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CPA Consultation Responses
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CPA responds to as many consultations as we can that are relevant to the planning system or natural environment.
These are mainly to MHCLG (the Ministry of Housing, Communities & Local Government), and to DEFRA (Department for Farming and Rural Affairs). We also make submissions to Inquiries and Committees at the House of Commons and House of Lords.
Responding to consultations can be time consuming and onerous, but please let us know if you are aware of a new national consultation.
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(Image by KamranAydinov on Freepik)
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CPA Submission to Environmental Audit Committee: Flood Resilience - January 2025
CPA submitted a response to the UK Parliament Environmental Audit Committee who asked for evidence on flood resilience.
Land use strategies which cover all the ecosystem and natural capital services provided in an area are an essential tool for ensuring that climate mitigation, future food security and nature’s recovery are all considered as an equal priority alongside growth and development.
We said that the starting emphasis should be on natural flood management techniques, such as wetland restoration, river re-wiggling, pond creation and tree planting. Peatland and wetland restoration, for example, provides many benefits in addition to supporting huge levels of water capture and storage (including carbon sequestration and biodiversity gains).
Land use strategies which cover all the ecosystem and natural capital services provided in an area are an essential tool for ensuring that climate mitigation, future food security and nature’s recovery are all considered as an equal priority alongside growth and development.
We said that the starting emphasis should be on natural flood management techniques, such as wetland restoration, river re-wiggling, pond creation and tree planting. Peatland and wetland restoration, for example, provides many benefits in addition to supporting huge levels of water capture and storage (including carbon sequestration and biodiversity gains).
CPA Submission to MHCLG: Working Paper on Planning Committees - January 2025
CPA responded to a working paper from MHCLG, rather than a formal consultation, on options to "change planning committees in England that would support the plan-led system, including the introduction of a national scheme of delegation, a new system of targeted committees for strategic development, and mandatory training for committee members."
We said there is a need not only for a scheme of delegation but an explicit clarification that the policies set out in the National Planning Policy Framework (NPPF) and district local plans must be adhered to. One of the main reasons for delays, difficulties and disagreements is that organisations ‘cherry-pick’ those policies. Both developers and communities must have certainty that, if applications do not comply with those policies, they will not be accepted by either officers or planning committees for consideration. The concept of ‘departure from the development plan’ must become a thing of the past because communities have invariably not been consulted on those deviations. Communities should be able to call-in any application to committee or the Secretary of State if they can demonstrate that it is not compliant with the NPPF, Local Plan policies or any other relevant policy.
It should also be recognised that it is a fallacy that lots of planning applications are turned down by Councillors at committees. The officers are always rigorous in reminding Councillors that if they refuse an application that is in accordance with the development plan the refusal will be overturned at appeal, and that they will lose on costs. It is really developer propaganda that this is a major issue.
We said there is a need not only for a scheme of delegation but an explicit clarification that the policies set out in the National Planning Policy Framework (NPPF) and district local plans must be adhered to. One of the main reasons for delays, difficulties and disagreements is that organisations ‘cherry-pick’ those policies. Both developers and communities must have certainty that, if applications do not comply with those policies, they will not be accepted by either officers or planning committees for consideration. The concept of ‘departure from the development plan’ must become a thing of the past because communities have invariably not been consulted on those deviations. Communities should be able to call-in any application to committee or the Secretary of State if they can demonstrate that it is not compliant with the NPPF, Local Plan policies or any other relevant policy.
It should also be recognised that it is a fallacy that lots of planning applications are turned down by Councillors at committees. The officers are always rigorous in reminding Councillors that if they refuse an application that is in accordance with the development plan the refusal will be overturned at appeal, and that they will lose on costs. It is really developer propaganda that this is a major issue.
Link: CPA Submission
CPA Submission to MHCLG: Working Paper on Development and Nature Recovery - December 2024
CPA responded to a working paper from MHCLG, rather than a formal consultation, on a new approach which proposes "using funding from development to deliver environmental improvements, and moves more responsibility for these improvements onto the state rather than developers. The aim of this approach is to free up and accelerate development while ensuring better environmental outcomes."
We said that the starting point should not be that nature is in the way of development. Nature is not only essential for our existence, but brings many benefits, too, as set out in the Dasgupta Review. There is a risk with the proposals in the working paper that developers will manipulate the system to use it as a ‘pay to harm’ approach to obtaining consent for inappropriate projects in the wrong place.
We said that the starting point should not be that nature is in the way of development. Nature is not only essential for our existence, but brings many benefits, too, as set out in the Dasgupta Review. There is a risk with the proposals in the working paper that developers will manipulate the system to use it as a ‘pay to harm’ approach to obtaining consent for inappropriate projects in the wrong place.
Link: CPA Submission
CPA Submission to Environmental Audit Committee: Environmental Sustainability and Housing Growth - December 2024
CPA submission on 3rd December 2024 to the UK Parliament Environmental Audit Committee who asked for evidence on the Government's proposed new NPPF.
Our submission states that CPA does not believe that the revised NPPF will support the protection and enhancement of the environment. The approach taken by the Government to setting housing policy risk placing growth and targets above all other factors, at great risk to the natural environment. The environment is barely an afterthought and, instead of setting policy that aims to meet the need for homes (as opposed to demand) while also protecting the environment, Government has placed the onus squarely on meeting un-evidenced housing targets that do not solve the housing crisis.
Our assertion, in a paper due to be published soon, is that we can have homes for everyone (people and nature included) long before we have to tap into our precious green spaces. This can be done by insisting on a greenfield last approach in which greenfield can only be built on once a council has demonstrated that it has renovated empty homes, repurposed commercial buildings, encouraged letting of rooms in houses, reused all brownfield land, maximised density and seen the majority of planning permissions built out. Clearly this will need support and financing from the Government.
We note that, while Labour’s manifesto pledge was for 1.5m homes, its proposed Standard Method results in 1.85m homes and that, in addition to this, there will be new towns of 10,000 homes or more. As far as we are aware, there has been no Sustainability Appraisal for the proposed NPPF, the Standard Method, for the new towns, nor for the cumulative impact of these initiatives.
Our submission states that CPA does not believe that the revised NPPF will support the protection and enhancement of the environment. The approach taken by the Government to setting housing policy risk placing growth and targets above all other factors, at great risk to the natural environment. The environment is barely an afterthought and, instead of setting policy that aims to meet the need for homes (as opposed to demand) while also protecting the environment, Government has placed the onus squarely on meeting un-evidenced housing targets that do not solve the housing crisis.
Our assertion, in a paper due to be published soon, is that we can have homes for everyone (people and nature included) long before we have to tap into our precious green spaces. This can be done by insisting on a greenfield last approach in which greenfield can only be built on once a council has demonstrated that it has renovated empty homes, repurposed commercial buildings, encouraged letting of rooms in houses, reused all brownfield land, maximised density and seen the majority of planning permissions built out. Clearly this will need support and financing from the Government.
We note that, while Labour’s manifesto pledge was for 1.5m homes, its proposed Standard Method results in 1.85m homes and that, in addition to this, there will be new towns of 10,000 homes or more. As far as we are aware, there has been no Sustainability Appraisal for the proposed NPPF, the Standard Method, for the new towns, nor for the cumulative impact of these initiatives.
CPA Submission to New Towns Taskforce: Call for Evidence - November 2024
CPA submission on 13 November 2024 to the New Towns Taskforce led by Sir Michael Lyons. The consultation was a "call for sites" for potential new settlements of over 10,000 dwellings. But that rang so many alarm bells that we felt compelled to write. We see this as approaching the selection of new towns from the wrong direction. Surely start with a national land-use strategy to work out where you need development?
Link: CPA Submission
CPA Submission to Office for Environmental Protection - September 2024
The Office for Environmental Protection (The OEP) was established by the Environment Act 2021 to protect and improve the environment. They do this by holding government and other public authorities to account against their environmental responsibilities and the law. This consultation was about an update to their starting strategy.
Link: CPA Submission
CPA Submission to MHCLG: Proposed Reforms to the NPPF - September 2024
CPA submission on 6th September 2024 to Government proposals to change the National Planning Policy Framework and to introduce a new mandatory standard methodology for calculating housing targets.
Link: CPA Submission
CPA Submission to DLUHC: Street Vote Development Orders - February 2024
CPA submission on 1st February 2024 on government plans for Street vote development orders, described as "an innovative new tool that will give residents the ability to propose development on their street and, subject to the proposal meeting certain requirements, vote on whether that development should be given planning permission."
Link: CPA Submission
CPA Submission to Competition and Markets Authority: The Housing Market - December 2023
The CMA has published the initial findings of its housebuilding market study, and is suggesting far-reaching, community-excluding, changes to the planning system.
Obviously, no-one would disagree with its starting premise that everyone needs a place to live. But this study has blundered straight into the elephant trap and assumed that the market (developers) can deliver all housing need. The seemingly dramatic under-delivery against housing targets that the report cites is because the market will not meet social housing needs. It never has.
There are two studies, and a series of detailed questions in the reports themselves.
Obviously, no-one would disagree with its starting premise that everyone needs a place to live. But this study has blundered straight into the elephant trap and assumed that the market (developers) can deliver all housing need. The seemingly dramatic under-delivery against housing targets that the report cites is because the market will not meet social housing needs. It never has.
There are two studies, and a series of detailed questions in the reports themselves.
Link: CPA Submission
CPA Submission to DLUHC: Reforms to Plan-making - September 2023
CPA submission on 6th September 2023 to Government proposals to make plans simpler, faster to prepare and more accessible. We agree that local plans do need standardising, digitising and simplifying, and communities do need to be engaged better and earlier, so the proposals set out in this consultation are a positive step forward. We propose a Community Engagement soundness test for Inspectors to evaluate at examination stage.
Link: CPA Submission
CPA Submission to DLUHC: Reforms to Permitted Development Rights - September 2023
CPA submission on 6th September 2023 on plans to extend PD rights. In general we are in principle very supportive of the need to re-use existing buildings for housing and, in the countryside, also for commercial purposes. But Permitted Development powers are already extremely wide ranging - in some cases far too wide ranging already and we explain our concerns.
Link: CPA Submission
CPA Submission to DEFRA: Protecting Hedgerows - July 2023
On July 12th 2023 CPA made a submission to DEFRA in reponse to its consultation on protecting hedgerows
Link: CPA Submission
CPA Submission to National Highways: RIS3 Shaping the Future of England's Strategic Roads - June 2023
CPA made a submission on 21st June 2023 to the proposals made in National Highways’ Initial - Report Shaping the future of England's strategic roads. The report outlines National Highways’:
- view on the current state of the strategic road network (SRN)
- potential future needs
- proposed priorities for the next road period (RP3), covering the financial years 2025-26 to 2029-30
Link to National Highway's Consultation: shaping-the-future-of-englands-strategic-roads
Link: CPA Response
Link: CPA Response
CPA Submission: Strategy and Policy Statement for Energy Policy - June 2023
In June 2023 the government held a consultation on its policy for the delivery of energy infrastructure and how to provide the legal framework for planning decisions. The link to the consultation page and the accompanying policy statements, the link is here:
Link: CPA Submission
CPA Submission to Commons Levelling-Up Committee: Planning Reform - March 2023
CPA submission stating that we support in general the aims of the Levelling Up and Regeneration Bill (LURB), for a genuinely plan-led system, stronger voice for communities, community infrastructure by developers, clear design standards that reflect community views, enhanced protections for our precious environmental and heritage assets.
CPA Submission: Reforms to National Planning Policy - February 2023
CPA submission to proposals in the Levelling Up and Regeneration Bill (LURB) on Reforms to National Planning Policy, where we suggested a better method of calculating housing "need, and a much more sensible Standard Method with constraints included at the start, and using uptodate household and affordability projections.
Link: CPA submission
CPA Submission: Proposals to reform the Human Rights Act - March 2022
Article 6 of the Human Rights Act protects our rights to a fair and public hearing. This means that if a public authority is making a decision that has a impact upon your civil rights or obligations (in this context, your civil rights and obligations are those recognised in areas of UK law such as property law, planning law, family law, contract law and employment law) you have a right to a fair and public hearing, which is held within a reasonable time, giving you all the relevant information, allows you representation and is followed by a public decision. In addition, you also have the right to an explanation about how the decision-making authority reached its decision.
CPA Submission to National Highways: RIS3 Route Strategies Consultation - December 2021
In December 2021, CPA submitted a response to National Highways consultation on Road Investment Strategies 3.
We said that Government should stop building new roads, as the Austrian government has recently announced, but that in the event that the RIS3 programme does go ahead then there need to be changes to the way options are evaluated.
We would like alternatives to be compared directly with new roads, and we believe that externalities such as illness from air and noise pollution, plus road deaths and injuries, should be taken into consideration. We also believe that a natural capital assessment must be made of all habitats to be lost if a road is built.
CPA Submission: National Infrastructure Planning Reform Programme Consultation - December 2021
In December 2021, the CPA submitted a detailed response to the National Infrastructure Planning Reform Programme consultation.
We are concerned that the consultation focuses on speed and that the current system is too reliant on infrastructure projects that are proposed at a stage at which alternatives (that may be better for communities, the planet and the public purse) are not able to be considered.
The passing of the Environment Act provides the ideal opportunity to take a new approach. We must start by defining the problem, and then enable all stakeholders to discuss the full range of solutions. Read the rest of our suggestions by clicking on the link below.
CPA Submission: Ox-Cam ARC Spatial Framework Consultation - October 2021
In October 2021, CPA submitted a response to the consultation, “Creating a vision for the Oxford-Cambridge Arc”.
We said that any future framework produced for the area needs to be evidence-led and community-driven, and must minimise damage to the environment.
If this consultation is to be genuine, with outcomes not already pre-decided, as indications in press coverage in recent years would lead one to believe, it must also consider seriously two further alternatives. One of those being a 'do-nothing' strategy of no spatial framework for the Arc, and the other, a spatial framework that delivers only local housing need and associated infrastructure.
Our full submission is available to read at the link below.
CPA Submission to Lords Select Committee for the Built Environment - September 2021
In September 2021, CPA submitted a response to the House of Lords Built Environment Committee, which launched an inquiry on the demand for new housing in the UK and how barriers to meeting this demand can be overcome.
In summary we proposed that the inquiry should recommend the following actions:
- A review of the national housing target, with Census 2021 data as the trigger;
- That Government policy should deliver for housing need, not just demand, and for renters as well as home buyers, while investment in social housing must be prioritised;
- The need for far greater and more meaningful community participation, not less, across the planning system, so that outcomes are improved for everyone. And that genuine community participation should be a core component of all future planning policy, including mandatory referendums for Local Plans.
You can read our full submission by clicking on the link below.
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