It is nevertheless vitally important in understanding how quickly the changes to policy will come into effect and how likely therefore the government is to achieve its target of 300,000 new homes a year.

For decision-making, the changes are simple.  The previous paragraph 226 is removed and in those authority areas where there was between a four and five year housing land supply, the presumption in favour of sustainable development will be engaged in determined applications for housing.

For plan-making, the proposed arrangements are not so simple.  The new paragraphs 226-228 set out alternative paths which the vast majority of local authorities will need to follow based upon the stage they have reached in the plan-making process at a point in time one month after publication of the final version of the Framework (referred to here as the ‘trigger date’).

• For those who haven’t reached Regulation 19 before the trigger date the position is simple – they will need to use the policies of the replacement Framework and output of the new Standard Method as the basis for determining the housing requirement.

• For those that have reached Regulation 19 stage with a local plan that contains a new housing requirement, the path depends on how close their proposed housing requirement is to the new Standard Method figure for the authority area:

If the housing requirement is relatively close to the output of the proposed new Standard Method (i.e. the increase is not more than 200 dwellings per annum) then they are to continue to examination under the previous Framework with their existing proposed housing requirement; or

If the housing requirement is significantly below the output of the proposed new Standard Method (i.e. more than 200 dwellings per annum) then the authority will need to produce a replacement Regulation 19 local plan to accord with the new policies in the Framework and the new Standard Method before then proceeding to examination within a maximum of 18 months.

• Authorities with a local plan which has been submitted for Examination by the trigger date will continue under the current Framework.  The authority is then obliged to review the recently adopted local plan “at the earliest opportunity” (paragraph 227).

In simple terms, if the local plan is almost there or reasonably close to where government wants the housing requirement to be, then carry on.  If not, the housing requirement will need to be revised.

So, how quickly will the combination of the transitional arrangements and the new Standard Method outcomes turn the super-tanker that is the local plan process around?  An analysis of local plan progress and the new Standard Method by Savills Research reveals that approximately 60 LPAs at currently examination or Reg 19 stage will be able to continue with their emerging local plans. Around 15 LPAs currently at Reg 19 would be required under the transitional arrangements to revise their plans to account for the higher need assessment unless they can submit for examination before the new NPPF is implemented. The 53% of LPAs that are not at examination and or Reg 19 stage, and do not have an up to date Local Plan will be required to take on board the new Standard Method immediately for their new emerging plans.

Savills Research have also analysed data on the status of current local plans, the average time taken between stages of plan preparation, existing housing requirements and the emerging Standard Method outputs.  This analysis reveals that housing requirements are likely to increase, as one would expect, but that a reasonable best-case scenario is that it’s going to take over five years for the total land supply within adopted local plans to reach the golden number of 300,000 new homes a year, based on the current average timescale to adopt a new local plan.

In the short-term, and before the plan-making super-tanker has fully changed course, to deliver 300,000 new homes a year will require a significant quantum of housing to come forward on sites not allocated in a local plan.  It will be down to the application of the other proposed policies in the Framework to deliver a step-change in housing permissions, reversing the trend over the past two and a half years which has seen detailed planning permissions drop to around 220,000 homes per year in March 2024.

Savills view is that the proposed transitional arrangements strike a sound and pragmatic balance between the twin objectives of full local plan coverage and the step-change needed in housing delivery.  It would do more harm than good for authorities to abandon well progressed emerging local plans and to start afresh.  There are also practical realities which would make a faster transition challenging, such as the availability of local plan inspectors at PINS, upon whom a sudden surge in local plan examinations would place an unmanageable amount of pressure.

There is also the small matter of how the local authorities are going to react to the changes.  Given the magnitude of the proposed new Standard Method outputs, there will undoubtedly be a good deal of head scratching taking place within local authorities over the next few weeks.

Local authorities have received a clear message from government  – that housing delivery is a top priority, and they are expected to make the tough decisions needed to support that priority.