From Policy to Permissions: What the Revised NPPF Must Deliver

“We welcome the introduction of a clearer, more rules-based NPPF, with a stronger presumption in favour of development in the most sustainable locations and a renewed focus on delivery. Measures such as a permanent presumption for suitably located development, a ‘default yes’ around railway stations, and clearer expectations on urban intensification should help reduce delay and uncertainty, increase developer confidence, and unlock much-needed new homes.

In particular, we support the strengthening of the presumption in favour of suitably located development. This should give local planning authorities greater confidence to accept the principle of development and focus decision-making on delivery and quality, front-loading certainty for developers, especially on previously developed urban land.

The emphasis on building homes around railway stations is long overdue, and we support the proposed ‘default yes’ approach. However, minimum density expectations must allow sufficient flexibility to respond to local context, including heritage and townscape considerations, flood risk, site capacity and the availability of deliverable infrastructure. Similarly, higher-density suburban development must continue to meet established NPPF tests relating to residential amenity, parking and design code expectations.

We welcome the intention to reduce duplicated and inconsistent local standards. This should help speed up plan-making and the determination of applications, giving certainty to applicants.

Finally, we also support the stronger emphasis on bringing forward small and medium-sized sites, including the introduction of a new ‘medium development’ category. However, proposals to allow cash-in-lieu affordable housing contributions will only work where there are clear, robust safeguards to ensure this does not simply displace on-site affordable housing delivery.”