Our Thoughts on the NPPF Consultation – What It Means for Strategic Land

The Government’s current planning reforms – including the Planning and Infrastructure Bill, the English Devolution and Community Empowerment Bill, and the draft revisions to the National Planning Policy Framework (NPPF) – represent one of the most significant shifts in the English planning system in recent years.

For those of us involved in land promotion, these changes are not theoretical. They will directly influence how, when and where sites are brought forward.

The starting point is a system that is already under pressure.

According to Savills’ UK Cross Sector Outlook 2026:

 

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1. The plan-led system is not currently delivering at the scale required.
2. Appeals and speculative applications are filling the gap.

At the same time, the Government remains committed to delivering 1.5 million homes. However, the National Housing Federation, the Home Builders Federation and Savills have all warned that this target will be extremely difficult to meet given planning delays, rising costs, labour shortages and infrastructure constraints (Savills, 2026).

The draft NPPF reinforces the return of mandatory housing targets and strengthens the presumption in favour of sustainable development (notably through proposed amendments to Policies S4 and S5).

For authorities without an up-to-date Local Plan or five-year supply, the pressure to allocate deliverable sites will increase significantly.

In the short term, this creates opportunity for landowners and promoters holding credible strategic sites. Authorities facing housing shortfalls will need robust, well-evidenced options that can realistically come forward.

The current position, where Councils are playing catch-up due to a lack of five-year housing land supply, particularly where the updated standard method requirement has increased significantly gives us the opportunity to maximise the potential of sites that were previously considered to be longer-term opportunities. However, uncertainty remains around land value capture and the scale of developer contributions that may be sought (Savills, 2026). That balance will be crucial to ensuring schemes remain viable and deliverable.

Alongside policy reform, many landowners are facing increasing financial pressure.

Savills (2026) reports that average farmland values have fallen by 0.6%, although results vary widely by region and land grade.

 

Beyond headline values, many farming businesses are experiencing:

Many are asset-rich but cash-poor.

For multi-generational farming families in particular, these pressures can lead to difficult conversations about the future.

In this context, strategic land promotion provides a structured route to unlock value while respecting long-term stewardship. A more streamlined planning system — if implemented effectively — could allow sites to progress more efficiently and with greater certainty.

The proposed move to a 30-month Local Plan process fundamentally changes how and when land promotion needs to happen.

There will be less time to influence strategy and evidence bases.

Early engagement, technical work and proactive Call for Sites submissions will become even more critical.

One of the more contested proposals in the draft NPPF, which will make a feature in our reps to the new NPPF, is the restriction of development outside settlements to locations well-connected to stations within the top 60 Travel to Work Areas (TTWAs).

In principle, supporting rail-connected, sustainable growth makes sense.

However, Lichfields’ 2026 research warns of a potential “cliff edge” effect, where well-connected stations outside the top 60 TTWAs are excluded despite strong sustainability credentials .

This risks concentrating opportunity in already strong markets — particularly in the South East — while limiting growth potential in other regions.

We support the principle of sustainable development around rail infrastructure. However, it should not be constrained by an arbitrary top-60 threshold.

Similarly, suggested minimum densities of 40–50 dwellings per hectare may work well in urban settings, but in rural or edge-of-settlement locations, a more context-sensitive approach may be appropriate.

The Government highlights the delivery of homes on small- to medium-sized sites as one of its “twelve key policy changes”, intending to provide clearer support for the principle of development across a wider range of locations through plan-making.

The draft revised NPPF proposes support for SME housebuilders. This is music to the ears of our in-team housebuilder, Neil McManus of Lanley Homes, but it also opens up more small- to medium-sized sites from the land promotion side of the spectrum.

In reality, small sites are often treated as marginal to housing delivery, with a multitude of policy requirements rendering many applications unviable, particularly in lower-value locations.

The new medium site category for developments of 10–49 homes has been designed specifically for SMEs and would not be subject to information requirements intended for larger developments where these would be disproportionate to the scale of the proposal.

The proposed National Development Management Policy (NDMP) GB8 (“The Golden Rules”) introduces the ability to justify site-specific viability assessments in defined circumstances:

In lower-value areas, or where affordable housing policy would otherwise render schemes unviable, this approach could help unlock development that might not otherwise proceed.

The introduction of Spatial Development Strategies (SDS) aims to provide strategic direction across wider geographies.

Draft NPPF policies PM10 and PM14 suggest that:

SDFs will set housing needs for constituent authorities

Local Plans will not need to revisit matters already addressed at SDS level

In theory, this should simplify plan-making and reduce duplication.

However, SDSs will identify broad growth locations, not allocate individual sites. Detailed site allocation will still sit within Local Plans, meaning proactive engagement at local level remains essential.

If implemented carefully, the clearer division between strategic and local policy could improve efficiency and reduce unnecessary complexity — something the planning system urgently needs.

The proposed removal of footnote 7 from the grey belt definition seems to be positive in broadening consideration of land suitability.

However, environmental constraints — including Green Belt, national landscapes, national parks and flood risk — will still carry significant weight in plan-making and decision-making. They simply will not automatically determine grey belt status.

If Government is serious about closing the housing delivery gap, it cannot rely solely on new towns.

The return of mandatory housing targets increases pressure on authorities to identify such sites. For landowners and promoters prepared to invest early, the next round of Local Plans presents a genuine opportunity.

The direction of travel is clear: a more rules-based, delivery-focused system. Those who engage early, evidence thoroughly and align with emerging spatial strategies will be best placed to benefit.