LGA Independent Group response to the National Planning Policy Framework Consultation 2023

The Independent Group supports the LGA’s cross-party submission to the NPPF consultation. The aim of this response is to emphasise the issues that are important to our members.

About the LGA Independent Group

The Independent Group represents councillors in England and Wales who are Independent, Green or from smaller parties. We provide our members with a voice at the national level and work within the cross-party Local Government Association (LGA) to ensure that the values and interests of our members are represented. The Independent Group is the most diverse group of councillors and the most representative of the public, with 73 per cent of our members not affiliated to a political party.  We harness the knowledge and experience of our members to ensure that we are working effectively and that our voices are heard.

We support the LGA’s cross-party submission to the NPPF consultation. The aim of this response is to emphasise the issues that are important to our Independent Group members.

Key messages

  • While the removal of the 5-year Housing Land Supply has been welcomed by local government as helping to protect local areas from speculative development, it is undermined by the retention of the 3-year housing delivery target. We are very concerned that the target will simply replace the 5-year Housing Land Supply and continue to place speculative pressure on local areas.
  • Although councils will be able to set their own 3-year housing delivery targets, the consultation also reaffirms the government’s target of 300,000 new homes a year by the mid-2020s. The two are not compatible.
  • In some areas, our members have pointed out that it is not just that they cannot build more, but they have no land to build on. As such, any targets should take account of local opportunities for the conversion or refurbishment of existing buildings.
  • The Levelling Up and Regeneration Bill sets out that should there be a conflict between National Development Management Policies (NDMPs) and a local plan, determination would be found in favour of the NDMPs.  Local plans require years of work and consultation with local residents, alongside extensive research and democratic debate. To have this overruled by a one-size-fits-all NDMP that does not take into account the residents’ voice undermines trust in the planning system and its effectiveness.
  • New NDMP’s should only be applied in the absence of a Local Plan and should be a safety net. Government should be setting a baseline upon which local areas build to ensure development is locally appropriate, with the local plan taking precedence. Our members have questioned what assurance will be in place that these new National Policies will receive the same rigorous consultation given to our local plans before implementation.
  • The Viability Test should have been taken into consideration in this consultation as it continues to undermine the local planning system and the will of local people. Despite the creation of local plans through local democracy and local engagement, developers can still prioritise their profit margin over local neighbourhoods and the democratic process.
  • Because the Viability Test allows developers to side-step requirements to improve, for example, the carbon efficiency of homes, it also serves to keep the cost of such technological interventions and sustainable housing methods high as it stifles the market’s response to the demand and need. Because the need for delivery is side-stepped by developers, the initial high costs never come down because the market is not able to grow enough to incentivise competition and bring down costs.
  • The consultation fails to tackle the big national infrastructure issues, instead addressing a number of piecemeal issues, such as fake grass and an ask for ‘beauty’.
  • Beauty is very subjective, time-limited and will struggle with a lack of legal definition. A better aspiration would be to enable residents to live healthy lives in the broadest sense which would include pleasing aesthetics. It should also include access to nearby quality open and green space as well as leisure facilities. There must be sufficient space for living, which includes working, gathering with family and friends, and privacy. Urban and suburban neighbourhoods need easy access to work, leisure, education and health facilities, with special and individual consideration given to the needs of our rural areas.
  • Despite the clear message in Chris Skidmore’s “Mission Zero” review to reform the planning system to put net zero at its heart nationally and locally, the proposals in the consultation do not even go as far as linking with national carbon reduction targets. This is a significant missed opportunity in the Government’s legislative timetable considering the pressing need to act on climate change.
  • There is also no reference to linking up and connecting with transport infrastructure or our national health infrastructure. Unless the Viability Test is removed and we have a useable framework for tackling interconnected issues through planning, we will continue to see the escalation of positive feedback loops putting more and more pressure on public services and our residents. For example, we already see a growing number of our local doctors’ surgeries overwhelmed, more reliance on struggling emergency services and less space in hospitals, as those requiring continued care in the community have nowhere to go.


LGA Independent Group Office – [email protected]

Leader – Cllr Marianne Overton MBE

Head of Group Office – Abigail Gallop