CIC calls for further design, quality and sustainability safeguards in NPPF response

The Construction Industry Council (CIC) has responded to a consultation seeking views on a revised version of the National Planning Policy Framework (NPPF).

The new NPPF’s strategic approach to planning, and the consideration of housing delivery in tandem with the provision of infrastructure and amenities, has been widely welcomed. So too has the emphasis on creating well-designed places while strengthening measures to bring forward development in places where it is needed including the principle of more homes around infrastructure, including transport hubs. 

CIC members have expressed a need for reassurance that measures intended to significantly increase the speed and quantity of development do not sacrifice design quality, sustainability and the ability to improve people’s quality of life. There are some concerns that without adequate safeguards in place the changes to the NPPF risk losing local voice and accountability, undermining progress on net zero and, if planning departments are not appropriately resourced and trained, will result in unchecked substandard development.

Areas that members felt required more consideration included: 

• Housing near stations and the need for safeguards against the ‘default yes’. There are concerns that the establishment of a ‘default yes’ for high-density development around railway stations, does not have enough safeguards. RIBA members, for example, have shared experiences of overdevelopment of constrained sites, reduced daylight, amenity and adaptability, which have led to growing public resistance to necessary new housing delivery.
• Policy Modification 13 and the need for local accountability. ‘PM13’ is intended to improve clarity, consistency and accountability in how planning policies are applied and delivered by restricting the ability of local authorities to demand higher standards than those in the Building Regulations. Unfortunately there appear to be inconsistencies between PM13 and the climate aims of the draft Framework and draft Design and Placemaking Planning Practice Guidance. Furthermore, the potential social impacts of PM13 such as energy savings from building to higher efficiency standards, or health impacts for vulnerable populations, have not been subject to assessment. In the absence of ambitious building regulations at a national level, planning is one of the few mandatory drivers to foster improved environmental/energy performance and meet local democratic expectations.
• The need to safeguard design and landscape quality in the presumption in favour of sustainable development. Given fewer than a third of local planning authorities are thought to have up-to-date local plans, meaningful progress on the drawing up and updating of local plans will be essential to make this approach work and the draft Framework needs to be rigorously clear that inadequate design quality is a legitimate ground for refusal in terms of development both inside and outside of settlements. The planning, design and management of the landscape needs greater consideration as part of good placemaking including highlighting the design of views to historic and natural landmarks and the integration of distinctive landscape features to strengthen a sense of place.

While our members are positive on the reforms including the plan-based approach to decision making coupled with a return to regional planning strategies, for successful delivery to happen it must be accompanied by a change of culture and greater safeguards to ensure that good design in quality and placemaking is actually delivered in practice.

The full response can be read here.