The Government is proposing major changes to the National Planning Policy Framework (NPPF) – and for landowners, developers and anyone with a potentially developable plot, some of the proposals could be significant.
For years, many sites have occupied something of a planning grey area.
A piece of land might sit amongst existing houses but fall just outside a defined settlement boundary. A rural plot might be well-related to a village but still be treated as countryside development. A previously refused site may have appeared to have very limited prospects simply because of where a line was drawn on a Local Plan map.
The Government’s proposed new NPPF signals a more rules-based and growth-focused approach to planning, with clearer national policies around where development should be acceptable in principle.
For some sites, that could change the conversation considerably.
At Connor Ferris Architects, we have been reviewing the emerging framework and considering what it could mean for landowners and development opportunities across Essex and the wider South East.
Here are some of the changes we think are particularly worth watching.
First: what is actually changing?
The National Planning Policy Framework sets out the Government’s planning policies for England and is an important material consideration when planning applications are determined.
The Government is proposing a substantial restructuring of the framework, including clearer national decision-making policies and a more rules-based approach intended to create greater certainty about the types of development that should be acceptable in different locations.
The overall direction is strongly focused on housing delivery, economic growth and making the planning system faster and more predictable.
Importantly, however, these policies are currently part of the Government’s proposed new framework. Until the final framework is published, individual proposals may still change.
Nevertheless, they provide a strong indication of the direction in which national planning policy is moving.
1. Rural infilling could become much more interesting
One of the proposals that has particularly caught our attention is Policy S5.
The proposed policy identifies forms of development which may be acceptable outside settlements, including:
“Limited infilling within groups of houses.”
That wording could be significant.
Historically, many rural planning applications have faced difficulty simply because the site sits beyond a defined settlement boundary.
Imagine a row or cluster of existing houses along a rural road.
There may be an obvious gap between properties which, visually and physically, appears to form part of the existing group.
However, if that land falls outside the settlement boundary identified by the Local Plan, securing planning permission for another dwelling can currently be challenging.
The proposed national policy provides much clearer recognition that limited infilling within an existing group of houses can potentially represent an acceptable form of development outside a settlement.
That does not mean every gap between two houses automatically becomes a building plot.
Questions will still need to be considered around matters such as:
- the character of the area;
- the relationship with neighbouring properties;
- landscape impact;
- highways and access;
- ecology;
- flood risk;
- drainage;
- design;
- infrastructure; and
- other site-specific constraints.
There will also inevitably be discussion about what constitutes a “group of houses” and what represents “limited infilling”.
Nevertheless, this is potentially a very important policy direction for rural landowners.
2. Being outside a settlement boundary may no longer be the end of the conversation
The proposed changes go considerably further than infilling alone.
Policy S5 sets out a national approach to development outside settlements and identifies several circumstances where development may potentially be acceptable.
This matters because settlement boundaries have traditionally been a significant constraint for many sites.
A landowner might own a parcel of land immediately adjacent to a village, surrounded by development and close to existing services – but find that it sits just beyond the settlement line.
The proposed approach suggests that the planning assessment should become more nuanced.
Instead of simply asking:
“Is the land inside the settlement boundary?”
the questions may increasingly become:
“What is the site’s actual relationship with the settlement?”
“What existing development surrounds it?”
“How accessible is it?”
“What type of development is proposed?”
“Does it fall within one of the forms of development supported by national policy?”
That could create opportunities for sites which historically struggled under more restrictive local countryside policies.
3. The relationship between national and local planning policy is changing
Another potentially significant proposal appears within Policy PM6.
The Government proposes that development plans should not duplicate, substantively restate or modify national decision-making policies unless another part of the framework directs them to do so.
Why does that matter?
Because one of the Government’s objectives is to reduce the number of overlapping or alternative development-management policies operating across different local authorities.
Rather than each council effectively recreating national planning policy through its own local policies, the intention is to establish clearer national rules while allowing local plans to concentrate on genuinely local and site-specific matters.
For applicants and landowners, the intended result is a more consistent and predictable planning system.
It does not mean that Local Plans become irrelevant.
Far from it.
Local planning authorities will continue to have an extremely important role in determining where development should occur and addressing matters specific to their areas.
However, the balance between national rules and additional local development-management policies could change.
4. Previously refused rural sites may deserve another look
This is where the changes become particularly interesting from a practical perspective.
If you have previously been refused planning permission because your land was considered to be:
“outside the defined settlement boundary”
or represented:
“development within the countryside”
it may be worth reviewing the reasoning behind that decision.
A previous refusal does not suddenly become irrelevant.
And we certainly would not recommend simply resubmitting the same application because national policy is changing.
But planning decisions are made within a policy context – and that context evolves.
If the fundamental objection to a proposal was its location outside a settlement, and national policy becomes more permissive towards certain forms of development in those locations, the planning balance may need to be considered again.
The appropriate approach would normally be to review:
- the previous application;
- reasons for refusal;
- appeal decisions, if applicable;
- current Local Plan policies;
- emerging national policy;
- physical characteristics of the site;
- relationship with surrounding houses;
- accessibility;
- design opportunities; and
- any technical constraints.
From there, it may be possible to establish whether there is a credible new planning strategy.
5. Sites amongst existing houses could be particularly interesting
One category we think landowners should pay particular attention to is land sitting within or between existing groups of houses.
That might include:
- gaps between existing homes;
- large side gardens;
- parts of unusually large residential plots;
- land between established properties;
- small paddocks amongst existing development;
- former garden land;
- underused parcels of land; or
- small sites along existing rural roads.
The critical issue will not simply be ownership or size.
The physical relationship between the proposed plot and the existing group of houses is likely to be extremely important.
For example, a small gap within an established cluster of houses could present a very different planning proposition from an isolated field some distance away.
This is why development potential needs to be assessed on a site-by-site basis.
6. Well-connected locations receive stronger support
The proposed NPPF also places significant emphasis on sustainable and well-connected locations.
Of particular interest is support for suitable housing and mixed-use development within reasonable walking distance of qualifying well-connected railway stations.
The proposed policy considers factors including whether development is physically well-related to the station or the settlement containing it and whether the scale of development can be accommodated by available or proposed infrastructure.
This could potentially create opportunities for land that sits outside an existing settlement but benefits from excellent transport connectivity.
Again, this is not a blanket permission to develop land around every railway station.
But proximity to good public transport could become an increasingly important factor when considering the development potential of a site.
7. Green Belt and Grey Belt remain major areas to watch
Green Belt planning policy has already undergone substantial change, particularly following the introduction of the concept of Grey Belt.
The Government reports that, following the December 2024 changes, a significant proportion of major residential appeals involving Grey Belt land have subsequently been allowed.
The proposed new framework continues to develop the approach to Green Belt decision-making.
For landowners, the important point is that:
“Green Belt” does not necessarily answer the entire development question.
A proper assessment may need to establish:
- whether the land is Green Belt;
- whether it could fall within the definition of Grey Belt;
- which Green Belt purposes the land contributes towards;
- whether the proposal constitutes inappropriate development;
- whether another national policy exception applies;
- how the land relates to existing development; and
- what other planning constraints affect the site.
Green Belt remains an important planning designation and should never be treated lightly.
But some sites which might historically have been dismissed simply because of their Green Belt designation may warrant more detailed assessment.
8. Brownfield land remains a major priority
Previously developed – or brownfield – land continues to feature strongly within the Government’s planning reforms.
For landowners, this can include more than large former industrial sites.
Potential opportunities could arise from:
- redundant commercial premises;
- former workshops;
- underused employment land;
- redundant buildings;
- previously developed rural sites;
- old yards;
- existing developed plots capable of intensification; and
- sites where redevelopment could make more efficient use of the land.
If a site already contains development but is substantially underused, the planning opportunity may be considerably greater than simply refurbishing the existing building.
Sometimes the right question is not:
“What can we do with this building?”
but:
“What is the best use of this site?”
9. Housing need remains an important consideration
The Government’s proposed framework continues to place significant emphasis on delivering the homes communities need.
Where there is an evidenced need for housing, that need can form an important part of the planning balance.
This doesn’t override matters such as unacceptable landscape impact, poor design, highways safety or environmental constraints.
However, the wider planning context matters.
The prospects for a site cannot always be assessed in isolation from:
- local housing need;
- housing supply;
- delivery performance;
- emerging Local Plans;
- national policy; and
- the sustainability of the location.
That is another reason why planning advice obtained several years ago may not necessarily provide the complete answer today.
10. Sustainability and climate-responsive design are becoming increasingly important
The proposed framework also strengthens the relationship between planning and climate change.
The draft policies address matters including:
- reducing energy consumption;
- renewable and low-carbon energy;
- sustainable transport;
- reuse of existing structures and materials;
- climate adaptation;
- overheating;
- sustainable drainage;
- green infrastructure; and
- the transition towards net zero.
The proposed framework also continues to recognise the importance of outstanding and innovative design.
For CFA, this is particularly interesting.
Sustainability should not simply be treated as a technical exercise undertaken at the end of the design process.
For the right project, considerations around orientation, building form, energy demand, materials, landscape, renewable technologies and climate resilience can form part of the architectural concept from the outset.
Importantly, however, sustainable credentials do not automatically make otherwise unacceptable development acceptable.
They form part of the wider planning balance and need to be considered alongside the location, principle of development and other planning considerations.
11. Appropriate development within settlements is being strongly encouraged
The Government is also proposing a more positive approach towards suitably located development within settlements.
This could be particularly relevant to:
- infill sites;
- backland opportunities;
- underused plots;
- redevelopment;
- subdivision of larger sites;
- residential intensification; and
- mixed-use development.
For homeowners with unusually large gardens or land alongside their property, it may therefore be worth establishing whether there is development potential that has never previously been explored.
The existence of land does not necessarily mean it can accommodate another dwelling.
But neither should potentially valuable development land simply be assumed to be “part of the garden” without considering the planning position.
12. The planning system is intended to become faster and more predictable
The reforms are about more than where development can happen.
The Government also wants the planning system itself to operate more efficiently.
Proposals include a more rules-based framework, streamlined local requirements, clearer national decision-making policies, more consistent use of conditions and obligations, and measures intended to prevent unnecessary delays.
The Government’s stated objective is to make planning faster, simpler and more certain, particularly where development is considered appropriate in principle.
Whether this produces noticeably faster decisions in practice will depend on implementation and resources within individual planning authorities.
But the policy direction is clear.
What does all of this mean for landowners?
The most important message is not:
“The planning rules have changed, so you can now build on your land.”
Planning is considerably more complicated than that.
The more useful message is:
Land which previously appeared difficult to develop may deserve to be looked at again.
That is particularly true if your land:
- sits outside but close to a settlement boundary;
- forms a gap within an existing group of houses;
- is surrounded or partly surrounded by residential development;
- sits close to a well-connected railway station;
- comprises previously developed land;
- is within the Green Belt and may warrant a Grey Belt assessment;
- has previously been refused because of countryside or settlement-boundary policies;
- benefits from good access to services and facilities; or
- simply hasn’t been professionally assessed for several years.
What constitutes a “group of houses”?
This is likely to become one of the particularly interesting questions arising from the proposed rural infill policy.
The draft wording refers to “limited infilling within groups of houses”, but every site will have its own physical context.
A group could potentially be influenced by factors such as:
- the number and proximity of existing dwellings;
- spacing between properties;
- whether the buildings read visually as a cluster;
- the relationship with the road;
- surrounding landscape;
- existing built form; and
- whether development would genuinely fill a gap or instead extend development further into open countryside.
We expect the interpretation of this policy to develop through planning decisions and appeals.
For that reason, simply owning land between two points on a map is not enough.
Understanding the physical context of the site will be crucial.
Should you revisit a previously refused planning application?
Potentially, yes.
But don’t simply resubmit it.
A previous refusal provides valuable information about what the local planning authority considered unacceptable.
The better strategy is to establish:
What exactly caused the refusal?
Then ask:
Has national policy changed the significance of that issue?
And finally:
Could a redesigned proposal address the remaining concerns?
Sometimes the answer will still be no.
In other cases, a different planning strategy, revised scale of development or fundamentally different architectural response could create a more credible proposition.
Our view
We see the proposed NPPF as an important shift in the direction of national planning policy.
The move towards clearer national rules, recognition of certain forms of development outside settlements, continued evolution of Green Belt policy and stronger emphasis on delivering housing could create opportunities for sites that historically sat in a difficult planning position.
But opportunity does not equal permission.
The strongest applications will still be those that combine a sound planning case with excellent architectural design and a detailed understanding of the site’s constraints.
For landowners, therefore, the first step shouldn’t necessarily be a planning application.
It should be establishing whether there is a credible development opportunity in the first place.
Could Your Land Have Development Potential?
At Connor Ferris Architects, we work with homeowners, landowners and developers across Essex, Kent and the wider South East to assess the architectural and planning potential of land.
If you own:
a large garden, a gap between existing houses, land on the edge of a village, a rural plot, previously developed land, Green Belt land or a site that has previously been refused planning permission, the emerging changes to national planning policy may make this an appropriate time to reassess its potential.
Our Land & Development Appraisal service can review:
- the site’s planning history;
- national and local planning policy;
- settlement boundaries;
- surrounding development;
- Green Belt and potential Grey Belt considerations;
- relevant site constraints;
- access and connectivity;
- potential development scenarios; and
- the most appropriate planning strategy.
Where there appears to be a credible opportunity, we can then advise whether the next step should be feasibility work, pre-application engagement, further specialist assessment or preparation of a planning application.
This article provides general information on emerging national planning policy and should not be treated as site-specific planning advice. The proposed NPPF policies discussed above remain subject to the Government’s consultation/finalisation process and may change before final publication.
