Principle concerns are highlighted below

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These responses seek to take a fair and balanced approach to the consultation – favouring no ‘one-side’ and seeking to ensure any eventual changes bring about sound and logical changes to the system. 

It is, nevertheless, important to re-emphasise the scale of the issues facing the UK in the delivery of sustainable development. There can be no debate that we are in the midst of a housing crisis – meaning there is not enough housing to meet the needs of the population:

• The system, as a whole, has failed to deliver adequate development to sustain the needs of the population. It is not one sector, or part of the sector that is to blame – there are many elements that need to
• work better, faster, with clearer goals and targets;
• There is no clear and realistic vision at the national or local level to ease the housing crisis;
• The economic, social and environmental problems, inequalities and inequities relating to the housing market and quality of the existing stock are getting worse, not better;
• The national annual housing target of 300,000 dwellings has never been achieved since it was set;
• The result of demand continually exceeding supply is rising costs and reduced affordability for those buying, renting or running a home;
• Applying national averages, in order to buy a home it will require lending equivalent to 9.4 times average incomes, which has risen steadily from 3.5 times income in 1997. It is not possible to borrow at this rate;
• The impact of this affordability crisis is felt disproportionately by the young and the poorer in society; and 
• There is a clear evidential link between the state of the housing market and fertility: fewer births, can be linked directly to the affordability of housing stock - creating a vicious circle of social and economic decline.

Any resolution to these issues is likely to result in the need for a suite of genuine problem-solving policies that will be unpalatable to some. We witnessed an ‘uprising’ by a number of marginal MPs prior to the publication of the proposed package of reforms and changes to the NPPF. The effect of this was to seek to ‘water-down’ elements of the proposed reforms. We do not consider that the package of reforms as originally tabled would have been sufficient to address all of the issues identified above. This requires root and branch reform. It should be based on a responsible governmental resolution to the problem. It should not be impacted by a short-term political purview.

One of the unfortunate effects of the proposed reforms is that they have created a hiatus in the delivery of Local Plans. This has widened the gap that currently exists between the delivery of up-to date Local Plan, and full national coverage.

Any proposed changes to the system that would, whether by intention or otherwise, place the delivery of sustainable development at risk, or act to supress it, should not be progressed.

We welcome the opportunity to engage further on these critical matters, as the provision of development in the right places and at the right time is critical to the delivery of sustainable development. In turn, the delivery of sustainable development is critical to the future economic stability of the country and the delivery of a socially responsible and fair society.

The Government is set to respond to the consultation in ‘Spring 2023’, adopting the NPPF revisions as part of this exercise, which suggests that these significant changes will not be properly considered.

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