NPPF consultation responses show widespread support for proposed changes

Sector bodies have set out their responses to the consultation on changes to the National Planning Policy Framework.

The consultation on the changes, proposed just weeks after the election of a Labour government in July, ran until Tuesday of this week.

There was widespread enthusiasm for the proposed changes, which include the reintroduction of mandatory targets, a review of the grey belt and the removal of beauty references, but organisations made a number of suggestions for improvements.

These included greater support for small and medium sized businesses, as well as clearer and more precise language to ensure the NPPF is easily interpreted in planning decisions.

Rico Wojtulewicz, head of policy and market insights at the National Federation of Builders, said its response to the consultation supported the return of mandatory housing targets and the new standard methodology, as well as the removal of beauty references.

“We have recommended that all local plans should use the new methodology with no transition option, plus add a 15% buffer to their five year land supplies for housing and a new addition of commercial,” he said.

“We support their density proposals but would have them more in line with our election manifesto’s ‘community density’ proposal, which encourages well designed tall buildings.”

The NFB have also proposed the addition of a ‘medium sized site’ definition of between 10 and 50 homes, as well as a review of planning conditions to establish a maximum number, which it said would help SMEs.

>>See also: The ins and outs of Labour’s new National Planning Policy Framework

>>See also: A boost for housebuilding or an ill-defined gimmick?: Labour’s ‘grey belt’ plans explained

Wojtulewicz said the NFB believed a separate consultation was needed for benchmarking land and land protections, such as heritage and green belt protections, in order to get proper feedback on “these complex topics”. He added that this should be part of the land use and spatial planning strategy.

The Institution of Civil Engineers said the NPPF should strengthen the duty for local authorities to cooperate across administrative boundaries, ensure the delivery of accessible blue-green infrastructure and reintegrate large onshore wind projects into the nationally significant infrastructure project regime. 

It also said the government needed to implement Schedule 3 of the Flood and Water Management Act as soon as possible, and prioritise climate resilience and adaptation measures within national policy and to ensure the NPPF focuses more heavily on a “nature-first” approach in the design and delivery of infrastructure.

Jeremy Gray, head of policy and public affairs at the Federation of Master Builders, said the organisation’s consultation response had urged the used of “clear and concise language throughout the amendments to the NPPF to avoid misinterpretation and confusion”.

The FMB also encouraged the adoption of minimum targets for SME housing delivery in local plans and asked the government to be “clear in the definition of grey belt land to ensure concise planning decisions”.

RIBA’s response supported “many aspects” to the government’s proposed approach, including the removal of beauty references, measures for better cross-boundary cooperation and the release of grey belt land.

But it said more needed to be done to promote the use of architects, increase local authority planning capacity, reinstating the five-year housing land supply and ensuring affordable housing includes homes for social rent.

“Architects are poised to bring the high-quality design that these reforms call for, but the uncomfortable truth is that most volume homes never pass through an architecture design studio,” said president Muyiwa Oki.

The Chartered Institute of Housing said the government should set out the proportions of different tenures that should make up the overall 1.5 million home target, with a focus on social rented homes.

“Whilst it is positive to reintroduce mandatory targets, we believe that work is needed to agree on a new standard method to determine them,” it said.

“The formula used must appropriately assess needs and consider factors such as homelessness, temporary accommodation, supported housing, and private rental prices.”

It welcomed the grey belt review – but said “care must be taken” to protect natural habitat sites – as well as the ambition that all local authorities should have an up to date local plan and the return of strategic level planning. 

It urged the government to redefine “affordable rent” in terms of “local, lower quartile, wages instead of the current practice of defining it as 80 per cent of market rates”.

The CIH’s response also noted that while planning reforms were “very welcome”, it needed to come alongside “clarity” on the new Affordable Homes Programme, grant levels and a long-term rent settlement.

Pocket Living said the government’s planned changed to the NPPF needed to go further to remove barriers to development on small brownfield sites, in order to encourage SME builders to develop such sites.

“The planned changes within the NPPF are a positive start and we want to work with government to go further with the amendments and introduce an explicit presumption in favour of sustainable development for small sites to provide a vital lifeline to the Small and Medium sized builders, who build out the majority of small sites,” said Paul Rickard, managing director.