Update 24th September 2024
NPPF Consultation ending Tuesday 24th Sept
Dear all,
STOP PRESS NPPF Consultation ending Tues 24th Sept at 11.45pm
The amended NPPF
https://assets.publishing.service.gov.uk/media/66acffddce1fd0da7b593274/NPPF_with_footnotes.pdf
Thank you to all those who have shared concerns and comments with us. This is incredibly helpful. Time is very short but we will try and incorporate them into a FeCRA response to the survey. Residents say that the repetitive nature of the questions is concerning as it suggests that this could be used to claim agreement of policies that had in fact been substantially rejected.
If you can, despite the very short notice please submit a response. You can email the Ministry for Housing Communities and Local Government at
PlanningPolicyConsultation@communities.gov.uk
You need to make it clear which question or paragraph number each comment relates to and ensure that the text of your response is in a format that allows copying of individual sentences or paragraphs, to help them when considering your view on particular issues.
and please cc Cambridge MP Daniel Zeichner daniel@danielzeichner.co.uk
Daniel Zeichner is Defra Farming Minister. This is important as this NPPF consultation removes the obligation to consider food security and the importance of agricultural land.
If you do nothing else, if you have concerns about food security, object to the deletion of 2nd sentence of Footnote 63 “The availability of agricultural land for food production should be considered, alongside the other policies in this Framework, when deciding what sites are most appropriate for development.” (Questions 82/83) removal of this obligation.
· Please tell the government and your MP that you want “Homes for Everyone” including wildlife
· The government must rethink its housing plans to prevent harm to countryside and wildlife.
· We can have homes for nature and homes for humans.
· The government must protect wildlife and farmland by enabling housing in the over a million empty and derelict homes and 165,000 commercial properties.
· The million unbuilt planning permissions must be built out and homes constructed on the over a million brownfield sites available.
· The priority should be a focus on genuinely affordable homes (social housing) for those in the most need.
Please tell your MP and MHCLG
Dear MHCLG
NPPF 2024
The government’s push to mandate 1.85 million new homes, alongside new towns, will not address the housing crisis and will come at the expense of our countryside, food security and nature.
What people are telling us
Community Organisations such as the CPRE and their branches in Cambs and Peterborough, Norfolk and Beds and the Community Planning Alliance (CPA) who have surveyed their members say:
‘over 80% of respondents believe the proposed changes to the National Planning Policy Framework (NPPF) will:
§ fail to make housing more affordable
§ fail to reduce social housing waiting lists
§ lead to an unacceptable loss of countryside
80% also feel that food security is as important as housing. The so-called ‘grey belt’ classification is overwhelmingly unpopular, with only 9.6% in favour.
Furthermore, 95% demand greater community involvement in the planning process.
The December 2023 changes to the NPPF had started to rebalance the system away from developers. Now government proposals send us further into a developer-driven system, where market houses will be prioritised over affordable housing, often in unsustainable locations.
That’s because the emphasis on targets and the presumption in favour of development promotes unsustainable development outside local plans, and because viability opt-out clauses will allow housebuilders to negotiate their way out of commitments.
We need:
An evidence-led planning system
We need evidence of how housing need will be met (including a social housing target), with local input. We need an impact test to demonstrate what the policies proposed mean for developers and what happens if they are not delivered. And we need independent scrutiny of the ecological, natural capital and food security impact of policies and what they mean for carbon emissions, air quality and future food security.
The end of car/HGV-dependent urban sprawl
Instead of a confusing new ‘grey belt’ definition, we need a robust hierarchy across the board that plans for use of empty homes and for conversions, then suitable brownfield, and finally, gentle density/compact transit-oriented greenfield. All low density, car/HGV-dependent development should be refused in favour of compact, transit-oriented development, with sustainable freight transport options being a requirement where warehousing and logistics are proposed.
Recognition of viability constraints
Undeliverable promises serve no one. Viability opt-outs must be eliminated, and policies that prioritize housebuilder profits over public good should be revoked. In addition, the government must recognise the viability limitations in the system and that removing hope value will not solve viability problems. Government must therefore fund social housing and new towns. Scrapping the new roads programme would be an immediate way to release funds for public and active travel and councils should be supported to look at workplace charging & local congestion charging.
Food security and the natural world at the forefront
Our planning system must prioritise and protect our prime farmland and natural ecosystems. Solar, batteries and non-linear grid infrastructure must be on brownfield, rooftops & car parks. The environment must be on an equal footing with economic growth.
To conclude
Imposing top-down targets on councils misunderstands the fundamental issue. It’s housebuilders, not councils, who build homes—they prioritise profit margins over housing volumes and there are currently no penalties for non-delivery. Relying on the market to deliver is a flawed strategy, rendering the government’s policies undeliverable.
We need to ask who we are building for: if it’s foreign investors and private equity, then our politicians are clearly doing something wrong.’ ( CPA letter)
See what the Leader of Buckinghamshire County Council Martin Tett (Conservative) has advised Bucks residents and reflect that the changes being proposed to the planning system, pose an even greater threat to water short Cambridge, which has huge infrastructure and affordability issues and has been targeted for the highest growth in the country by the government. The Cam chalk streams are in dire straits, already sucked dry by the water companies and filled with sewage by Anglian Water, who run the Cam Ely Ouse catchment, advised by the Rivers Trust.
We are told that Cambridge’s water scarcity can be addressed by an untried system of water credits.
Can you drink water credits?
Scientists at the Environment Agency have been objecting to the huge developments posed for this area until there is evidence of there being enough water have warned that it is a choice between the environment and growth. The huge development planned for Cambridge, will impact our city’s lovely green spaces and its beautiful setting of water meadows and top grade agricultural land and add to the risks known to be posed by flooding and rising sea levels.
Extract from Bucks County Council Leader (Martin Tett’s) Latest Newsletter on the new NPPF with respect to Buckinghamshire.
Proposed changes to planning laws
I have written about this before but I make no apology for majoring on it again. In my opinion this is the subject that, above all others, could most directly influence and potentially radically change our towns and villages. We now have a lot more details from the new Government and I want to make sure that you are aware of them.
The proposed changes relate to something called the ’National Planning Policy Framework’. This is simply the legal rules that all councils must follow in Planning. The proposed changes are complex but I will try to simplify them.
Firstly, the new Government is proposing introducing non-negotiable legal targets for the number of houses that must be planned to be built in an area. Previously this was a ‘starting point’ and could be modified due to constraints such as the Green Belt, the Chilterns Area of Outstanding National Beauty, flood plains, agricultural value etc. This would no longer be the case.
Secondly, the way this target would be calculated has changed very significantly. This means that the proposed target for Buckinghamshire would increase from 61,152 to 86,562 by 2045 – an increase of 42%! At the same time the proposed target for London has been reduced. On top of this Buckinghamshire would have to allow for an additional 5% to encourage builders to build and finally the Government is proposing so called ‘new towns’ of at least an extra 10,000 homes in addition. As a result, Buckinghamshire could be required to plan for and absorb almost an additional 100,000 houses in the next few years.
To enable this the next major change being proposed is to the Green Belt. Councils would be required to designate areas that make a ‘limited contribution’ to the overall Green Belt as so called ‘grey belt’. Developers would also be able to put forward sites that they claim are ‘grey belt’. This is clearly a very vague definition and could lead to many applications to build across much of the Green Belt.
Very importantly, if the changes come into effect as currently proposed then from early next year it will be very difficult to refuse applications even if they are not in existing and approved Local Plans.
Lastly, I am also concerned that, with the potential for such significant housebuilding in Buckinghamshire, there is no commitment to fund the necessary infrastructure and facilities from doctors to roads, schools and sewage treatment that will be needed to accompany these very large numbers of new homes and new residents.
(Martin Tett extract ends)
Best wishes,
Wendy
Wendy Blythe
Chair, FeCRA
www.fecra.org.uk
www.facebook.com/CambridgeRAs
www.twitter.com/fecra2
Wendy Blythe
Chair, FeCRA
www.fecra.org.uk
www.facebook.com/CambridgeRAs
www.twitter.com/fecra2
Recent Comments