Introduction
There is an urgent need for places to be resilient to environmental, economic and social challenges. Climate change is the greatest challenge facing our society, and its impacts are no longer hypothetical; the population is already experiencing increased temperatures and severe weather events. Action is needed to reduce carbon emissions and enable places to adapt.
It is also critically important to be aware that the climate, housing and health crises will not affect everyone to the same extent – disadvantaged communities will generally bear the brunt. An evidence review conducted by the Joseph Rowntree Foundation found that lower-income and other disadvantaged groups contribute least to causing climate change but are likely to be most negatively affected by it.
How we create neighbourhoods and manage development is, therefore, important. And it is absolutely clear that planning has a crucial role to play in reducing carbon emissions and in the long-term planning for climate adaptation. The planning system will have a much bigger role in coming decades as we fight to save coastal communities and, in some cases, as we are forced to relocate whole populations as a result of sea level rise. Everyone has a shared common interest in building the necessary resilience to climate change which is the foundation of all economic activity.
That is why we are asking everyone to help us influence the content of the National Planning Policy Framework (NPPF). Proposed changes to this document are currently being consulted on. But, it is currently underwhelming in relation to climate change and we need to tell the Government that the changes must go further if we are to secure the urgent action we need.
Please consider responding to the consultation to help us set out the changes we believe are necessary to deliver on the 2050 net zero target.
How to respond
The deadline for responses is 11.45pm on 27th March.
To respond you need to submit your comments via a questionnaire. But you can answer as many or as few questions as you would like to. The questionnaire is available at: National Planning Policy Framework and National Model Design Code: Consultation proposals – Ministry of Housing, Communities and Local Government Citizen Space – Citizen Space
The draft National Planning Policy Framework, which is being consulted on is available at: Draft NPPF for consultation (publishing.service.gov.uk)
Developing your response
Via the questionnaire you can comment on all of the changes proposed to the NPPF but not the sections where it is proposed they remain as they are.
You can choose to comment on as many or as few proposals as you would like to. But you will have to respond to the section entitled ‘privacy notice’ and ‘a bit about you’.
Because of our concern about the Westminster Government’s lack of action on climate change, and the structure of this consultation, we are encouraging as many people as possible to respond to the consultation raising this specific issue.
Responding to ‘proposed changes to chapter 2’
The proposed changes to chapter 2 are broadly fine but they risk being too high level to ensure meaningful change in practice. So, we are asking people to respond to this consultation and call on government to go further.
Suggested response to question 1, ‘do you agree with the changes proposed in chapter 2?’
Please select ‘no’.
In the comments section, please consider stating:
While the recognition of the UN Sustainable Development Goals [paragraph 7] and proposed insertion of mitigating climate change into the plan-making section of the presumption in favour of sustainable development [paragraph 11a] are welcome the proposed amendments are currently a major missed opportunity for the Government to demonstrate action in relation to climate change.
The proposed changes in this section need to go further if the Government is to make sure the planning system delivers on the objectives of the 2008 Climate Act. The NPPF must ensure that all decisions deliver on the 2050 net zero target providing a clear direction of travel that will drive the transformation in the design, location and energy systems of all new development and the regeneration of existing places.
To this end the NPPF must make plain that all policies, plans and decisions must deliver on the objectives of the Climate Act. To achieve that, the following wording should be inserted into chapter two after the current paragraph eight of the NPPF:
Climate change is the greatest long-term challenge facing the world today. Addressing climate change is therefore the Government’s principal concern for sustainable development. For the avoidance of doubt, achieving sustainable development includes securing the mitigation of, and adaptation to, climate change. All planning strategies, and the decisions taken in support of them, must reflect the Government’s ambition to help business and communities build a zero carbon future and prepare for the impacts of climate change. Accordingly, planning policies and all planning decisions must be in line with the objectives and provisions of Climate Change Act 2008 including the 2050 net zero carbon target.
Any other comments
The TCPA is still working up its full response to this consultation and we recognise there are other issues that many will want to raise.
If you are considering raising other issues, we would ask you to consider raising the following in response to proposed changes to chapter 4: decision making.
Proposed changes to this chapter would make it even harder for local authorities to take steps to prevent permitted development rights being used to circumvent the planning system to deliver potentially poor-quality new homes. As the rights enable the conversation of other buildings to residential use, it also poses risks to the viability of town centres and presents a range of other challenges we wrote about in our report, No place for place-making.
In response to question 3, therefore, relating to chapter 4, we ask people to consider selecting ‘no’ and stating:
In light of the concerns set out in the Government commissioned report on the quality of homes delivered through permitted development rights [published 2020] and the wider concerns about the impact of these rights on place-making I object to all of the proposed changes set out for paragraph 53. Article 4 directions are one of the few tools available to local authorities to shape places and their use should not be limited any more than they already are.
If the Government is serious about seeking to ensure the vitality of villages, towns and cities, and the achievement of health communities, the proposed changes cannot be taken forward into the updated NPPF.
