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Title |
Response to government open consultation on changes to the National Planning Policy Framework (NPPF) and the planning system |
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Purpose of the report |
To make a decision |
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Report Author |
Martin Horn, Senior Planning Officer (Strategic Planning) |
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Ward(s) Affected |
All Wards |
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Exempt |
No |
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Exemption Reason |
N/A |
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Corporate Priority |
Community Addressing Housing Need Environment. |
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Recommendations
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Committee is asked to: 1. Approve the submission of Spelthorne BC’s response to the Government’s open consultation of changes to the National Planning Policy Framework (NPPF) and the planning system.
2. Give delegated authority to the Group Head Place, Protection and Prosperity in consultation with the chair of E&S committee to make any final amendments to the consultation response before it is submitted. |
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Reason for Recommendation |
The changes to the NPPF and the planning system as proposed by the Government is likely to have a great impact on how planning is conducted nationally, and this in turn will have impacts on the built environment of Spelthorne. |
1. Summary of the report
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What is the situation |
Why we want to do something |
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• We have been consulted by government on changes to the planning system and its chief policy document the NPPF. |
• We want to feedback on the proposals to help shape the future of planning. |
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This is what we want to do about it |
These are the next steps |
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• We want to submit a response covering a proposal consisting of a wide range of matters, and to express our view on these proposals as a council. |
• Response to be formally submitted to government prior to the deadline of 11.45 pm on 24th September. |
1.1 This report presents the proposed response to the consultation on the revised NPPF, and to seeks member approval for submission to government.
2. Key issues
2.1 The new Labour government has acted very quickly to set out some significant changes to the National Planning Policy Framework (NPPF) in order to “fix the foundations of our housing system”. It forms part of a more comprehensive package of measures which will come forward in the autumn with a Planning and Infrastructure Bill and a long-term housing strategy alongside the Spending Review. These changes may impact on the way we deliver services across the Council in the future.
2.2 Appendix 1 is the letter which all Councils received from the Deputy Prime Minister Angela Raynor MP on 30th July 2024. It sets out very clearly the level of ambition and is an easy-to-read summary of the detailed technical changes that we are being consulted on. It will assist councillors in understanding the responses that we are proposing.
2.3 Below follows a summary of the key positions on the proposed changes that are set out within the full response:
2.4 Planning for the homes we need: proposed amendments to paragraph 1 and 60 of the NPPF clarifies that plans should as a starting point plan for an area’s entire housing need. This provides more clarity as to what amount of housing should be planned for, but the response is critical of the logic that increased housing targets automatically leads to increased housing delivery without addressing the conflicting incentives of planning authorities and for-profit developers.
2.5 Design codes: the response expresses a pragmatic view of both understanding the benefits of the proposed new focus for design codes to focus on smaller areas, whilst at the same time seeing the benefits of more strategically oriented area-wide design codes.
2.6 Strategic planning: the response questions the soundness of the approach of, in the short-term prior to strategic planning being fully implemented, sharing unmet needs with neighbouring planning authorities. The reality is that development need often functions on a different spatial level than authority boundaries. It is proposed that need should be shared within Housing Market Areas (for housing) and Functional Economic Market Areas (for commercial development).
2.7 New standard method: the response agrees that it does not constitute sound planning to assess housing need based on growth projections that are more than ten years old. It does, however, set out that the proposed new method of basing housing need on existing housing stock is coarse and does not take into account different rates of growth in different parts of the country. It also sets out that the 20% increase in housing numbers that Spelthorne would be facing as a result of the stock-derived method and the increased affordability uplift would be an immense challenge for a constrained borough such as ours.
2.8 Green belt release: support is set out for a strategic approach to Green Belt release in favour of our current haphazard method but acknowledges that we do not yet have the full details on how the strategic planning tier will function. There has been no strategic review of the Green Belt since the mid-1900s, and a stronger focus on the actual function of the Green Belt and its purposes is preferable to the current consideration of if the land is Green Belt or not regardless of its quality.
3. Options analysis and proposal
Option 1 – agree the suggested response to government (recommended)
3.1 This will ensure government are fully aware of our views and is the only way we might be able to influence or change those areas which we feel need improving, changing or where there are omissions.
Option 2 – do not respond to the consultation
3.2 We will be passing up the opportunity to make our views known to government and would be failing in our public duty to represent the views of our residents and communities.
Option 3 – suggest revisions or amendments to the suggested response
3.3 It is open to the committee to decide if there are areas of the response that need more focus or where a more decisive comment needs to be given. There may also be areas which the revise NPPF does not cover which the committee wish to specifically draw to the attention of government.
4. Financial management comments
4.1 If fully implemented, the NPPF would allow the Council to recover higher fees for householder applications. This will help in reducing the shortfall between the planning application fee and the cost of the development management service. However, we will not reach full cost recovery.
5. Risk management comments
5.1 If we do not respond to the consultation we cannot be clear to our residents and communities what our views are, and cannot use it to lobby government to get amendments where required.
6. Procurement comments
6.1 There are no procurement implications arising from this report
7. Legal comments
7.1 There are no legal implications arising from this report
8. Other considerations
8.1 Depending on feedback, the government may or may not make any further amendments to the NPPF. If it remains substantially unaltered, then it will result in an increased housing requirement, and a greater prosect that we may be required to look at possible future grey and green belt release for future Local Plans.
9. Equality and Diversity
9.1 There are no equality and diversity implications arising from this report
10. Sustainability/Climate Change Implications
10.1 The revised NPPF is looking to secure enhanced benefits for nature and public access, and Local Nature Recovery Strategies.
11. Timetable for implementation
11.1 Response to be formally submitted to government prior to the deadline of 11.45 pm on 24th September. There is no date for the publication of the NPPF in its final form.
12. Contact
12.1 Martin Horn, Senior Planning Officer – m.horn@spelthorne.gov.uk
Please submit any material questions to the Committee Chair and Officer Contact by two days in advance of the meeting.
Background papers: There are none.
Appendices:
Appendix 1 – Letter from Deputy Prime Minister Angela Rayner MP
Appendix 2 – Draft SBC Response to Government consultation on NPPF amendments 2024