CRITICAL ACTION: Respond to the NPPF Consultation!
Government has proposed major changes to the National Planning Policy Framework and is currently running a public consultation, with a deadline of 11.45pm on March 2nd.
We urge ALL of you to PLEASE RESPOND, even if it's just a brief email!
The development industry is highly concerned about the changes, meaning they will be responding in droves. We must ensure that our viewpoints are considered too.
Scroll down to learn how you can respond.
Here is the link to the Government page, which contains further information, documents and details of the various ways in which you can respond: www.gov.uk/government/consultations/levelling-up-and-regeneration-bill-reforms-to-national-planning-policy
If all you have time for is a simple email, but you're not sure what to say, you will find a list of ideas in the template email below. However, personal responses will carry more weight, so do feel free to edit/lengthen it as you see fit.
Dear Sir or Madam,
Thank you for the opportunity to respond to this consultation. I welcome the overall shift in emphasis towards communities and seek much more of this in the forthcoming consultations. Earlier and more effective engagement with communities will lead to a less confrontational planning system.
My specific comments are:
- The changes to housing targets, to make them ‘advisory’, are very welcome. However, we remind you that Government continues to insist on using out-of-date projections (2014) and we urge an immediate change to guidance to insist (as previously) on most up-to-date projections. We also seek a review of the Standard Method, which does not make housing affordable and simply supports developers to build market homes where they want to.
- I strongly support the changes proposed to paragraph 11 and the five-year housing supply. It is essential that councils can plan, instead of being subject to speculative development & planning by appeal.
- 'JUSTIFIED' must be reinstated as a soundness test in plan-making – a local authority must be able to demonstrate why it has chosen a strategy and to support it with appropriate evidence.
- Mentions of brownfield, farmland, climate and density are welcomed. However, this needs to go further:
- Brownfield first policy (when suitable)
- Protection for BMV in policy, not footnote
- Climate – carbon impact assessment for local plans essential
- Gentle or goldilocks density first
- Environment – the six focus areas must be clearly set out in NDMPs and NPPF and linked to Government’s environmental announcement January 2023.
[INSERT YOUR NAME HERE]
If you and/or your campaign group wish to submit a more comprehensive response, listed below are a number of tools that you may find helpful.
Firstly, NPPF tracked changes can be found here, and Government's description of changes can be found here.
Secondly, our February 7th webinar was designed to help us consider the proposed changes to the NPPF and contained excellent information from:
- Rosie Pearson, CPA Chair, who introduced the consultation and then focused on the good, the bad and the missing
- Gareth Capner, Planning Consultant, who highlighted some key points about the 'Standard Method'
- Caroline Dibden, CPA Committee Secretary, who covered what the development sector and others are saying about the proposed changes
- Catriona Riddell, Planning Consultant, who focused on the removal of the 'Duty to Cooperate' and why strategic planning is good for communities.
The webinar can be viewed here: www.youtube.com/watch?v=8MeWr1jD1dU or, if you don't have time to watch it in full, we have uploaded the most important slides below. (Click on the picture to enlarge, or on the link to download.)
Thirdly, we have created an online template with all of the consultation questions listed. We suggest you SAVE it onto your own drive and share with anyone who is writing your group's response. You can then create columns for other people allowing you to compare responses. You might find this easier than answering one question at a time in the Government survey, although you will subsequently have to copy the answers over.
And finally, if you need any further help or advice, you will find a wealth of knowledgeable individuals in our lively Facebook group, so do please feel free to post your questions there.