RICS Response to Consultation on National Planning Policy Framework Reform

The RICS has responded to the Levelling-up and Regeneration Bill: Reforms to National Planning Policy consultation. Our response to the consultation was informed by the insight and expertise of RICS members, who gave their time to ensure that a plurality of views have been considered.

The Government has described this consultation as an opportunity to gather opinions on its proposed approach to updating to the National Planning Policy Framework, the forthcoming National Development Management Policies (NDMPs), and how it develops policy to support levelling up. This consultation is the first of many, with several others slated for release over the course of the year. 

One of the central built-environment challenges for the UK is reducing our carbon footprint. We welcome the measures proposed in this consultation to support renewable energy and the adaptation of buildings to meet the challenge of climate change.

We also welcome government’s desire to ensure our places are better planned, designed and built to standards which contribute to achieving the UN Sustainable Development Goals, thereby ensuring future generations enjoy enhanced levels of health and wellbeing than previous ones.

Nevertheless, we are concerned that in reality these future generations will have poorer access to housing due to a combination of factors. First amongst these has been a failure over the last 20 years to effectively address the housing shortage in England through public policy, which has widespread implications and needs urgent intervention.

While there are elements of the amended Framework that we welcome, such as the retention of the housing target and the retention of the Standard Method for assessing housing need; a number of the proposed amendments have resulted in a slowing down of the plan-making process. Together with weakening housing demand in 2023, we fear that several of the suggested policies in the Framework will reduce the ability of the sector to meet the annual housing need.

Key themes from the National Planning Policy consultation and our response to them are set out below:

• Achieving Net Zero: We welcome the consultation’s acknowledgement of the importance of carbon measurement throughout the plan-making process and the focus on climate adaptation, areas which we have readily contributed to through our suite of sustainability standards, including ICMS3 and the Whole Life Carbon Assessment, but sustainability and carbon reduction must go hand-in-hand with ambitious housing targets. Sustainable housing requires economic, social and environmental priorities to be ‘met’ also and meeting housing targets should not be achieved by reducing standards in other areas essential to ensuring overall sustainability. Nevertheless, we await future consultations on environmental aspects of the Levelling Up and Regeneration Bill, so a fuller picture will be established over the course of the year.
• A diverse sector: In order to satisfactorily meet housing demand, Government policies should encourage a mix of tenure and housing types to support a competitive and efficient market with choice. We welcome a diverse mix of housing to support sustainable communities.
• Ensuring certainty and stability: The uncertainty created by years of proposed planning reforms has led to a reduction in the number of up-to-date local plans, impacting the certainty that the public and our members value and disrupting the foundational basis of the plan led system.
• Place making: Although we understand the origins of the term beauty in public policy terms through the Building Better Building Beautiful Commission, the term ‘well-designed’ may be more appropriate in the context of the diverse technologies needed to be incorporated into the building process to address climate change. Quality of design is crucial in implementing regeneration policies which are often about physically transforming the image of the ‘place’.
• Appropriate targets and enforcement: Retention of a data driven set of housing delivery targets and reporting against them (5-year supply end of year data) remains essential to reach the 300,000 per annum housing supply target and to provide transparent and democratic accountability to the electorate on a Local Planning Authorities (LPA) performance. Furthermore, we strongly advocate that the enforcement functions of planning authorities and building regulators are appropriately staffed and funded to verify compliance and provide the necessary assurances to local communities.
• Devolution & Levelling-up: If Levelling Up is to be achieved based on rational principles the plans must be aligned to the national, regional and local objectives for economic growth and social provision, currently these amendments will not reduce these inequalities. In addition, while these plans are England-specific they should consider those already in place in other UK nations, such as National Planning Framework 4 in Scotland.
• Planning for the future: RICS advocates a review of the Green Belt policy to transparently consider the benefits and trade-offs that apply to its current operation, which is in line with established research, including the recent report The Centre for Policy Studies: The Case for Housebuilding. Failure to review Green Belt removes the opportunity to consider the most logical and sustainable option for increasing housing within cities, a policy which requires a combination of brownfield development, higher density, and in some cases limited Green Belt release.

The National Planning Policy Framework and forthcoming consultations ensure that this will be one of the most ambitious reforms to the planning system in recent years and we will continue to work alongside our members to provide expertise to the government as this develops.

For more information or to get involved in RICS’ policy work, contact Senior Public Affairs Officer, Robbie Toomey at rtoomey@rics.org.