The Government’s Draft 2025 National Planning Policy Framework (NPPF) proposes some of the most notable changes to the planning system in recent years. The draft signals a more ambitious and delivery‑focused approach, with a strong emphasis on boosting housing supply, streamlining processes, and supporting a greater diversity of housing types.
Below, we break down what has changed — and, crucially, where small and medium‑sized housebuilders (SMEs) can find new opportunities.
Key Changes:
A stronger, more growth‑focused agenda
The overall tone of the Draft NPPF is more ambitious, positioning housing delivery as a strategic economic priority. It reinforces the national goal of building 1.5 million homes, embedding growth across the framework.
One of the most notable and important changes is the replacement of the familiar ‘tilted balance’ with a more permanent, specific location based presumption in favour of sustainable development. The presumption is now proposed to be ‘switched on’ as a default position and applies a level of support for developments which are located inside of settlements under policy S4, and the circumstances where this may be acceptable, outside of settlements, under policy S5.
This would be a more permissive and rule based approach to the principle of development, providing greater certainty over what forms of development should and shouldn’t be permitted.
More Planning Opportunities in the Green Belt
The introduction of Grey Belt in the 2024 NPPF update has already been a game changer with 80% of major residential grey belt appeals being allowed – much higher than the typical appeal success rate.
The scope of Grey Belt is proposed to be expanded by removing the restrictions on its application in sensitive areas such as National Landscapes and designated heritage assets.
There is also a wholly new provision allowing housing and mixed-use development on Green Belt land where it is near a well-connected railway station – which has clear potential to open up opportunities in accessible locations which have long been constrained by Green Belt policies.
Housing need calculation and housing mix
The standard method for calculating housing need, as previously set out in guidance is now written directly into the NPPF (Annex D). The standard method will likely result in significant increases to local housing targets, and may present SME housebuilders with opportunities in LPA’s which have previously have lower housing requirements.
SME housebuilders are also supported by the requirement for Local Plans to allocate:
- 10% of sites under 1 ha
- 10% of sites 1–2.5 ha
Local housing needs assessments must also now account for a wider scope of housing needs including social rent, retirement living, care homes, and traveler accommodation, and development will be expected to meet the identified need within the plan period.
Stronger expectations on land supply
LPAs are required to identify sufficient delivery of land based on the standard method, this potentially means looking at smaller sites, which can be delivered more efficiently, than relying solely on the larger strategic allocations.
New ‘Medium Development’ Category
This is significant for SME developers – the draft NPPF proposes a specific ‘medium size’ category for sites delivering 10–49 homes on sites up to 2.5 ha. This is a clear recognition of the impact delivery of such sites can have on overall housing numbers.
This change is intended to try and correct some of the issues SMEs have where proposals of this scale are treated more like major schemes (in terms of application details and timescales) and can get held up; policies DM1 and DM2 now emphasise a more proportionate engagement and validation requirements to try and lower upfront costs and get to swifter validation and determination timescales.
Other benefits of this new category include;
- Standardisation to reduce delays – The draft introduces the use of more standardised conditions, legal agreements, and validation requirements across all LPAs, there by reducing time with the hope of speeding up all relevant stages of the application process.
- BNG exemptions expanded – Sites under 0.2 ha and brownfield sites up to 2.5 ha could now benefit from exemption of the mandatory BNG.
- Wider application of the presumption in favour – Stronger presumption in favour of supporting development within settlements, on previously developed land, reuse of buildings, development which meets unmet need, and transport‑linked development (those sites near rail stations or transport hubs) which may be outside of settlements, but well connected.
Changes to affordable housing
The NPPF consultation also seeks feedback on whether on small or medium sized sites, affordable housing could be provided through a cash in lieu contribution, rather than on-site. SME housebuilders will be aware of the difficulties in providing affordable housing on-site, and if enacted, these changes look to bring in flexibility to delivering affordable housing.
Where Are My Opportunities?
The draft NPPF is good news for small and medium (SME) housebuilders, as there is a clear need for smaller sites to come forward in line with the aims of the draft NPPF. This means that SMEs are well‑positioned to promote and deliver more small and medium scale sites, particularly on edge of settlements, on previously developed land or sites which have good links and access to transport.
- Some of the opportunities the NPPF draft presents to SME housebuilders are;
- Stronger presumption in favour of housing delivery on smaller sites within settlements, or those adjacent to settlements, or well-connected sites next to transport hubs.
- Supports SME delivery in under‑supplied areas.
- Growth in retirement, care (including Looked after Children), and traveler accommodation markets.
- SMEs will be able to deliver growth and build out rates in a more timely way than larger national housebuilders.
- With more standardised and streamlined processes faster decisions should mean that less time and costs need to be attributed to early planning stages.
- Payments in lieu of providing affordable housing on-site could increase viability on smaller schemes.
- BNG exemptions provide more developable area (without the need to set aside land to deliver BNG on site), and more sites become deliverable without costly biodiversity offsetting impacting viability.
Although only a draft consultation at this time, the direction of the NPPF is one of pro housing delivery.
If you have a site which falls within a settlement, or on the edge of a settlement, which has the capacity for up to 50 dwellings, these potential changes to the NPPF have the potential to create real opportunities now the ‘presumption in favour’ is almost automatically applied in these areas.
The positive changes sought to support this ‘medium development’ category have the potential to reduce costs, complexity, speed up decisions and assist with opening up more deliverable land which can be brought forward in a more timely manner.
Here at Edgars we constantly monitor local housing supply position statements and appeal decisions so that we are aware of the current housing land supply positions across our local LPAs. These insights, as well as our knowledge and experience in residential development can support you from initial site feasibility, through to application submission, conditions discharges and completion.
Our experience in and with the local LPAs and our collaborative approach makes us the planning consultancy of choice to help you deliver these much needed, small to medium-sized sites. So, if you have any sites which may now fit the definitions of ‘Medium Development’ then please get in touch – now would be a good time to review opportunities in light of this renewed growth agenda from Government.
Author
- Hannah Wiseman, Associate Director