National Planning Policy Framework

We have wriiten to each Nottinghamshire MP encouraging them to write to the Communities Secretary supporting CPRE views on the revision of the NPPF.

CPRE briefing on the National Planning Policy Framework (NPPF)

Overall Summary:

The role of the planning system is to pursue sustainable development, in order to meet people’s needs for decent housing, productive farmland, and access to green spaces. With good planning, it is possible to build the homes the country needs, while also protecting our countryside. ‘Sustainable development’, however, needs to be defined more robustly in planning. As MHCLG consults on its Draft Revised National Planning Policy Framework, CPRE is calling for an NPPF which explicitly links to the government’s commitment to the UN Sustainable Development Goals, and one which will:

• Support local democracy by adhering to neighbourhood and local plans.
• Ensure realistic and high quality development based on genuine need not market demand.
• Deliver more affordable homes by closing legal loopholes that put developer profits first.
• Adopt a true ‘brownfield first’ approach to development.
• Protect our countryside for current and future generations, with robust maintenance of Green Belt policy, and strong protection for National Parks and AONBs.

Supporting Local Democracy

We welcome the addition of text in paragraph 12 of the draft NPPF, which clarifies the primacy of local and neighbourhood plan policies in determining planning applications, and the improved clarity on the relationship between strategic policies in local plans and more detailed policies in neighbourhood plans.

We want councils and local communities to be empowered to say no to bad development which does not conform to neighbourhood or local plans, or meet all the aspirations of the NPPF. Where a council falls behind on housing delivery, the focus should be on getting consented sites built, not releasing even more land for development. The new housing delivery test should not be used to punish and disempower councils who rightly seek to defend those areas which the NPPF requires them to protect from unsustainable development. We also urge the government to specify that local plan reviews must take into account the wishes of communities who have prepared their own neighbourhood plan.

Ensuring Realistic and High Quality Development

We welcome the government’s recognition of the scale of the housing crisis and the strengthening of existing policies on achieving well-designed places.

We want solutions which focus on high quality development, rather than growth at all costs. Housing targets should be set at realistic levels and based on local need, availability of appropriate sites and capacity of house-builders, rather than arbitrary indicators of demand based on ‘market signals’. The government should also use national planning policies to rebalance the economy away from London and the overheated housing markets of the South East, and towards regions where there are opportunities available through suitable brownfield sites and existing infrastructure, and where investment in high quality development could have a truly transformative effect.

Delivering Affordable Homes

We welcome the stronger rhetoric on developer accountability and the requirement that viability assessments be publically available. We explored the damaging effects of viability assessments on affordable housing provision in rural communities in our recent ‘Viable Villages’ report with Shelter.

We want the government to recognise the continuing importance of social homes and affordable rented homes in meeting the needs of people who cannot afford even sub-market home ownership, especially in rural communities where average incomes are lower. Government support for starter homes and other forms of low-cost home ownership should not come at the expense of providing genuinely affordable, decent rented accommodation for those who cannot afford to buy. We also want the new Planning Practice Guidance to specify that viability should be assessed across a whole development plan at the plan-making stage, and not just for individual sites within local plans. We fear that the draft guidance will result in lower, unambitious affordable housing policies that will not push developers to deliver the affordable homes that are needed. Finally, we call on the government to remove references to the minimum profits that developers should expect to receive.

Brownfield First

We welcome the higher priority that the revised NPPF gives to the reuse of brownfield sites, the role of councils in bringing forward suitable brownfield land, and the importance of increased but appropriate density of development.

We want an explicit policy in the NPPF that ensures suitable brownfield sites are developed before greenfield sites are released, and which prevents developers from cherry-picking greenfield sites. Presently, developers are able to force through greenfield development even when brownfield options exist, on the grounds that greenfield sites are more ‘deliverable’ in the terms used in the current NPPF. More should be done to encourage councils and developers to use Brownfield Registers to actively make more suitable sites deliverable.

Protecting Our Countryside

We welcome the new ‘exceptional circumstances’ test for altering Green Belt boundaries, which requires councils to demonstrate they have considered brownfield sites, increasing densities and other options with neighbouring councils before releasing land for development. We are also pleased to see stronger protection for Areas of Outstanding Natural Beauty (AONBs) and National Parks against large developments of market housing which is usually better located elsewhere.

We want a clear statement that high housing demand and aspirations for growth, in and of themselves, do not constitute a reason for altering Green Belt boundaries. Local authorities facing significant policy or environmental constraints on development should not be encouraged to plan for growth or meet unrealistically high housing targets unless there are suitable unconstrained opportunities available. We also urge the government to reconsider the proposed introduction of an ‘entry level exception sites’ policy, which we fear will lead to more unaffordable ‘executive homes’ being built on greenfield sites, in the guise of cross-subsidisation for entry level housing.

Our Consultation Response

CPRE campaigns for a beautiful and living countryside. We work to promote good development and protect the countryside from bad development. Over the coming weeks, we will be consulting with our network of 43 branches to produce our response to the government’s NPPF consultation, which closes on Thursday 10th May 2018. We are asking MPs to write to the Secretary of State, Sajid Javid MP, and share these concerns above before the consultation closes.