RICS Response to Consultation on Reforms to National Planning Policy Framework

This week, we submitted our response to the Ministry of Housing, Communities and Local Government’s (MHCLG) consultation on proposed reforms to the National Planning Policy Framework and other changes to the planning system.

RICS fully supports the aims of the reforms to the NPPF to deliver 1.5 million new homes in the next five years by boosting land supply and thereby housing delivery. We support the Government’s desire to remove barriers and inject a degree of uniformity into the planning system but caution the unintended consequences potentially arising from the application of the revised Standard Method approach, Grey Belt/Green Belt definition and the Golden Rules as designed.

Our response includes representations from an array of members, including the CPO expert working group, heritage advisory group, the Planning & Development member group, our Professional Group Panels and Governing Council. A special thanks goes to members of the Planning & Development Expert working group, who gave up a considerable amount of their time and expertise to ensure an evidence-led response to the consultation.

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

• The importance of private and public sector partnerships: We recognise the role the private sector is intended to play to deliver the majority of this housing. Nevertheless, the delivery of the homes needed across England will require the contribution of the local authority and housing association sectors.
• Standard Method: We welcome the proposed introduction of the ‘Standard Method’ but caution that without further means for moderation it currently produces some significant outliers.
• Affordable housing delivery: 50% affordable housing delivery on Green Belt land is a laudable target, but viability testing at plan making stage will remain necessary and should apply as currently conducted. Many low sales value areas will not support this target, so the need for flexibility remains essential to deliver more housing including more affordable. We have submitted case studies to MHCLG to support the evidence gathering process in this area.
• Ensuring clarity across a diverse environment: We recognise policy makers desire to have simple standard metrics applied universally to Grey Belt/Green Belt land. This ignores the great diversity of house prices, land values and viability conditions within Grey Belt/Green Belt land.
• Green/Grey Belt: We advocate that the new policy towards Grey Belt/Green Belt land is applied as an extension of existing procedures for assessing viability, tested in the first instance at plan making stage.
• CPO reform: We advocate alternatives to ensure land comes forward without having to resort to CPO measures. Nevertheless, failing success through these measures we would support the use of compulsory acquisition powers where the market and policy changes are not delivering the housing required in specific areas.
• Planning fees: In some cases, an increase in planning application fees could lead to service improvements, however this is based on tangible service improvements, as well as a ringfencing of these increased fees for Local Planning Authorities. In addition, to ensure planning departments are adequately resourced and manned, alternative ways of working should be considered.

The National Planning Policy Framework and forthcoming consultations on brownfield passports and the development of the New Towns Taskforce 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, Robert Toomey at rtoomey@rics.org