This follows representations made on the previous two NPPF consultations (January 2021 and March 2023) and Planning White Paper and Changes to the Planning System consultations in October 2020.

In July, we assessed what the Labour government’s proposed reforms meant for NPPF and Standard Method for Housing in a blog, with our first thoughts around the proposed Standard Method calculation included in our response in relation to it being used as a starting point for assessing housing need for Local Authorities.

To support our submission, Savills Residential Research prepared analysis of some relevant housing and planning matters. Housing is an important component of national policy, though this should not overshadow the importance of other key issues, including mitigating climate change, achieving net zero carbon, planning positively for employment needs, enhancing green infrastructure / the environment, ensuring high quality design, planning for healthy communities and further embedding social value as part of the planning system.

All are key themes, which a more comprehensive review of national policy should address.

It is our view that the NPPF has provided a fundamentally more practical approach to conveying national planning policy since its inception in 2012. The streamlined approach to policy is to be commended, as is keeping it up to date.

We support the government’s objectives of sustained economic growth, delivering more homes through sustainable development, building pride in place and a focus on stability, investment and reform. We also welcome the direction of travel of the proposed changes.

Whilst the focus of the NPPF Revision, and consultation questions is on housing, we have made wider comments on economic development and employment, viability, renewable energy provision, design and beauty, flood risk, social value and health.

We also highlight the matter of ongoing planning reform, notably if/how/when those measures that the previous government outlined in the Levelling Up Act are to be introduced, and also how/when Local Growth Plans will happen.

Our response can be read in full here, but a summary of some of the points that have been made within include the following introductory comments:

• On housing targets, we welcome the government’s commitment to a housing target of 1.5 million new homes over the Parliament (300,000/year) and support the objective of ensuring every Local Planning Authority (LPA) has an up-to-date Local Plan.
• We agree with the consistent use of the Standard Method for determining housing need and support deleting the non-evidence-based ‘urban uplift’ from paragraph 62. We also support the new Method, based on existing stock plus appropriate uplift (equating to a target of circa 370,000 homes permitted/year across England).
• We consider it of critical importance that a standard method is included within national policy for employment uses too.
• The reintroduction of the rolling five-year housing supply requirement and robust testing of Local Plans to ensure they remain up to date is one that we support. A five-year employment land supply should be required also.
• We support retaining the presumption in favour (paragraph 11) and have suggested that the introduction of Footnote 8 alone should suffice without changes to paragraph 11d.
• On the topic of affordable housing and viability, we have emphasised the need for a balanced mix of sites, including the private rented sector in affordable housing definitions, and urges caution with a one-size-fits-all approach to viability. We have, though, urged caution in respect of the approach to viability outlined in Annex 4.
• In respect of the proposed transitional arrangements we have requested a defined programme (30 months) to undertake a Local Plan review. Further guidance will be required on the relationship between Local Plans and Local Growth Plans.
• We advocate for strategic planning at the relevant economic scale and in respect of neighbourhood planning, suggest reverting paragraph 14 to earlier NPPF versions to enable targeted housing delivery.
• We support prioritising brownfield sites for development, amending the definition of previously developed land, and releasing ‘Grey Belt’ land where it does not undermine Green Belt objectives.
• On renewable energy and climate change, we are in support of the transition to a net zero carbon economy and calls for comprehensive national planning policy on carbon emissions and renewable energy projects.
• We have highlighted the importance of embedding social value and health considerations in planning policy to address societal changes and health care challenges.

In summary, Savills largely supports the changes put forward in the consultation draft, which reverses the previous NPPF but still an absence of economic land supply might constrain growth and we need the consultation version to be adopted quickly, to allow decision makers to boost development and land supply. The development industry also needs stability, so an update on the rest of the reforms put forward under the Levelling Up and Regeneration Act would be welcomed.