Agenda item

Consultation Response to the Ministry of Housing, Communities and Local Government on Proposed Reforms to the National Planning Policy Framework

Report of the Director of City Services and Commercial

Minutes:

The Cabinet Member for Housing and Communities considered a report of the Director of City Services and Commercial, that had also been considered at the meeting of the Scrutiny Co-ordination Committee on 19th September 2024, 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 and sought approval to submit a proposed response to the consultation.

 

The Government was consulting on a series of proposed changes to national planning policy that included 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 ran from 30th July – 24th September 2024 with the Government indicating that a new version of the NPPF would be published before the end of 2024.

 

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 had not been possible to submit a report to either Council or Cabinet. Where time did not permit the submission of a report to Council or Cabinet, the Constitution required that responses should be agreed by the Leader, the appropriate Cabinet Member and the appropriate Director, following consultation with the appropriate Shadow Cabinet Member. In this case, the appropriate Cabinet Member had the authority, at their discretion, to refer a consultation to the relevant Scrutiny Board in light of the importance and high profile of the consultation process.

 

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 would 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 was invited to attend both the Scrutiny Co-ordination Committee and the Cabinet Member for Housing and Communities meetings. 

 

Since December 2022, the City Council had been undertaking a Local Plan Review in order to update the 2017 Local Plan. To this end, a Regulation 18 (Issues and Options) consultation was undertaken between July and September 2023. Led by the Local Plan Advisory Panel, officers were now at an advanced stage of the Local Plan Review process and a Regulation 19 (draft revised Local Plan) consultation was scheduled to commence before the end of 2024.

 

The report gave an overview of the proposed changes to the National Planning Policy Framework highlighting any implications for Coventry. An appendix to the report provided the National Planning Policy Framework: Draft Text for Consultation and a further appendix provided a Draft Response to Consultation.

The Cabinet Member received a briefing note from Scrutiny Co-ordination Committee’s consideration of the report (their Minute 27/24 referred) that had been circulated and requested that the following be considered as part of the Council’s response to the consultation:

 

  A covering letter which included the following alongside 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.

 

The Committee also requested that Planning Officers arrange Elected Members seminars and/or briefings on the review of the Coventry Local Development Plan ahead of consideration at the meeting of the Council in December 2024. 

 

RESOLVED that the Cabinet Member for Housing and Communities:

 

1)  Agrees the comments and requests made by the Scrutiny Co-ordination Committee following their consideration of this matter at their meeting on 19th September 2024. 

 

2)  Recommends that the Leader of the Council approves the draft consultation response attached at Appendix II to the report in accordance with the Constitution.

 

3)  Delegates the submission of the approved consultation response to the Strategic Lead for Planning before the deadline on 24th September 2024.

Supporting documents: