The new NPPF has landed – what does it mean for SME developers?

James Brokenshire NPPF

Tuesday 24 July 2018 saw the publication of the Revised National Planning Policy Framework (NPPF), six years on from its original release.

Our review of the draft revisions back in March 2018 identified some potentially exciting changes for smaller landowners and developers. Now that the revised NPPF has been published by MHCLG, it appears to have consolidated the Government’s focus on supporting the delivery of homes, but did the proposed changes to enable smaller sites make the final cut?

Small sites – an important contribution to housing delivery?

The draft revision made a clear acknowledgement that small sites can make an important contribution to meeting the housing need of an area by ‘ensuring that at least 20% of the sites identified for housing in their plans are half a hectare or less’.

However, the final version of the revised NPPF appears to have diluted the commitment to bringing forward small sites. Whilst it seems to have widened the net by stating that both ‘small and medium sites’ can make an important contribution to meeting housing requirements in an area, with a consequent increase in site size from half a hectare or less to one hectare or less, it now only requires local authorities to accommodate at least 10% of their housing requirement on sites no larger one hectare. Furthermore, provision is made in the final NPPF for local authorities to avoid this entirely if they can provide strong reasons why this 10% cannot be achieved.

The revised NPPF and windfall sites

The draft revision of the NPPF redefined windfall sites as ‘sites not specifically identified in the development plan’. A positive change from the 2012 NPPF which suggested such sites should normally contain previously developed land. This alteration has made the cut following the revised NPPFs publication which is great news for many of our clients who are looking to develop windfall sites and add to the delivery of housing.

Affordable housing options for smaller sites

As stated in our previous article about the draft revised NPPF, several flexible affordable housing options were proposed. These proposals have remained in the final revision which once again gives landowners greater options when promoting smaller and medium sized sites.

These include:

  1. Discounted market sales housing – This has been included within the affordable housing definition and means that market homes sold at a discount of 20% below local market value can be categorised as affordable housing.
  2. Entry level exception sites – Paragraph 71 now highlights the importance of these sites and ensures that local authorities support the development of such sites. It offers landowners the chance to promote sites which are not already allocated within a plan.
  3. Rural exception sites – Paragraph 77 of the revised NPPF reaffirms what was set out in the draft, that a ‘proportion of market homes’ as opposed to ‘a small number’ as set out in the previous 2012 version can be developed. This important change once again provides further opportunities for smaller and medium sites to secure planning permission.


Whilst the final NPPF waters down some of the provisions in its draft, it still signals a significant opportunity to unlock smaller and medium sites which previously lacked policy support from the 2012 NPPF.

However, it is worth bearing in mind that judgements relating to Braintree and Dartford were still assisting us in unravelling the original NPPF six years after original publication. This next chapter in the planning story will no doubt continue with plenty more unpicking. The only thing we can be sure of is that we will need to wait and see how this revised version is received and interpreted.  

As ever, we will be keeping a close eye on relevant case law and in the meantime, if there is a single message to take on board it would be that early action will be key, whilst everyone is still trying to decide what the implications of these proposed changes actually mean.

If you have a site and would like to understand more about its development potential and formulate a robust planning strategy to help realise this, then contact our team of planning consultants via 

The revised National Planning Policy Framework: Policy Paper