LGA submission to the Ministry of Housing, Communities and Local Government on the National Planning Policy Framework and National Model Design Code

Whilst we support an increased focus on design, we are concerned that because ‘beauty’ is subjective, striving for, or allowing ‘beautiful’ development to be fast-tracked may not lead to the quality homes and places communities want and need. Councils need tools that will empower them to create great quality homes and places and stop poor development, rather than supporting those deemed to be ‘beautiful’.


About the Local Government Association

The Local Government Association (LGA) is the national voice of local government. We are a politically-led, cross party membership organisation, representing councils from England and Wales.

Our role is to support, promote and improve local government, and raise national awareness of the work of councils. Our ultimate ambition is to support councils to deliver local solutions to national problems.

Summary

  • The LGA welcomes the opportunity to respond to this consultation on the draft revised National Planning Policy Framework (NPPF) and draft National Model Design Code (NMDC). We have also responded to recent consultations on the Planning for the Future White Paper, Changes to the Current Planning System, and Supporting Housing Delivery and Public Service Infrastructure.
     
  • We support changes to the NPPF that will clarify policy to address legal issues, changes that remove or amend out of date material.
     
  • We support an increased focus on sustainable development, climate change, and flood risks and agree that UN Sustainable Development Goals need to be reflected throughout the NPPF.
     
  • The timing and purpose of this consultation, which is to implement the Building Better, Building Beautiful Commission (BBBB) recommendations and introduce the NMDC, is premature. The Government’s response to the Planning White Paper consultation will require further consultation on changes to the NPPF, which will also need to align with any new planning legislation. 
     
  • Whilst we support an increased focus on design, we are concerned that because ‘beauty’ is subjective, striving for, or allowing ‘beautiful’ development to be fast-tracked may not lead to the quality homes and places communities want and need. Councils need tools that will empower them to create great quality homes and places and stop poor development, rather than supporting those deemed to be ‘beautiful’.
     
  • We urge the Government to ensure there is more consistency across the NPPF, and that it reflects other policy changes and/or legislative changes such as the forthcoming Environment Bill.
     
  • We do not support the proposal to restrict the use of Article 4 directions to remove national permitted development rights (PDR), as it undermines councils’ ability to make locally-led planning decisions. Permitted development undermines the policies in the NPPF and the intention of the NMDC to create sustainable, well-designed places. It can also fail to meet adequate design standards, avoid contributing to local areas, and create worse living environments.
     
  • Local planning authorities will need the appropriate resources to carry out the meaningful community engagement critical to achieving good planning. They will need to be properly resourced for any additional burdens due to any of NPPF revisions and draft NMDC are being taken forward.
     
  • We do not support the proposed new wording in considering applications to remove or alter an historic statue, plaque or memorial (whether listed or not). Local planning authorities should consider these, and other changes that impact on communities through a locally-led planning system with public participation at its heart, in which councils and the communities have the power and voice to shape their local areas.

Response to individual questions

Chapter 2: Achieving sustainable development


Q1. Do you agree with the changes proposed in Chapter 2?

Paragraph 7

We welcome the reference to the 17 UN Global Sustainable Development Goals (SDGs). We support taking a SDGs focussed approach because it provides an internationally recognised framework, and works at national and local levels, reinforcing existing plans and commitments.  

We welcomed the revised wording to the NPPF in 2018 that emphasised that the three objectives (economic, social and environmental) are interdependent and need to be pursued in mutually supportive ways, and the reference to taking opportunities to secure net gains across those objectives. Whilst some of the SDGs are picked up in part in the NPPF, such as Goal 11 Sustainable Cities and Communities and Goal 13 Climate Action, many of the goals are neither referenced nor identified. We recommend that either each of the 17 SDGs is identified where appropriate throughout the NPPF, or that it is explicitly stated which of the SDGs are indeed part of the NPPF.

Paragraph 8(b)

We do not believe that inserting the word ‘beautiful’ to reflect the BBBB Commission’s recommendation to ‘emphasise the importance of well-designed, beautiful and safe places’ will help in ‘achieving social objectives of sustainable development. The words ‘beautiful’ and ‘beauty’, which are being proposed throughout the NPPF, are subjective and not defined. They may help ‘emphasise the importance of well-designed, beautiful, sustainable places’ but provide no framework or explicit guidance regarding how places and the spaces should be developed. Consulting publicly on what meets a ‘beauty’ threshold in Local Plans will pose a challenge for communities and councils in their decision making. The NMDC is supposed to provide the framework for creating healthy, greener, environmentally responsive, sustainable and distinctive places, with a consistent and high-quality standard of design. However, there is no tenable link or explanation between the subjective terms ‘beauty’ or ‘beautiful’ and how these words will influence the design of, for example, buildings, spaces, places, and the built pattern.

As noted in our response to the Planning White Paper’s proposals for a fast-track for beauty, we would not support the term ‘beauty’ insofar as it will allow for the legislated widening of the nature of permitted development whereby a developer could follow the proposed national pattern book approach, circumventing the usual planning (i.e. Local Plan) process.

Paragraph 11(a)

We welcome the proposed addition for the presumption in favour of sustainable development, in particular the recognition that growth and infrastructure need to be aligned, and the critical need for climate change mitigation and adaptation. Local government plays a leading role in accelerating the shift towards achieving net zero carbon. With nearly two thirds of councils in England aiming to be carbon neutral 20 years before the national target, councils are well placed to support the Government to meet its net zero carbon ambitions by 2050.

Regarding the specific change, we recommend that to be effective, the text ‘in all plans should promote a sustainable pattern of development…’ needs to be replaced with ‘in all plans will be required to promote a sustainable pattern of development’. We also recommend that ‘sustainable development’ needs to be defined. However, the LGA has argued that the threat of presumption of sustainable development should be replaced with other more positive measures, such an offer for external expert advice on local action planning. Any new accountabilities must be accompanied with tools to deliver.


Chapter 3: Plan-making

Q2. Do you agree with the changes proposed in Chapter 3?

Paragraph 22

We support the proposed change that consideration for the location of larger scale developments should be set within a vision that looks ahead by at least 30 years and take into account the likely timescales for delivery. Local planning authorities should have the ability to set the direction for how their area will grow and develop over the next 30 years. This longer timeline allows for better long-term planning, allowing for the appropriate flexibility and certainty, and to ensure the investment and infrastructure funding pipeline will be sufficient and meet requirements.

We have continued to raise our concerns with the Government’s standard method for housing need since its introduction. We were also disappointed that the Government did not consult on the more recent proposals for the method in December last year. That said, we recommend that the 20 cities and urban areas identified by the Government that will be required to increase their 5-year land supply expectations by 35 per cent as part of the new standard method are allowed to be defined as larger scale developments. This could facilitate better long-term planning and alignment of public service facilities and social infrastructure requirements such as libraries, schools, hospitals, sports and leisure centres, and open space through a locally-led planning system rather than through ad hoc permitted development as proposed recently by the Government.

We are still concerned that local authorities with a Local Plan that do not have a 5-year housing land supply or are unable to meet the national Housing Delivery Test will be subject to the national presumption in favour penalty. The evidence shows  that councils are approving nine in 10 planning applications and over a million homes already allocated in Local Plans waiting to be taken up by the development industry. Our recent analysis, compiled following a survey of council heads of planning, estimates that more than a third, or 1 million of the 2.7 million homes allocated in current Local Plans in England have not even been submitted into the planning system.

Councils need powers to incentivise build out of homes that have been approved and also need powers to bring forward land that is allocated in Local Plans. We urge the Government to scrap the presumption in favour of sustainable development which leaves councils exposed to speculative planning applications for development outside of the Local Plan. This potentially results in homes that do not meet local needs, in places where they are not needed and undermines community trust in the planning system.


Chapter 4: Decision making

Q3: Do you agree with the changes proposed in Chapter 4? Which option relating to change of use to residential do you prefer and why?

Paragraph 53

No. We do not support the proposals to restrict the use Article 4 directions ‘where they relate to change of use to residential’, as this will remove a local planning authority’s ability to make local decisions based on local need. Councils need the powers, tools and resources to be able to shape vibrant places for their local communities with a mixed offer including retail, culture, and sport and leisure provision. Councils use Article 4 directions for a range of reasons, including tackling issues relating to the change of use of dwellings to Houses in Multiple Occupation (HMO). We seek clarification on what situation of ‘national significance’ would require removing the use of an Article 4 direction. The proposal for Article 4 directions to apply ‘in all cases to the smallest geographical area possible’ further undermines the ability for a local planning authority to make appropriate decisions for that area.

The Government’s own research showed that PDR can fail to meet adequate design standards, avoid contributing to local areas, creates worse living environments, and undermine or fail to deliver the ‘good design and beautiful places’ that these NPPF changes intend to promote. The report also found that PDR undermined councils’ ability to bring about positive changes to places by limiting their influence to repurpose town centre assets. PDR neither supports nor aligns with the Government’s aspirations which we support and are outlined in the Planning White Paper, including greater democratic accountability and transparency, tackling climate change, improving biodiversity, protecting our heritage, planning for beautiful and sustainable places, and developing the necessary and high-quality infrastructure and affordable homes we need. 

If the Government’s recent proposals to extend PDR go ahead, allowing conversions to residential use in, but not limited to, high streets and town centres, this will erode councils’ ability to also lead their recovery from the pandemic. As we said in our response to the Supporting Housing Delivery and Public Infrastructure Delivery consultation, councils have already been working hard to repurpose their high streets and town centres and respond to longer-term trends in how they are used. Previous conversion of office to residential use has already led to the loss of business activity and its contribution to local economies and community vitality. This could also undermine councils’ existing high street recovery plans, and weaken the Government’s recent funding commitments of £830 million to 72 recipients through the Future High Streets Fund, and £3.6 billion to 45 recipients through the Towns Fund, which are intended to support economic regeneration of deprived towns by renewing and reshape town centres and high streets.

Before any changes are made to Chapter 4 the Government should also consider the alignment with other chapters potentially impacted by this change, including, but not limited to: Chapter 5: Delivering a wide choice of high quality homes; Chapter 6: Building a strong, competitive economy; Chapter 7: Ensuring the vitality of town centres; Chapter 9: Promoting sustainable transport; 12 Achieving well-designed places.


Chapter 5: Delivering a wide choice of high quality homes (consultation document)/Delivering a sufficient supply of homes (draft NPPF)

Q4. Do you agree with the proposed changes in Chapter 5?

The title of Chapter 5 in the NPPF, ‘Delivering a sufficient supply of homes’ differs from that in the consultation document, ‘Delivering a wide choice of high quality homes’. We seek clarification regarding which is the correct heading and purpose of Chapter 5.

Paragraph 65

While we welcome clarification that ‘at least 10 per cent of the total number of homes to be available for affordable home ownership’, this still risks displacing provision of genuinely affordable homes, for example social/affordable rented homes. As we said in our 2018 response the NPPF consultation, we do not agree with a minimum national requirement. It remains our view that local planning authorities, through their local plans, should determine any site size threshold and proportion of affordable home ownership units that are required on sites based on their objectively assessed need and taking into account site viability.

Paragraph 70

We welcome the amendment clarifying that neighbourhood plans groups should also give particular consideration to the opportunities for allocating small and medium-sized sites suitable for housing in their area.

Paragraph 73

We welcome the new wording that reflect a ‘genuine choice of transport modes’ as a part of the infrastructure needed to support large scale housing development. An integrated approach that brings together and promotes mainstream cycling across all planning scales will support better health and wellbeing and decarbonise our transport network.

Paragraph 80(e)

We seek clarification regarding why ‘innovative’ has been removed, when Chapter 12: Achieving well-designed places, states that ‘innovative designs which promote high levels of sustainability’ must be considered for development (paragraph 133b). Further, there is a missed opportunity to address the need for low carbon and zero carbon housing to achieve the Government’s 2050 net zero target, aligning with the interim uplift and longer term changes to domestic and non-non-domestic dwellings proposed in the Future Homes Standard and Future Buildings Standard.


Chapter 8: Promoting healthy and safe communities

Q5. Do you agree with the changes proposed in Chapter 8?

Paragraph 92(b)

Yes. We welcome the amendments to the policy wording that reflects the support for safe and accessible cycle routes as part of a sustainable approach to transport. Recognising the role that supporting cycling can play in decarbonising our transport, and a climate smart recovery from COVID-19, we developed guidance outlining the most cost-effective interventions councils can make to build an inclusive local cycling culture and safe, healthy facilities for cycling.

Paragraph 97

We support the amendment to address both climate change and the health and wellbeing of our communities through the use of open space. Our Developing Healthier Places guide provides information about how councils can work with developers to create places that support wellbeing.


Chapter 9: Promoting sustainable transport

Q6. Do you agree with the changes proposed in Chapter 9?

Yes. Councils should be using latest national guidance. This includes alignment with the NMDC and Manual for Streets, which is currently being updated.

Councils are keen to promote more sustainable transport but also recognise that every place and its travel needs are different. The issues they are trying to address vary from place to place – be it tackling air quality and congestion, improving accessibility, encouraging and supporting active travel or ensuring sufficient EV chargepoints. They therefore require maximum local flexibility to shape their transport infrastructure, including reallocating road space appropriately. Councils are also keen to play a role in decarbonising our transport networks through the avoid/ shift/ improve model. For instance, encouraging people to avoid travelling (via private car) where possible, to shift onto sustainable transport (such as public and active travel), and where there are limited alternatives, to travel in low emission ways (e.g. EV cars).


Chapter 11: Making effective use of land

Q7. Do you agree with the changes proposed in Chapter 11?

Paragraph 124

We support the new wording in this paragraph.


Chapter 12: Achieving well-designed places

Q8. Do you agree with the changes proposed in Chapter 12?

Paragraphs 126-128

We welcome the new wording regarding the requirement for local authorities to produce design policies, guides, and codes consistent with the principles in the National Design Guide, National Model Design Code, and reflecting local character and design preferences through community engagement. However, we are concerned about the additional resources this will require. Councils will need the necessary resources to upskill officers to undertake the transition process locally and then implement both the new planning regime alongside developing a new design guide. According to Public Practice, local planning authorities will need forward-funding to upskill and produce and deliver local Design Codes at scale. They also found that the cost of adopting a Design Code for an area of approximately 1000 homes has been estimated at £139,000.

We have previously argued that genuinely constructive public engagement will take longer than the timeframes proposed in the Planning White Paper for completing Local Plans. Local democratic oversight and community engagement are critical factors in ensuring trust and transparency in planning decisions and all aspects of the planning system. Genuine public engagement will provide a community with an agreed understanding about how planning decisions and anticipated design outcomes will impact on their immediate and wider area.

We caution that allowing permitted development, especially the recent sweeping proposals, are an ad hoc and disconnected approach to planning that will undermine proposals for well-designed places.

Paragraph 130

We welcome new wording to ensure that streets are tree-lined, and that existing trees are retained wherever possible. Tree-lined streets must be in addition to, and not instead of, parks and open space. Trees play an important role in addressing our climate challenge, sequestering carbon, and cleaning the air by binding CO2 and exhaust particles. Trees can also play an important role by creating urban forests or ‘green lungs’ that help to cool cities down.

We would welcome both the retention of and recognition of the important role of trees and hedges in the street scene. Studies have shown that hedges can minimise pollution levels and exposure to traffic emissions and maximise the potential for other ecosystem services (e.g. noise pollution reduction or biodiversity support). Particularly around schools this can mitigate the exposure of traffic pollution to children.


Chapter 13: Protecting the Green Belt

Q9. Do you agree with the changes proposed in Chapter 13?

We have no specific comments on this proposal.


Chapter 14: Meeting the challenge of climate change, flooding and coastal change

Q10. Do you agree with the changes proposed in Chapter 14?

The aims of the NPPF and the new national Flood and Coastal Erosion Risk Management Strategy (FCERM) must be coherent, and they must work together to provide a clear framework for development in areas of flood risk. It is welcome that further thought has been given to this question and that the NPPF has been amended to reflect of the principles at the heart of the FCERM strategy.

For the aims of the NPPF to succeed, there needs to be a stronger alignment between planning for housing development and investment in flood defence. This is particularly relevant as the revised NNPF asks planners to consider the risk of funding “from all sources”. This makes it more important than ever that investment can be secured from a wide range of sources, not just the Environment Agency and local authorities.

The Public Accounts Committee on Managing Flood Risk noted that responsibility for surface water flooding sits with Lead Local Flood Authorities, who are dealing with the consequences of increased surface water from new development. The committee recommended that Defra’s joint review with MHCLG of planning reforms and flood risk “should consider approaches to ensure developers guarantee property can be insured and contributes to flood mitigation measures. There is also a disconnect between the developers who financially benefit from new housing developments and those who face the consequences of it not being sustainable or insurable”. Further thought needs to be given to the implementation of the revised NPPF and the LGA would be happy to work with the Government on this.

The Government should go further to avoid operating in departmental siloes on flood risk, climate change and planning. That is why we want to work with government to establish a national framework for addressing the climate emergency. This must set out a clear articulation of the national role and local roles, and an assessment of funding and financing opportunities through public and private sector means.


Chapter 15: Conserving and enhancing the natural environment

Q11. Do you agree with the changes proposed in Chapter 15?

We have no specific comments on the revised wording of this chapter. Looking ahead to the implementation of the Environment Bill, the introduction of biodiversity measures may require further amendment to the NPPF. We welcome clarity on the timetable for the implementation of these measures and a full assessment of the impact on local authorities.


Chapter 16: Conserving and enhancing the historic environment

Q12: Do you agree with the changes to proposed in Chapter 16?

No. We are concerned that wording in the current draft seeks to impose a particular approach to this issue over alternatives that may be chosen by communities, by emphasising the importance of retention over other issues that need to be considered in individual cases. We therefore suggest the word ‘importance’ be replaced by ‘possibility’ or ‘the case for’. This would maintain the Government’s objective of ensuring retention is considered, which we agree it should be, without implying that other considerations, which may be more important to the affected community, should be given less weight.

The LGA believes that in considering applications to remove or alter an historic statue, plaque or memorial (whether listed or not) that local planning authorities should consider these changes through a locally-led planning system with public participation at its heart, in which councils and the communities have the power and voice to shape their local areas. We recently raised the point, in our responses to the Planning White Paper and  Supporting Housing Delivery and Public Service Infrastructure consultation, that in contrast, decisions such as permitted development are made without community input and therefore undermine councils’ and their communities’ ability to make local decisions for local needs. As the LGA’s advice on Responding to calls for public realm changes states, ‘all sections of the community have to feel heard by decision-makers, but also by each other’. The best approach to addressing contested historic commemorative structures can therefore only be decided locally, taking into account the views of the local community.


Chapter 17: Facilitating the sustainable use of minerals

Q13. Do you agree with the changes proposed in Chapter 17?

We welcome clarification of references and amendments proposed in relation to Mineral Consultation Areas in paragraph 209(c) and the extraction of building stone in paragraph 210(b).

Annex 1-3

Annex 1: Implementation

Housing Delivery Test

Whilst we appreciate the clearer wording regarding the Housing Delivery Test (HDT) arrangements we continue to have concerns with the Government’s standard method for housing need and the resulting figures it produces for local areas. In particular, the methodology is not responsive to the complexity in local housing markets, and there are implications of using the resulting numbers as a target within the HDT and the subsequent sanctions if these are not met. We have previously argued that the HDT is inherently unfair, in that it penalises councils and the communities that they represent when factors outside their control have limited housing numbers (for example unbuilt planning permissions).

Timeframes and resourcing

We welcomed the Government’s statement in the Planning White Paper (paragraph 5.2) that they would ‘consider the arrangements for implementing the reforms changes will be considered to minimise disruption to existing plans and development proposals and ensure a smooth transition’. We therefore recommend that a timetable is published as soon as possible to provide certainty about further consultation on the NPPF, upcoming planning consultations, and the overall progress with the Planning White Paper response. This will help councils already struggling with the impact of COVID-19 to undertake the transition process with as little disruption as possible.

Planning departments are already under-resourced and will need greater resourcing to implement the planning reforms. Between 2010-11 and 2017-18 there was a 37.9 per cent fall in net current expenditure on planning functions and planning departments. Planning fees also do not cover the true cost of processing planning applications, with taxpayers subsidising the cost at a rate of nearly £180 million a year

The Planning White Paper identified a skills strategy for local authorities, and we welcome more information regarding how this will be resourced. There is considerable concern from councils about their already stretched capacity, notwithstanding the need to respond to numerous relevant consultations. Councils will need the necessary resources to upskill officers to undertake the transition process locally and then implement the new planning regime over many years. Planning affects other areas of council business, and any changes to the system will have impacts well beyond planning departments and across all council operations as a whole.


Annex 2: Glossary

Q14. Do you have any comments on the changes to the glossary?

Green infrastructure

We support the expanded definition of ‘green infrastructure’ and recommend that ‘social’ is inserted with the words ‘wide range of environmental, social, economic, health and wellbeing benefits…’

Housing Delivery Test

We support the change of wording to reflect the measurement of ‘homes delivered’ instead of the previous ‘net additional dwellings’.

For clarity, definitions should be provided for ‘sustainable development’, ‘beauty’ and/or ‘beautiful’, and ‘large-scale developments’.


Annex 3: Flood risk vulnerability classification

We welcome the addition of the classification, previously contained within guidance, to give it more weight.

National Model Design Code

Q15. We would be grateful for your views on the National Model Design Code, in terms of:

a) the content of the guidance
b) the application and use of the guidance
c) the approach to community engagement

We welcome the National Model Design Code insofar as design is being considered at a national level with a set of urban design guidelines for councils to use. We support  Government’s testing programme pilots to test aspects of NMDC how it might be applied to different contexts for further development  to inform use of design codes in any reforms to the planning system. We are pleased to see the References to Further Guidance section (pp 42-45) because it provides the user with complementary guides that should be used together with the NMDC.

The recent Future Place partnership report points out that as we recover from the pandemic, quality design of our existing and future homes and places has never been more important. We are therefore disappointed that the NMDC does not mention current context and the impact of existing proposals for more PDR. We reiterate that PDR neither supports nor aligns with the Government’s aspirations which we support and are outlined in the Planning White Paper, including greater democratic accountability and transparency, tackling climate change, improving biodiversity, protecting our heritage, planning for beautiful and sustainable places, and developing the necessary and high-quality infrastructure and affordable homes we need. 

As we stated in response to Question 3 (Chapter 4), if the Government’s recent proposals to extend PDR to allow conversions to residential use in, but not limited to, high streets and town centres go ahead, this will erode councils’ ability to also lead their recovery from the pandemic. As we said in our response to the Supporting Housing Delivery and Public Infrastructure Delivery consultation, councils have already been working hard to repurpose their high streets and town centres and respond to longer-term trends in how they are used.

We are concerned that there is no discussion about the dealing with complexity of local views. The NMDC should go much further in emphasising the need for a process that ensures that the views of an entire community are fairly reflected in local design codes, rather than just the views of a resource-rich vocal minority.

We are disappointed that there is only one positive mention of innovation in the Guidance notes for Design Codes, and none in the NMDC. Innovative design plays an important role in addressing the climate challenge and creating and shaping great places at both local and national levels. Examples of collaborative programmes leading this work include the LGA’s Design in the Public Sector Programme with the Design Council the Net Zero Innovation Programme led in partnership by the LGA and UCL. We are also concerned that there is no discussion about how innovation can be incorporated into the vernacular to achieve more sustainably designed homes and places, to both mitigate and adapt to the effects of climate change.


Community engagement and resourcing

We have previously argued that local democratic oversight and community engagement are critical factors in ensuring trust and transparency in planning decisions and all aspects of the planning system. Genuine public engagement will leave a community with an agreed understanding about how planning decisions will impact on their immediate and wider area. We have already noted our concern about the additional resources this will require. Local planning authorities will need resources to carry out the meaningful community engagement critical to achieving good planning and will need to be properly resourced for any additional burdens due to any of NPPF revisions and draft NMDC are being taken forward.

Councils will also need the necessary resources to upskill or hire new planning officers to undertake the transition process locally and then implement the new planning regime alongside developing a new design guide. According to Public Practice, local planning authorities will need forward-funding to upskill and produce and deliver local Design Codes at scale. They also found that the cost of adopting a Design Code for an area of approximately 1000 homes has been estimated at £139,000.


Office for Place

We welcome further detail about how the Office for Place will operate. We agree with the Government that local communities need to be at the heart of plans, and therefore recommend that the Office must include local government representation and should work closely with local planning authorities. We welcome the opportunity to work with the Government on this.

Public Sector Equality Duty

Q16. We would be grateful for your comments on any potential impacts under the Public Sector Equality Duty

We are concerned that the proposed changes have been put forward prior to conducting any impact assessments. We suggest that impact assessments are undertaken prior to any final recommendations and reflected in any proposals taken forward.

We have previously argued that the pandemic has highlighted stark inequalities within our society. This is especially so in health outcomes due in part to poor quality housing such as PDR, due to poor ventilation, a lack of space standards, and a lack of access to services and green space. PDR also fails to meet adequate design standards, avoid contributing to local areas and create worse living environments. There is a significant body of evidence that points to the negative impact that overcrowding and poor-quality housing has on people, and that our housing is an important determinant of our health. While this affects anyone living in poor quality housing, Public Health England has identified how existing inequalities affecting BAME, for example, have become exposed and exacerbated during the pandemic. The recent Women and Equalities Committee inquiry on the unequal impacts of COVID-19 on a range of different groups highlighted that overcrowding, which is characteristic of PDR, also disproportionately affects the BAME community, low-income household, older persons, renters and those with disabilities.

Permitted development schemes have tended to be located primarily in commercial and/or industrial areas, far more than those with planning permission. The Government’s research found that vulnerable people are being placed in accommodation that falls short of space standards, often in remote locations in the city with poor access to public transport. The research also found that there are noticeable differences in terms of the compliance with NDSS, with only 52 per cent of prior approval units meeting the standard, and poorer Energy Performance Certificate (EPC) performance than for those developed with planning permission. Substandard and poorer quality homes developed through PDR are more likely to be used to house vulnerable people such as those in temporary accommodation.

Additional comment - First Homes

The Government’s summary of responses to the First Homes consultation stated that related planning policy changes would be taken forward through the NPPF along with guidance. However, because First Homes is not included in this current review of the NPPF we seek clarification regarding whether it will be part of the fuller review ‘likely to be required in due course, depending on the implementation of the government’s proposals for wider reform of the planning system’, or through another method.