Agenda item

Report of the Director of City Services and Commercial

The Scrutiny Co-ordination Committee considered a report of the Director of City Services and Commercial which outlined the consultation currently being undertaken by the Ministry of Housing, Communities and Local Government on proposed reforms to the National Planning Policy Framework. A copy of the Council’s proposed response had been circulated prior to the meeting.

 

The report indicated that Government is consulting on a series of proposed changes to national planning policy. This includes specific changes to the National Planning Policy Framework (NPPF) and broader reforms relating to planning fees, local plan intervention and the thresholds used for determining applications under the Nationally Significant Infrastructure Project (NSIP) regime.

 

The consultation runs from 30 July – 24 September 2024 and the Government has indicated that a new version of the NPPF will be published before the end of 2024. The report  provided an overview of the proposed changes highlighting where possible, any implications for Coventry.

 

Paragraph 6 of Part 2 A of the Constitution sets out how the Council will respond to Government Consultation papers. Due to the short timescale and complexity, it has not been possible to submit a report to either Council or Cabinet. With the agreement of the Cabinet Member for Housing and Communities and the Chair of the Scrutiny Co-ordination Committee, given the importance and high profile of this consultation and in order to ensure transparency and afford cross party consideration of the response,  it had been agreed that Scrutiny Co-ordination Committee and the Cabinet Member for Housing and Communities will formally consider the proposed response prior to recommending the response to the Leader of the Council, in accordance with the Constitution. The Shadow Cabinet Member for Housing and Communities, Councillor Bailey, attended the meeting and had been invited to attend the Cabinet Member meeting on 20 September 2024. 

 

The report, together with a comprehensive presentation at the meeting, indicated that the consultation proposals have the following significant implications for the City:

 

  I.  Councils at the Regulation 18 stage of their Local Plan (such as   Coventry) will have to prepare their plans against the revised   NPPF unless a Regulation 19 consultation can commence within   one month of the revised NPPF being published. In that scenario,     the emerging Local Plan would be prepared in accordance with   the current NPPF (December 2023).

 

  II.  The requirement for social rented housing from new   developments would be increased, and First Homes would be   removed as an affordable housing tenure. The consultation also   seeks views on the most appropriate way to promote high     percentage social rent / affordable housing developments.   Delivering more affordable housing, particularly social rented   housing, is a Council priority and these proposed changes are     welcomed.

 

  III.  The consultation proposals include various changes to   national Green Belt policies, including introducing the   concept of ‘Grey Belt’ land within the Green Belt.

 

  IV.  The Government proposes changes to the national   method of determining housing need for individual local   authorities. The number of homes the Government     calculates to be needed in the city through the “standard   method” is 1,527 homes per year or 30,540 over a twenty-  year Local Plan period. This contrasts with the current   methodology which suggests 3,081 homes per year or   61,620 over twenty years. These proposed changes align     with the Council’s position and are strongly welcomed.

 

  V.  The housing need figure would become a mandatory   starting point for determining the Local Plan housing   requirement for all local authorities and for calculating 5   Year Land Supply. If the proposed approach is     implemented, it is significantly more likely that Coventry   will be able to demonstrate at least 5 years of future supply.   Government anticipate that some local authorities will be   unable to demonstrate a 5 year housing land supply as a     result, although the Government says, “This is necessary   to ensure that we urgently address the issue of chronic   undersupply of land that has underpinned the housing   crisis and support our drive to deliver 1.5 million new   homes over the next five years.”

 

  VI.  It is proposed to strengthen expectations that plans should   promote an uplift in density in urban areas such as   Coventry.

 

  VII.  Brownfield (previously developed) land “within   settlements” would become “acceptable in principle” for   homes and other development needs.

 

  VIII.  Local planning authorities and other relevant public bodies   will continue to be under a duty to cooperate with each   other and new mechanisms would be introduced to     strengthen cross-boundary strategic planning. These   mechanisms have not yet been specified but the principle   of a return to effective strategic planning is welcomed.

 

  IX.  The proposals include increased support for onshore   renewable energy schemes and the updated NPPF would   direct decision-makers to give “significant weight” to the     benefits associated with renewable and low carbon energy   generation, and proposals contributing to meeting a net   zero future. These proposals would strengthen the     Council’s ability to deliver the objectives of the One     Coventry Plan and are welcomed.

 

  X.  Government proposes to clarify that “significant weight”   should be placed on the importance of facilitating new,   expanded or upgraded public service infrastructure when     considering development proposals.

 

XI.  Within the consultation, Government has confirmed it will not implement the Infrastructure Levy as introduced in the Levelling-Up and Regeneration Act 2023. Further proposals on the use of S106 agreements to deliver infrastructure are expected next year.

 

XII.  The proposed changes continue Government support for effective design coding to be prepared by local planning authorities. Government proposes the preparation of localised design codes, masterplans and guides “for areas of most change and most potential”. This approach will be particularly helpful for Coventry and is welcomed.

 

XIII.  The Levelling-Up and Regeneration Act 2023 introduced the ability of Government to produce National Development Management Policies (NDMPs), which are set to take precedence over local and neighbourhood. The current consultation does not include these policies but it does confirm the Government’s intention to do so from summer 2025.

 

The Committee considered the proposed consultation response in depth and asked questions, sought assurances and made comments on a number of issues which were to be reported to the Cabinet Member for Housing and Communities on 20 September, 2024.

 

RESOLVED:-

 

1)  That the Cabinet Member for Housing and Communities be recommended to include the following comments and questions as part of the Council’s response to the consultation:

 

·  A covering letter which includes the following alongside the consultation response submission:

·  The Council stress the primacy of the local plan in decision making notwithstanding the national planning policy framework

·  Further reinforce the needs of an ageing population and the necessity for the highest regard to be given to designing for healthy communities.

·  Re-introduction of financial support for ‘planning aid’, in order to support local residents in their ability to engage with the planning system.

 

Additional comments or amendments to specific questions:

 

·  Question 4 – Add reference to the need for family housing and the considerations of how family housing with appropriate garden, space standards and parking standards may be met alongside the NPPF’s promotion of increasing density in urban areas.

 

·  Question 7 – Refer to Annual Monitoring Statements (AMR’s) produced by all authorities which demonstrate housing supply – and reinforce their role in the definition of a local authorities supply position.

 

 

·  Question 12 – Reinforce local circumstance and the Coventry and Warwickshire context being distinct from other areas of the WMCA.

 

·  Question 17 – Strengthen response to identify the need for local affordability metrics to inform calculations.

 

 

·  Question 20 – Strengthen response on the lack of clarity on brownfield passports and suggest reference is removed.

 

·  Question 23 – Strengthen wording further to promote that grey belt should only be identified through plan making process and not be open to speculative application processes.

 

 

·  Question 70 – Strengthen wording to further emphasis the role of public open space in the creation and sustainability of healthy communities and positive individual health.

 

·  Question 78 – Further strengthen that climate change standard should be delivered on a national level and through the building regulations system in order to meet climate goals and ensure equitability and promote the easiest integration of retrofit renewables.

 

·  Question 80 – Strengthen to state that CCC do not support development within areas of flood risk.

 

 

·  Question 84-86 – Further wording to support the inclusion of considerations of water security as both a national and local priority.

 

·  Question 92 – State that there should be a fee uplift to retrospective applications to disincentivise development taking place where consent should have been sought.

 

·  Question 92 – Fee uplift for significant major developments should be set, whilst a reduction in fees to support small businesses and support economic growth should also be considered.

 

·  Question 92 – Add additional reference for the necessity of funding for planning aid to support local residents in understanding and making representation in the planning system.

 

·  Question 105 – Add in comment of support of standardisation and digitisation of the planning system to promote ease of access for residents.

 

 

2)  That the Cabinet Member for Housing and Communities be recommended to request Planning Officers to arrange Members seminars and/or briefings on the review of the Local Plan ahead of consideration by Council in December 2024.

 

3)  That the Committee receive Briefing Notes covering the following issues:-

 

a)  Permitted Development rights for renewables for   householders

 

b)  Potential fee generation uplift as a result of uplifted fee   proposals in Chapter 11