or even rural living. For example, Warfield Park, one of the largest park home sites in the country, is outside the settlementPark Homes boundary of Bracknell and technically located in the countryside. Park homes count towards the housing supply numbers and help address the housing shortage, including releasing larger family homes back on to the market as people downsize.

In addition, sites for park homes can be developed more quickly than traditional homes and so can contribute to the crisis faster. This is because they are manufactured in factories and then transported to site. Off-site construction also improves build quality and sustainability.

Although park homes are largely open for anyone to buy, such a provision also provides an opportunity for councils to provide specialist housing for older people. This type of housing is rarely included within local plans. The over 55s is now the largest portion of the population but very little is being done to provide them with viable and attractive housing options which they want to move to. This means they tend to remain in their family homes, which itself restricts the market as those family homes are desperately needed by younger families. They, in turn, cannot move, which restricts their smaller homes from coming back on the market for first time buyers.

Councils are missing fundamental opportunities by not including park homes in their local plans. Apart from numbers, they would increase the choice of accommodation in the housing market, and a valuable addition to the housing numbers. They also provide the opportunity for housing for older people, releasing more family homes back onto the market increasing mobility.


New Team Member

Andrew Saywell A senior Cabinet Member in one of the UK’s largest local authorities, Andrew brings more than fifteen years of experience in local government and public engagement. A former member of a planning committee, Andrew has worked on a variety of regeneration and housing projects across the country, working on sites in Surrey, Kent, Essex, and Hertfordshire. He brings a wide experience of community engagement schemes – from running public exhibitions to working on local plan housing allocations.


Local Plan updates

Chelgate Local has updated its dedicated webpage that brings you Local Plan updates for:

Basildon, Brentwood, Castle Point, East Cambridgeshire, Elmbridge, Epping Forest, Harlow, Maidstone, Medway, Mole Valley, Rochford, Runnymede, Sevenoaks, Spelthorne, Thurrock, Uttlesford, Watford, Waverly and many more…


Contact Us

If you would like to know more information on the NPPF or any of the above content please contact us or speak to Michael Hardware