Government Publishes Consultation on Approach to Reforming NPPF – A wolly and complete waste of time consultation


This consultation seeks views on our proposed approach to updating to the National Planning Policy Framework. We are also seeking views on our proposed approach to preparing National Development Management Policies, how we might develop policy to support levelling up, and how national planning policy is currently accessed by users.

A fuller review of the Framework will be required in due course, and its content will depend on the implementation of the government’s proposals for wider changes to the planning system, including the Levelling-up and Regeneration Bill.

No time to do a complete review but highlights inlude

-Complete removal tpo %YHLS buffers

-Paragraph 5. doesmnt actually state what changes are proposed to meeting housing need in NPPF, so impossible to comment on – a complete waste of time consultation

-[we] also propose to give more explicit indications in planning guidance of the types of local characteristics which may justify the use of an alternative method, such as islands with a high percentage of elderly residents, or university towns with an above-average proportion of students. – Note this is important as in each case these boosts to baseline population doent last forever. Elderly people did they dont add to baseline households, similarly students. In both cases though they revert back to the standard method not adopting a rigorous ‘stock flow’ computer model and cohort based model for household formation. It is better to reform the standaerd method than hav emultiple methods.

-, we intend to make clear that if housing need can be met only by building at densities which would be significantly out-of-character with the existing area (taking into account the principles in local design guides or codes), this may be an adverse impact which could outweigh the benefits of meeting need in full  – Wolly wolly wolly – ANY large scale planning means a change in character 0- especially in rural areas. Does this refer only to expected changes in density or changes in rural to urban density – or intensification through brownfield development – if the latter it is a ricicukous block on ALL change

-we propose to make clear that local planning authorities are not required to review and alter Green Belt boundaries if this would be the only way of meeting need in full  – Green Belts frozen fporever however out of date they are

_we propose to simplify and amend the tests of ‘soundness’ through which plans are examined, so that they are no longer required to be ‘justified’. Instead, the examination would assess whether the local planning authority’s proposed target meets need so far as possible, takes into account other policies in the Framework, and will be effective and deliverable. – Bu;;shot [plans are acce[ptab;e – no requirement to consider alternatives – a complete lock out for community groups offering evidence of alternative plans – the total abrogation of planning

– The government intends to maintain this uplift and to require that this is, so far as possible, met by the towns and cities concerned rather than exported to surrounding areas, except where there is voluntary cross-boundary agreement to do so. – Its not working it was the Greenbelt eating uplift – shifting away from the proposal to end the ridiculous transitional arrangements, so it now means a massive underdelivery nationalily – stop bullhsitting us and cancel this fairtail, fantasy most failed part of the last set of reforms

-The Bill will remove the Duty to Co-operate, although it will remain in place until those provisions come into effect. To secure appropriate engagement between authorities where strategic planning considerations cut across boundaries, we propose to introduce an “alignment policy” as part of a future revised Framework. Further consultation on what should constitute the alignment policy will be undertaken. We are, however, aware that the boundaries of some towns and cities mean that there is sometimes minimal distinction between areas that are part of one of the 20 urban uplift authorities and neighbouring authorities. In some cases, there is good co-operation between such authorities, but we would like to hear views on how such adjoining authorities should consider their role in meeting the needs of the “core” town or city. – I.e. the department has no clue what ;alignment’ and startegic planning means.

-The government does not propose changes to the standard method formula or the data inputs to it through this consultation. However, the government has heard representations that the 2014-based household projections data underpinning the standard method should no longer be relied on. – More admision of total confusion and failure – at the very least the standard method needs to take account of date – such as from the English Housing Survey – of where lack of housing has suppressed household formation – the evidence on this is now overwhelming.

-HDT – just delete it – it hardly applied to anywhere that wsnt failing the 5yhls supply test anyway – a complete failure and waste of time

-we propose a change to the current Framework footnote 58 by adding detail on the consideration that should be given to the relative value of agricultural land for food production, where significant development of higher quality agricultural land is demonstrated to be necessary, compared to areas of poorer quality land. – what change impossible to unbderstand

Wiltshire reduces Growth at Chippenham by 3,000, Homes England and Government Pull pout of Growth deal as Infrastructure Unaffordable


A £75m government deal to expand Chippenham is being scrapped due to rising costs.

The money was to help build the roads needed for thousands of homes and faced huge local opposition.

Due to spiralling building costs, Wiltshire Council said carrying on with the scheme would bring “extremely difficult financial risk”.

But questions remain about how Chippenham will now cope with future growth.

The original deal announced in 2019 was designed to bring travel upgrades including a new road looping around the southern and eastern sections of the town, unlocking the construction of up to 7,000 new homes over the coming decades.

Sorting that – so the argument went at the time – meant Chippenham would get the improved infrastructure to cope with growth before the homes arrived.

Following a backlash against the development, Wiltshire Council scaled back its ambitions to just the southern section, with around 4,000 homes.

Now, the council and the government body Homes England are withdrawing from the agreement altogether.

“The cost escalation has simply been too much,” Wiltshire’s leader Richard Clewer told the meeting in County Hall.

“It’s not unreasonable to say we would be looking at placing a massive financial strain on the council” if the plans had continued, he added.

The council would have needed to borrow tens of millions more than planned to pull the scheme off – and even then there was no guarantee Homes England would have agreed to a scaled back proposal.

The opposition Liberal Democrats said Wiltshire Council needed to learn serious lessons from the process.

“Chippenham was absolutely done-to, that’s what’s led to the bitterness and anger we’re living with now”, Liberal Democrat councillor Clare Cape told the meeting, who urged the council to rethink how it engaged with communities when developing plans like these, a point the council leader described as “fair”.

Meanwhile the lead campaigner who’d recently brought a legal challenge against the scheme, Helen Stride, accused the council of wasting money on “plans for a road that the people of Chippenham did not want, that the Chippenham Town Council unanimously opposed and that was subject to Judicial Review”.

Ms Stride’s campaign group fear “urbanising” large sections of land around the A350 South of Chippenham.

Wiltshire Council is going through the motions of working out how different corners of the county should grow in the decades ahead.

But if Chippenham continues to grow at the rate previously predicted, it has now become much harder to find the money to build the infrastructure to go with it.

Greater Manchester Strategic Plan Falling Apart Following Gove’s Abolition of Strategic Planning Tests

Manchester Evening News

A council leader has branded the massive Places for Everyone housing masterplan a ‘three year waste of time and money’ in light of a potential government planning U-turn.

The Secretary of State for Levelling Up, Housing and Communities, Michael Gove MP, has announced that there will be a consultation on a revised National Planning Policy Framework (NPPF), starting before Christmas.

He also confirmed that the long-standing target to build 300,000 homes a year would not be enforced, and would instead be considered ‘advisory’.

Housing targets have piled on pressure on local authorities, which are often unable to meet their ‘five year housing land supply’, by allowing development on protected green belt land.

Under the proposed changes to the NPPF, green belt land would have more protection and development of brownfield land would be emphasised in order to protect countryside development.

The announcement earlier this month comes as the Places for Everyone masterplan for nine boroughs of Greater Manchester, which proposes to allow thousands of homes to be built in the green belt, goes before planning inspectors.

The plan, previously known as the Greater Manchester Spatial Framework in its earlier incarnation, is allocating sites to build 165,000 homes across the region over the next 15 years.

However the inspection team have said that until any change becomes national policy, it won’t have an impact on the way the Places for Everyone plan is being assessed.

Liberal Democrat and Conservative councillors in Oldham raised the issue of the proposed planning changes at a meeting of the full council, asking what effect it would have on the regional masterplan – and whether green belt sites could now be withdrawn.

Lib Dem group leader Coun Howard Sykes said: “Following Mr Gove’s announcement, Greater Manchester now has two years during which to rethink and re-position its housing strategy.

“So, the question to the leader is will her administration now stop and pause and think again about the land grab to do with green belt and green spaces now we have no compulsory housing targets?”

Labour council leader Amanda Chadderton responded that she ‘welcomed the U-turn from the government’ in relation to the ‘top-down’ housing targets.

“I’m cautious given the government U-turns every ten minutes, so until it’s into law you have to be cautious about that,” she said.

“Obviously we have always said we don’t want to build on green belt. We should always progress a brownfield first policy and we should always be able to set our own targets based on our own housing need and the work that we do in this borough.

“It irritates me what an absolute waste of time, what an absolute waste of public money over the past three years. I find it disgraceful that we’ve had to go through this for them to change their minds.”

She added she had already begun conversations with authority officers about what effect it would have on the green belt sites in Oldham included in Places for Everyone, although until any change becomes law it would not affect the current plan.

In a statement, the Greater Manchester Combined Authority said: “The nine Places for Everyone districts will consider and fully participate in any consultation on the detailed proposals of this latest round of interventions from Government when the draft NPPF proposals are published.

“The nine districts note that the Written Ministerial Statement sets out proposals for consultation rather than immediate changes to Government policy. Consequently, the Inspectors have been clear that the examination of Places for Everyone will continue under extant policy unless and until such time as this policy changes.”

Mole Valley Pauses Local Plan in Face of Bullying by Paul Beresford MP and Nimby Cowardice by Gove


In light of recent announcements by the government, Mole Valley District Council (MVDC) has taken the decision to pause before moving on to the next stage in its Future Mole Valley timetable. MVDC will await clarification on the government’s plans for the planning system and Green Belt before deciding its next course of action.

Councillor Margaret Cooksey, Cabinet Member for Planning, said: “Michael Gove, the Secretary of State for Levelling Up, Housing and Communities, made three announcements* relating to housing targets and Local Plan production last week. Broadly, those announcements were suggestive of changes being made to the National Planning Policy Framework before Christmas. This has given us cause to consider and driven our decision to inform the Inspector in charge of the Local Plan Examination that we wish to put a pause to proceedings until we better understand what the government is saying.

“This decision has not been taken lightly and, given the very encouraging progress made during an exhaustive examination of the Plan between January and October this year, pausing this progression is not what we would otherwise want to do. However, it would be unwise to carry on when we are not sure what the wider national planning policy situation is so we have committed to wait until such time that the Inspector can advise us on what should be done next.

“We had been due to consult with stakeholders on the modifications proposed by us and the Inspector in January. We remain hopeful that clarity will be provided and we will take the best course of action for our residents.”

Note however there is legal dubiousness here – local plan submissions, pauses and withdralws are a full council matter. There ws no clear full council resolution on ANY of these matetrs.

Note recent – Iam looking at you you btter do as I say bully letters by Paul Beresford MP.

British trust for Ornithology wants to Ban reflective Windows as Birds Might Fly into them


None of the UK’s biggest cities have policies in place to protect birds from deadly strikes with buildings in their boroughs, exclusive Dezeen research has found.

Freedom of Information requests to the 33 local authorities in London and the councils responsible for 10 other major UK cities also revealed that none have ever carried out an assessment of bird-window collisions in their areas.

This is despite the British Trust for Ornithology‘s (BTO) alarming estimation that up to 100 million birds crash into the windows of buildings in the UK each year, with one-third of these birds dying as a result.

David Noble, a scientist who is investigating the issue of window-strike risks for the BTO, warned that building collisions could be accelerating the decline in bird numbers in the UK.

“UK bird numbers are declining overall and although evidence is lacking, collisions could be a contributing factor for any particularly vulnerable species, whether urban residents or nocturnal migrants or due to some other factor,” he told Dezeen.

The lack of council-led assessments reflects a wider shortfall in data on bird collisions, Noble added.

“We know from experience and through ring recoveries that bird-glass collisions occur but the magnitude of mortality and evidence for population-level impact in the UK and in Europe is little-studied and remains largely unknown.”

Bird-friendly legislation “would be both helpful and precautionary”

Noble called for legislation to require those working in the built environment to deliver bird-friendly buildings.

“Regarding policies to require architects and builders to implement bird-friendly windows and glass, moving in that direction would be both helpful and precautionary,” he said.

Through their planning policies, which are informed by national government guidance, councils are able to control new development in their areas.Read:Glass facades are “the main culprit” for billions of annual bird deaths

Councils in the UK have duties set by the governments of EnglandScotlandWales and Northern Ireland to consider the protection of biodiversity in their planning policies – but this guidance is focused on ensuring new developments do not affect habitats and not on preventing building strikes.

The Local Government Association, which represents councils in England and Wales, said it was not able to comment on Dezeen’s findings.

The Department for Levelling Up, Housing and Communities, which oversees planning policy in England for the UK government, did not respond to a request for comment.

“Change can and should come from within the industry”

Worldwide, it is estimated that collisions with buildings cause billions of bird deaths a year.

This is because birds can mistake windows for continued space or become disorientated by interior lighting that shines through them at night.

However, research suggests these fatalities can be minimised through simple measures such as opting for fritted or patterned glass on a facade, which is one of the most common ways to make glass on buildings visible to birds.

In response to Dezeen’s findings, senior vice president of animal rights organisation PETA Colleen O’Brien said that legislation and assessments could help save the lives of birds, but that architects should not wait for these to design bird-friendly buildings.

“Much-needed legislation requiring assessments of the impact of buildings on wildlife would save millions of animals’ lives, but change can and should come from within the industry,” she told Dezeen.

“Many architects are already embracing masking films, frits, ultraviolet patterns, and other design elements that prevent birds from crashing into reflective windows, and PETA is calling for bird-friendly glass to become the new industry-wide standard.”

London Plan suggests impact assessment of tall buildings

While no council contacted by Dezeen currently has any bird-friendly guidelines in place for new development, the London borough of Waltham Forest said it is developing a new local plan with a policy relating to the development of tall buildings, in which bird strikes are highlighted.

The proposed Policy 57 notes that where high-rise buildings are constructed, the “harmful environmental impacts in relation to wind movement, solar glare, microclimatic conditions, air, noise and light pollution and bird and bat strikes” should be avoided.

This clause echoes Policy D9 of the London Plan 2021, which was flagged by the London boroughs of Ealing, Havering, Hillingdon and Bromley as the only planning policy guidance relevant to bird strikes.

Released in 2021, the London Plan is a strategy developed by mayor Sadiq Khan to offer a framework for how Greater London should develop over the next 20-25 years. Policy D9 suggests that the impacts of tall buildings on birds “may need to be taken into consideration” when in development.

“For example, the impact of new tall buildings in proximity to waterbodies supporting notable bird species upon the birds’ flight lines may need to be considered,” reads the supporting text.Read:Eight ways to prevent birds flying into buildings with glass facades

However, both the London Plan and the emerging local plan of Waltham Forest do not explicitly prevent potentially harmful buildings from being constructed or offer suggestions for how they can be made more bird-friendly.

Both these policies also only refer to the development of tall buildings in the boroughs. However, according to Melissa Breyer, a volunteer for New York City wildlife charity NYC Audobonbuilding heights are not a key factor in bird deaths.

“The main culprit is definitely a reflective surface,” she told Dezeen earlier this year, indicating that even low-rise buildings can be hazardous to birds.

“Almost all of these [bird strikes] are happening at the treeline because that’s where the habitat is reflected,” she continued.

Bird-friendly legislation more stringent in US

Unlike in the UK, city officials across the US have begun introducing more stringent guidelines to prevent bird collisions with buildings as awareness of the issue increases.

This includes Local Law 15 in New York City, a bill introduced in 2019 that requires the surfaces of new glass buildings over 23 metres (75 feet) tall to be patterned to make them more visible to birds.

However, existing glass buildings in the city continue to pose problems for migrating birds. In 2021, Breyer made headlines when she collected the corpses of over 200 birds that had flown into buildings at the World Trade Center.

In a single day, she found 226 carcasses from the pavements around the 3 World Trade Center tower designed by Rogers Stirk Harbour + Partners and 4 World Trade Center tower by Fumihiko Maki.

At the time, Breyer said she identified many more, but that they were “inaccessible, or too mangled to collect”.Read:Billions of bird deaths due to the “simple indifference” of architects says PETA

Elsewhere, a bill was filed in Washington DC calling for new buildings in the city to be designed with products that deter birds from colliding with their glass surfaces.

Since being proposed earlier this year the bill has been widely supported in the city, according to the local organisation City Wildlife.

Its president Anna Lewis told Dezeen that the bill “will be highly effective” in solving the problem of bird collisions.

“We need to appreciate that these collisions are not random, that our building designs are causing them, and that there are simple fixes that can prevent these tragic collisions,” she said.

@lucyfrazermp @joannaaverley How to Stop the Already Started Collapse in Local Plan Making and Agreement

It has already started, meetings to agree local plans for submission are being cancelled up and down the country, even to agree reg19 draft plans, the incentive of a 4yHLS not being enough, many authorities want to be seen as abandoning large housing sites and Green Belt releases before the May elections, as Hertsmere and Ashfield have done, as the 4 year rules only applies to out of plan sites, not to the 15 year requirement for sound plans, hence it is a silly incentive that incentivizes nothing except planning application refusals.

A proper incentive would be to only apply the new standard method only if and when a local plan is adopted, to carry on with plan making, and where necessary review plans once they are adopted. Less housing but at the very least at least it wouldn’t further incentivise the ongoing collapse of plan making.

Will the New NPPF Weaken the 5 year Housing Land Supply Test at All

The statement is mystifying

Places with existing plans will benefit from the changes above, as they will be free of five-year land supply obligations provided that plan is up to date.

But this is what para 11.d says

For decision-taking this means: c) approving development proposals that accord with an up-to-date development plan without delay; or d) where there are no relevant development plan policies, or the policies which are most important for determining the application are out-of-date8, granting permission unless: i. the application of policies in this Framework that protect areas or assets of particular importance provides a clear reason for refusing the development proposed7; or ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.

So the ’tilted balance’ 11d already only applies when a plan is out of date which can include when there is no 5yhls (footnote 8)

This includes, for applications involving the provision of housing, situations where the local planning authority cannot demonstrate a five year supply of deliverable housing sites (with the appropriate buffer, as set out in paragraph 74); or where the Housing Delivery Test indicates that the delivery of housing was substantially below (less than 75% of) the housing requirement over the previous three years.

So what is the change? Perhsp ensuring that plans in first 5 years are not out of date even if no 5YHLS. A plan can be out of date btw for various reasons such as going out of time and 11d applies even if there is a 5YHS. So it is important to distinguish automatically out of date and when lack of a 5YHLS triggers being out of date.

Dropping ‘Justified’ Test will lock residents out from objecting in plan examinations

Housing Today

[changes] will include the government reviewing the soundness test for local plans so they no longer have to be “justified”, and therefore will need to meet a lower bar to be adopted.

Letter to Mps

As the Prime Minister committed in the Summer, I will also review how the ‘soundness’ test for reviewing plans at examination is operated by the Planning Inspectorate. I will ensure that plans no longer have to be ‘justified’ , meaning that there will be a lower bar for assessment, and authorities will no longer have to provide disproportionate amounts of evidence to argue their case.

NPPF Para 35

Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;

Suggested before as a way of making even terrible misconceived – lets put no housing allocations in te leaders ward – type plans get through. No need to have examinations then just go straight to JR for a plan not considering the SEA directive and better evidenced alternatives, heyt who needs evidence – get the lead members to write it in a smoke filled room over the weekend,putting all the housing in the oppositions area – they wont be able to object at the examination then.

There was never a test that evidence was siproprtionate – quite the opposite it had to be proprtionate.

Wont last 5 minutes.