PlanningPolicyConsultation@communities.gov.uk;
ministerial.correspondence@communities.gov.uk
Dear MHCLG
NPPF 2024
Labour’s push to mandate 1.85 million new homes, alongside new towns, will not address the housing crisis and will come at the expense of our countryside, food security and nature.
What people think
Over 80% of Community Planning Alliance respondents believe the proposed changes to the National Planning Policy Framework (NPPF) will:
- fail to make housing more affordable
- fail to reduce social housing waiting lists
- lead to an unacceptable loss of countryside
80% also feel that food security is as important as housing. The so-called ‘grey belt’ classification is overwhelmingly unpopular, with only 9.6% in favour.
Furthermore, 95% demand greater community involvement in the planning process.
The December 2023 changes to the NPPF had started to rebalance the system away from developers. Now government proposals send us further into a developer-driven system, where market houses will be prioritised over affordable housing, often in unsustainable locations.
That’s because the emphasis on targets and the presumption in favour of development promotes unsustainable development outside local plans, and because viability opt-out clauses will allow housebuilders to negotiate their way out of commitments.
We need:
An evidence-led planning system
We need evidence of how housing need will be met (including a social housing target), with local input. We need an impact test to demonstrate what the policies proposed mean for developers and what happens if they are not delivered. And we need scrutiny of the ecological, natural capital and food security impact of policies and what they mean for carbon emissions, air quality and future food security.
The end of car/HGV-dependent sprawl
Instead of a confusing new ‘grey belt’ definition, we need a robust hierarchy across the board that plans for use of empty homes and for conversions, then suitable brownfield, and finally, gentle density/compact transit-oriented greenfield. All low density, car/HGV-dependent development should be refused in favour of compact, transit-oriented development, with sustainable freight transport options being a requirement where warehousing and logistics are proposed.
Recognition of viability constraints
Undeliverable promises serve no one. Viability opt-outs must be eliminated, and policies that prioritize housebuilder profits over public good should be revoked. In addition, the government must recognise the viability limitations in the system and that removing hope value will not solve viability problems. Government must therefore fund social housing and new towns. Scrapping the new roads programme would be an immediate way to release funds for public and active travel and councils should be supported to look at workplace charging & local congestion charging.
Food security and the natural world at the forefront
Our planning system must prioritise and protect our prime farmland and natural ecosystems. Solar, batteries and non-linear grid infrastructure must be on brownfield, rooftops & car parks. The environment must be on an equal footing with economic growth.
To conclude
Imposing top-down targets on councils misunderstands the fundamental issue. It’s housebuilders, not councils, who build homes—they prioritise profit margins over housing volumes and there are currently no penalties for non-delivery. Relying on the market to deliver is a flawed strategy, rendering Labour’s policies undeliverable.
We need to ask who we are building for: if it’s foreign investors and private equity, then our politicians are clearly doing something wrong.