UPDATED: Proposed reforms to the NPPF

On 30 July, the Ministry of Housing, Communities and Local Government released a draft update to the NPPF and other planning changes. The consultation closes 24 September 2024.

Our response

Transport for New Homes has seen a very large number of sprawling car-dependent housing estates built on greenfield land away from jobs, services and public transport. These add substantially to traffic and congestion on our roads.

We cannot simply build more of the same; however the proposed updates to the NPPF risks doing just that, in the process compromising many of the government’s other goals on sustainable transport and the environment.

Infrastructure guarantees for green belt will not extend to most housebuilding

We are pleased to see guarantees of infrastructure, including adequate public transport and nearby amenities, for green/grey belt development. However, most housebuilding is on greenfield land not designated as green belt and will not benefit. At a minimum, the infrastructure guarantees must apply to all greenfield development, not just green/grey belt.

High housing targets in rural areas that are lacking in public transport

We are concerned that the housing need figures accompanying the proposed NPPF are calculated in isolation without taking account of local economies, employment, access by public transport, or the additional traffic on our road network. 

More ‘cowpat’ estates on the way

Central government is suggesting local authority targets direct hundreds of thousands of new homes to rural parts of the country which are the very places where car-dependent ‘cowpat estates’ will in most cases be the default. Future choices for people looking for somewhere to live, but not wanting a lifestyle around driving and wanting to live closer to work, friends and family, risks being limited.

We need a re-think – genuine planning not a numbers game

The updated NPPF as proposed, will not deliver and needs a fundamental re-think. We need instead, genuine planning reform with an integrated planning strategy for England at regional or sub-regional level, a strategy which matches jobs and services to new homes and expands urban areas with new suburbs and satellite towns served by existing and new metro, tram and bus networks. 

Transport for New Homes have seen many good examples of transit-oriented development in Europe, with new homes around metros, trams and segregated bus routes, with cycling and walking networks all part of the vision. 

A different model of development

With a new focus on urban areas rather than greenfield sprawl, new-build would also be at higher densities including for example, European-style low to mid-rise apartments and designed around the transport needs of pedestrians, cycling/wheeling. 

The higher density of population with far less land for roads and parking, enables innovative urban design around small parks and green squares. It renders shops, cafes, amenities and public transport viable. Other European countries are building in this way as part of a more sustainable future.

Public transport integrated into new development means people can get to work, colleges and university, and a variety of amenities without having to drive.

Opportunities for genuine planning reform missed

We hoped that the new NPPF would encapsulate this kind of modern thinking in town planning. However, unfortunately, it misses these exciting opportunities almost completely. Let us hope that a better approach can be adopted, working in a wider context of bringing together new homes, sustainable transport, access to jobs, good urban design and early consideration of all aspects of environment – a holistic approach to planning that builds new homes in the right places for the people who need them.

Your responses

We recommend responses that call for infrastructure guarantees to apply for all greenfield development and not just green/grey belt. Otherwise, these updates to the NPPF will not achieve their aims. More broadly, it is time for a completely different approach explicitly oriented around transit.

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