National Planning Policy Framework consultation response for IEMA

Response to National Planning Policy Framework proposals

New government proposals for the National Planning Policy Framework (NPPF) have been released and our governing institute (IEMA) asked us for a response. The NPPF provides a framework for how planning authorities do their work and IEMA asked us to contribute on the sections entitled “Golden rules to ensure public benefit” and “Delivering affordable housing” the full text of which is given below. Here’s what we wrote.

Golden rules to ensure public benefit & delivering affordable housing

The comments below relate to certain subsections of the “Proposed reforms to the National Planning Policy Framework and other changes to the planning system”. Specifically, in “Chapter 5 – Brownfield, Grey Belt and the Green Belt”, there are two subsections:

• Golden rule to ensure public benefit – which is about proposals on amount of affordable housing, local infrastructure and new green spaces
• Delivering affordable housing – which proposes 50% affordable housing – of which the % of social rented homes to be decided by local authorities

There are two questions relating to these subsections:

Question 34:

Do you agree with our proposed approach to the affordable housing tenure mix?

Question 35:

Should the 50 per cent target apply to all Green Belt areas (including previously developed land in the Green Belt), or should the Government or local planning authorities be able to set lower targets in low land value areas?

• We would agree with the approach to affordable housing tenure mix – as local authorities will have a better idea of actual need in the area. However, we would recommend that rules are put in place such that social rent homes are not negotiated out of s106 deals simply to improve profits.
• 50% seems a bit of an arbitrary number. Good quality homes are a basic need for people and so the figure should be based on actual needs of people. We would therefore encourage Government to gain data to inform this % to align with actual demand. For instance, one BBC report states that, “Only one in eight renters can afford to buy in the area in which they live” [1] which suggests that the figures should be around 87.5%, not 50%.
• Questions 34 and 35 come at the end of proposals for Golden Rules for public benefit but there are no consultation questions for this public benefit. Therefore, we add comments to address those proposals.
• We would certainly agree with the proposal for more infrastructure such as GPs, schools etc – we would add centres for community groups to meet, shopping for basic provisions, places of work and public transport hubs.
• Green Spaces –the proposals discuss the provision of access to green spaces, including access to existing ones. Data suggests that this improves wellbeing of people so will generally serve public benefit. It was also mentioned in the Social Housing White Paper [2]. However, even more public benefit will come from actually creating these green spaces, not just relying on existing ones.
• The green spaces themselves should be biodiverse areas that are part of green corridors. This will combat the species decline in the UK. The Biodiversity Net Gain target should be a minimum requirement, and developments should include green corridors.
• There is no specific mention of the Future Homes Standard for energy efficient homes, nor is there mention of net zero homes. Given the urgency of tackling climate change there should be building standards included. It is not clear whether the NPPF will be relying on current building standards or whether local authorities can make their own requirements to suit their own climate emergency declarations.
• In a similar vein, there is no mention of water efficiency. We have heard accounts of new developments being refused planning permissions because of the lack of water availability. Water is a basic human need and so it is therefore of public benefit to have effective water efficiency standards. Part G of the current building regulations does have these, but we have visited several recently built homes which have inefficient water fittings. There have been previous calls to improve water efficiency targets [3], but there seems no progress on this in England (Wales has done this via WHQS), so perhaps these new proposals can be used to do drive water efficiency. There should also be a regime in place to ensure that post-construction checks are made to ensure water efficient fittings are installed.
• The proposals make no mention of overheating or heat waves even though the Met Office projections are for more of this type of climate. There will be public benefit from by addressing overheating. There should be provision to ensure that homes and other buildings are not at risk from overheating. The recent addition of Part O to building regulations may make a difference but have not been truly tested yet. In addition, given the experience of ignoring Part G for water efficiency, perhaps a regime of post-construction checks can be instituted via these new proposals.  Provision of green spaces and trees will certainly contribute to summer cooling.

IEMA’s full responses can be found on its website. [4]

If you would like further information on assessing environmental impacts of your housing portfolio, please be in touch: https://shiftenvironment.co.uk/contact/

[1] https://www.bbc.co.uk/news/articles/c7209lk8x2wo

[2] https://www.gov.uk/government/publications/plan-for-water-our-integrated-plan-for-delivering-clean-and-plentiful-water/plan-for-water-our-integrated-plan-for-delivering-clean-and-plentiful-water

[3] https://shiftenvironment.co.uk/news/water-efficiency-targets-for-uk-housing/

[4] https://www.iema.net/media/3fcdr3mk/iema-response-to-nppf_final.pdf

[5] Photo by Andrey Zaychuk on Unsplash

 

Full text of sub-sections

Golden rules to ensure public benefit

23. The Government has committed to introducing ‘golden rules’ to ensure that major development on land released from the Green Belt benefits both communities and nature. This will build on our wider commitment for exemplary design, so that the following are required where land is released through plans or individual planning decisions:
24. in the case of schemes involving the provision of housing, at least 50% affordable housing, with an appropriate proportion being Social Rent, subject to viability;
25. necessary improvements to local or national infrastructure, including delivery of new schools, GP surgeries, transport links, care homes and nursery places, to deliver well-designed, connected places, recognising that local leaders are best placed to identify the infrastructure that their communities need; and
26. the provision of new, or improvements to existing, local green spaces that are accessible to the public – where residential development is involved, new residents should be able to access good quality green spaces within a short walk of their homes, whether through onsite provision or through access to offsite facilities.

Delivering affordable housing

24. The Government is proposing a target of 50% affordable housing on land released from the Green Belt for residential development. The Government is committed to delivering more genuinely affordable housing tenures, such as Social Rent. However, we also recognise that for the purposes of place-making, a balance of tenures is required. For that reason, we propose that the tenure split across affordable housing delivered under the golden rules should be for local authorities to decide.

Question 34

Do you agree with our proposed approach to the affordable housing tenure mix?

Question 35

Should the 50 per cent target apply to all Green Belt areas (including previously developed land in the Green Belt), or should the Government or local planning authorities be able to set lower targets in low land value areas?