BRE's response to the National Planning Policy Framework Consultation

BRE's response to the National Planning Policy Framework Consultation

BRE responds to The National Planning Policy Framework (NPPF) which sets out the government’s policy for local planning practitioners and stakeholders.

The National Planning Policy Framework (NPPF) sets out the government’s policy for local planning practitioners and stakeholders.  This includes the way in which local (and neighborhood) plans are developed and applications assessed, and also direction in respect to local policy ambition and requirements for issues such as health, security, climate change, housing etc.

Like many other individuals and organizations (some >22,000 it would seem), we welcomed the opportunity to comment on the revised version of the NPPF (released 5th March, 2018) and its supporting guidance notes.

Others have commented extensively on the key themes, attributes and purpose of the revision (POS , RTPI , TCPA etc.) which are (narrowly) summerised as:

  • The delivery and optimisation of land for housing (through, for example, a new housing delivery test, and the prioritization of brownfield/land use densification and stronger protections for the green belt); and
  • Streamlining of the plan making and approval process (front loading viability assessments, a review of S106 and CIL contributions, strategic planning via a ‘statement of common ground’ and the setting of ‘minimum strategic policies’ for plan making)

We are generally supportive of these overall aims to consolidate and optimize the current planning policy landscape and process. We also recognize the urgent need in the UK for more housing (and associated development) and, through our business activities, support this agenda in several ways. For example, though our leading independent certification schemes; BREEAM (driving sustainability in building and communities), the Home Quality Mark (for new homes), CEEQUAL (for infrastructure and public realm) and SABRE (for cross sector security risk management).  Also, via our Innovation Park , Centre for Resilience , and numerous planning good practice guidance’s  (relating to photovoltaic technologies and good daylighting for example).

However, the draft does not currently place enough emphasis on delivering housing and development ‘quantity and quality ’ in unison.  The NPPF (2018) should be strengthened to ensure long term societal goals relating to sustainability are delivered, with particular focus needed on those relating to public health and overall quality. 

Consequently, we focused our response points on assisting the MHCLG with achieving this imperative, and which have been summarized below as:  

1. Greater emphasis needing to be placed throughout on the critical importance of good design, public health and the delivery of quality.

  In order to build public confidence and deliver the places the nation needs.  

2. The reinstatement of the reference to Garden City principles.

  To ensure new, strategic developments are devised with high placemaking standards, socio-economic opportunities and have long-term stewardship.  

3. Strategic policies needing to also include those relating to securing public safety and positive health outcomes, and the demonstration of good quality design.

  To ensure the delivery of places that support national security and public health imperatives.  

4. The adoption of a more comprehensive and longer-term viability methodology.

  To enable more accurate and holistic assessments and the delivery of truly sustainable development.  

5. Making clear the positive use of pre-commencement conditions.

  To support faster decision making, collaboration and the delivery of desired outcomes.  

6. Greater emphasis needed in respect to the importance of public health and good daylighting, within and across development boundaries, present and in future.

  To ensure positive public health outcomes are safe guarded, and enabled, especially when considering higher density development.  

7. Clearer endorsement of independent, resource efficient delivery tools including (but not limited to) BREEAM, the Home Quality Mark, Passivhaus, CEEQUAL and SABRE.

  To support planners in the adoption of robust, market recognized, resource efficient tools that help ensure good quality, sustainable developments are built.  

8. Explicitly referencing the duty placed by the Climate Change Act and directly signposting overheating mitigation best practice.

  To ensure appropriate, and direct action is taken in respect to climate change mitigation and adaptation, and in particular reference to the risks of overheating and public health.  

9. Making clear the position with respect to energy demand reduction standards for new homes.

  To re-enforce, and support cross-sector investment and ambition in respect to the BEIS Clean Growth Strategy.  

10. Clearly relating to the ambitions and policies of the DEFRA 25-year plan in a integrated and comprehensive manner.

To ensure that the NPPF is an effective catalyst for environment protection and improvement.

We fear that it is unlikely that the Government will achieve its housing and development targets without a clearer, focused drive on the delivery of sustainable, quality developments and urge that the above points are reflected in the final NPPF (due to be released this summer).  Our built environment should be well designed, and support public and environmental health; quantity and quality can, and must be delivered in unison.

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