Response to Government consultation on the National Planning Policy Framework

In December 2022, the Government published some proposed amendments to the National Planning Policy Framework and offered an open consultation on the proposed updates. The consultation deadline was Thursday 2 March and as planned, officers sent a written response to the consultation, covering a number of key points. The letter articulates the council’s position on a number of important points, including that:

• The timing of the review of the “standard method” for determining new housing needs in the Local Plan, which the Government plans to undertake in 2024, should be brought forward
• Any new methodology should be evidence-based and relate to the emerging 2021 Census data
• Greater clarity should be provided on what factors might reduce the housing requirements in any given area
• The Government’s position on the status of “best and most versatile agricultural land” should be given greater clarity. In our view the proposed wording in relation to agricultural land is vague, and should be strengthened, so that it is equivalent to Green Belt protections. 

The letter also indicates the council’s broad support for proposed changes to the application of the five year housing land supply test and the way that the Housing Delivery Test (HDT) operates. While we agree that the Government should revise national planning policy to attach more weight to social rented housing in planning policies and decisions, in our view more could be done. 

We also advocate for the promotion of social rent as a first presumption for affordable housing provision and call for a new designation of Affordable Housing land. This is so that affordable housing providers are able to better compete with developers and housebuilders for land acquisition. 

You can read the entire contents of the letter here.