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NPPF - a reflection on the consultation

Dr Daniel Slade is the RTPI’s new Policy Manager. He is responsible for managing the Institute’s policy in England, and practice and networks across the UK.

The first thing on the to-do list

Even before I re-joined the RTPI on 30 January, one task in particular loomed on the new job to-do list: The mammoth consultation on reforms to national planning policy, to which the Institute has now replied. 58 questions on everything from the new NDMPs, to housing land supply, renewables, inclusive planning, and ‘beauty’, accompanied by a disconcerting number of proposals which came with no invite to comment. Most of this could have profound consequences for communities, councils, government and industry’s collective response to the greatest challenges we face, most notably the housing crisis and climate change.

Our eventual question-by-question response stretched to 31 pages, with another three devoted to a summary of our members’ headline concerns. But the approach we took is, perhaps, just as notable.

Responding to a mammoth

Much like planning itself, writing consultation responses is both a science and an art. It’s a double act: Ensuring technical accuracy while threading a line of argument through positions most of your members agree on. For the RTPI, this needs to be done whole wearing several very different hats. We have a membership that’s almost evenly split between the public and private sectors (with a smattering of third sector), and that are both a Learned Society and professional body. But, crucially, it’s this sheer breadth and depth of experience in the membership that is the RTPI’s greatest resource. So we did everything we could to draw on it?

By the time I’d clicked ‘send’ on our response, the RTPI had run 16 roundtables across all regions of England. We’d had the input of specialist networks, RTPI Fellows, housebuilders, and a great number of written representations from different aspects of practice. The England Policy Committee then spent more than two and a half hours debating the draft response and provided detailed feedback to officers.

The response

Understandably, given this range of inputs and how divisive some of the policy issues covered by the consultation were, there were some strong differences of opinion.

Views on the consultation’s opening question (‘Do you agree that local planning authorities should not have to continually demonstrate a deliverable 5-year housing land supply (5YHLS) for as long as the housing requirement set out in its strategic policies is less than 5 years old?’) split fairly neatly between those concerned about its impact on housing supply, and those concerned that the current arrangements lead to plans being undermined too soon after their adoption.

The introduction of the NDMPs and their proposed scope, meanwhile, were broadly supported, but vocally opposed by a smaller group on the grounds that they will be heavily centralising. The removal of the need to ‘justify’ local plans, meanwhile, was the inverse – the vast majority of our contributors opposed it, but some saw it bringing important benefits in the form of greater local political support for more vision-led plans, and a lighter burden on local planners.

But there were also - thankfully, from an officer perspective - many clear points of consensus. There was widespread dismay at the prospect of applicants’ past behaviour being taking into account in decisions. Members agreed that the ‘pincer’ on new development that the proposals on ‘out-of-character’ densification and strengthening green belts would bring could seriously undermine the delivery of housing (and indeed, employment land), even where it’s in the public interest. Mansard roofs featuring in national policy provided some light relief. And there was widespread support for a greater emphasis on creating inclusive places.

But above all, members agreed on the thrust and likely impact of these reforms as a whole. While the proposals aim to address very legitimate concerns - low local plan coverage and falling community support for plans or the wider development process, driven by what can be an overly technocratic, numbers-led approach to planning – they fall short of providing a meaningful solution.

This is because the proposals remove (what are certainly deeply flawed) incentives for local decision makers to produce plans that meet local needs without replacing them. In the process they introduce increasingly incompatible policy goals, and risk paying lip service to what communities need while giving councils fewer policy tools to see them delivered. Far from levelling up the country, these changes are likely to make it harder for local leaders to make the case for development, even where it would be in the wider public interest.

Looking ahead

Looking ahead, this mammoth is just the first in a wave of planning reform consultations.

On the 13 March the RTPI’s Head of Policy will give evidence to the Levelling Up, Homes and Communities Select Committee. After this will come our response to the consultation on planning fees, and after that, by our Senior Public Affairs Officer’s count, will come something like 10 more consultations on a range of issues.

It seems that my time as Policy Manager will go on as it has started.

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