Local Plan Review 2026-2043 Issues and Options Consultation
National Planning Context
- Significant changes to national planning policy occurred with the publication of an amended National Planning Policy Framework (NPPF) in December 2024 and updated National Planning Practice Guidance (NPPG) in February 2025.
- The most significant changes related to the following issues:
- Local Housing Need
- Green Belt policy
Local Housing Need
- Changes to the standard methodology for calculating housing need with a departure from using household projections as the starting point and a significant rise in how the affordability ratio is applied. As detailed in a later chapter, this has significantly increased (by 63%) the Borough’s housing need.
- Given the changes to the methodology which are no longer based on household projections, it is perhaps a misnomer to refer to the figure as local need, but rather a housing number that a local planning authority is now expected to meet.
Green Belt Policy
- Perhaps the biggest change to Green Belt since it was first a widespread feature of the planning system in the 1950’s is the introduction of the concept of Grey Belt. Whilst it was previously clear about whether a site was in the Green Belt or not (it was either allocated on the policies map as such or not), now the approach to whether a site is considered to be Grey belt or not includes an opinion-based assessment.
- Grey Belt sites are areas within the Green Belt that do not strongly perform against 3[1] of the 5 purposes of why land is designated as Green Belt. It should be noted that even if a site/area of the Borough is considered to be Grey Belt, it does not necessarily follow that the site should be allocated (or permission granted on a planning application[2]) as other key tests would need to be met. In particular, whether the site is in a sustainable location.
- Whilst national planning has always allowed housing need to be taken into account when considering proposals for development in the Green Belt[3], the NPPF now allows, in certain circumstances, housing need to ‘trump’ Green Belt policy.
Future Changes to National Planning Policy
- It is anticipated that further changes at the national and regional level are expected over the coming months. In preparation for this the following has occurred:
- The Planning and Infrastructure Bill received Royal Assent on 18th December 2025 and is now therefore an Act, albeit regulations will be required to bring into force many of its provisions.
- Draft revisions to the NPPF were published on the 16th December 2025. The consultation on this draft remains open until 10th March 2026 and an amended NPPF is expected to be published thereafter.
- Rollout of the new plan-making system - draft guidance on how the new plan-making arrangements are expected to operate[4] was published on 27th November 2025 alongside a Written Ministerial Statement (WMS).
Implications of the Changes to National Planning Policy
- The draft NPPF includes a set of national development management polices (which had been expected) and these feature in the document as ‘National Decision-Making Policies (NDMP).’ This will have implications for the nature and scope of policies that can be included in local plans since it is indicated that in preparing plans, Council’s should not “duplicate, substantially restate or modify the content of national decision-making policies”[5].
- The new plan-making system will put into practice a new 30-month process for producing a local plan. Any plans being produced under the current system (now being referred to as the ‘legacy’ system)[6] will need to be in accordance with the 2024 NPPF, and will need to be submitted for examination by the end of December 2026.
- For decision making, the new policies in the NPPF must be taken into account from the date of its publication, i.e. when the draft version is finalised after consultation.
- The draft implementation provisions[7] include the following:
“Development plan policies which are in any way inconsistent with the national decision-making policies in this Framework should be given very limited weight, except where they have been examined and adopted against this Framework. Other development plan policies should not be given reduced weight simply because they were adopted prior to the publication of this Framework.”
- This would mean that if policies in plans pursued under the 2024 NPPF would effectively be obsolete on adoption if they were inconsistent with the new NDMPs.
[1] Checking the unrestricted sprawl of large urban areas, prevent neighbouring towns merging into one another and preserving the setting and special character of historic towns. These 3 purposes specifically exclude villages.
[2] The NPPF changes in relation to Grey Belt and planning applications creates a set of circumstances where Green Belt policy would not be an appropriate reason for refusal in relation to proposed development in the Green Belt.
[3] Either through demonstrating ‘exceptional circumstances’ to change Green Belt boundaries (in a local plan), or via ‘very special circumstances’ when considering planning applications for proposals on Green Belt sites.
[4] It states: “We have published this guidance now so that LPAs can see the direction of travel for the new plan making system. We will review the guidance and make any necessary revisions and updates as the new system is implemented, and related regulations and policy are confirmed.”
[5] Proposed policy PM6 (c).
[6] Based on the Planning & Compulsory Purchase Act 2004.
[7] Annex A, paragraph 2.
