Letter Templates

Please respond to proposed changes in Planning Policy (by 11.45pm on 2nd March 2023)!

If the link in the other page doesn’t work for you, please email the below addresses. You can copy and paste the text, but make any changes or additions as you see fit. If the letters are individual they have more impact.

PlanningPolicyConsultation@levellingup.gov.uk

I am writing to you to voice my support for many of the proposed changes to national planning policy. Please can this email be treated as my response to the consultation.
I am very encouraged by the changes proposed for the Levelling-Up Bill, particularly:

•The changes to be made to the housing numbers generated by the standard method (through using up to date population projections rather than the out-of-date ones currently used)
•The ending of the obligation on local authorities to maintain a rolling five-year supply of land for housing
•The rebalancing of the relationship between local councils and the Planning Inspectorate, in making the numbers generated by the Standard Method ‘advisory’, giving local communities a greater say in what is built in their neighbourhood, increasing the power of local and neighbourhood plans, along with other proposed changes to the system under which local plans are developed
•Measures to ensure that developers ‘build out’ the developments for which they already have planning permission
•The emphasis on ‘brownfield’ first

However, there are a number of issues that are not included in the proposed changes which I would ask you to consider, particularly:

•It is not at all clear what ‘advisory’ actually means. It has been suggested that the following sentence is put into the new National Planning Policy Framework (NPPF) ‘The outcome of the standard method is an advisory starting-point for establishing a housing requirement for the area’. However, there is nothing to define what advisory means. This will cause confusion. As it stands the inclusion of the word advisory hasn’t really changed the meaning of the relevant paragraph in the current policy document. The sentiments in the statement made by Michael Gove on 6th December 2022 should be included in the policy document. For instance, Mr Gove explicitly said that the numbers produced by the Standard Method ….. ‘should, however, be an advisory starting point, a guide that is not mandatory’. This would provide Local Authorities with much more clarity and certainty.

•Why is the Standard Method formula not being revised? At the moment the formula includes an ‘affordability factor’ which can significantly increase the housing numbers for local authorities where house prices relative to average earnings are particularly high. The rationale for having the ‘affordability factor’ as part of the formula is that more houses being built in these high house prices areas will reduce prices, making them more affordable for those who really need houses. However, there is no evidence to indicate that this is the case. Also, one of the key tenets of government policy at the moment is levelling up. However, the use of the affordability factor in the Standard Method runs directly contrary to this. London and the Southeast are the most prosperous (and crowded) regions in the UK. The emphasis of housing policy should be to encourage population growth, and hence the development of economic activity, in less prosperous parts of the country. The existence of the affordability factor is achieving the very opposite of this.

So long as the sentiments of the Secretary of State’s statement made in December are actually reflected in the legislation then I am very supportive of the changes highlighted above, and I strongly urge you to consider the important omissions in the proposed changes.

Yours faithfully