National Planning Policy Framework

Written evidence from Places for People

1.0 Introduction

1.1 Places for People is one of the largest property management, development and regeneration companies in the UK. We own and manage more than 62,000 homes and have assets of £3.1 billion.

1.2 Our vision is to provide aspirational homes and inspirational places and our approach looks at all aspects of communities rather than focusing solely on the bricks and mortar provision of homes. Places for People’s innovative approach to place management and placemaking allows us to regenerate existing places, create new ones and focus on long-term management.

1.3 This paper sets out the response from Places for People to the House of Commons Communities and Local Government Committee inquiry on the draft National Planning Policy Framework (NPPF). We believe that the NPPF is probably going to be one of the most vital elements of future Government policy ranking alongside future financial and fiscal policy measures in terms of its importance to stimulating future economic growth.

1.4 Overall, in our view the compilation of the draft NPPF has made a considerable transition away from the confusion of detailed Planning Policy Statements (PPS) to a document that clearly sets out the Government’s planning strategy. This has been achieved without changing the principles of a plan-led and democratic planning system, whilst providing a vital emphasis on future economic growth in the need for presumption of sustainable development.

1.5 Our primary focus in evaluating the NPPF has been to ensure that it can be deliverable. To this end, our main concerns which we set out below relate to ensuring that there are linkages both within the NPPF and between the NPPF and related planning policies to ensure that the planning process is able to ensure that future residential development is viable and deliverable.

2.0 Executive Summary

2.1 Never has there been a time in recent history where there is a vital need for the planning system to support sustainable economic growth. High levels of public sector debt combined with ‘shock waves’ in financial markets mean that Governments across the world increasingly need economic growth to be private sector led.

2.2 This situation is no different in the UK, in particular in the housing and construction industries which are important sectors of the economy. On any measure, there is a clear and present need to increase the production of housing as the statistics demonstrate:

· In 2010, only 103,000 homes were built in England, the fewest since 1923;

· Official household formation projections show that 232,000 homes need to be built each year;

· Even if 250,000 homes were built annually for 25 years just 1% of England’s land would be used;

· Permissions for fewer than 34,000 homes were approved in Q1 2011 compared to 60,000 permissions granted in Q1 2006;

· Over 80% of people believe Britain needs more homes, particularly for first time buyers where there were just 200.000 first time buyers in 2010 compared to 600.000 ten years ago;

· 1.8m families (5m people) are currently on local authority housing waiting lists in England;

· Various studies [1] of the economic benefits of new housebuilding have established that there is an overall economic benefit (i.e. total of direct, indirect and induced/multiplier benefits) of £3 additional GDP to £1 expenditure on new housebuilding.

2.3 We agree with the Department of Communities and Local Government (DCLG) who have stated [2] that planning is acting as a serious brake on economic growth, slowing the delivery of much needed jobs and new businesses not least through the inability to build more new houses. In addition, there are social ramifications of not enabling economic growth including building enough new homes such as affordability and deprivation, all of which is set out in the NPPF.

2.4 The DCLG state that there is broad recognition that the current planning system is slow, complex, bureaucratic and unresponsive. In our opinion, the implementation of the NPPF including the presumption of sustainable development is vitally important to ensure the planning system is able to provide the support required to deliver sustainable economic growth across the country.

2.5 All of this can be achieved within the plan led and democratic principles that have underpinned our planning system since 1947. Indeed, we like the Government believe that these principles will be strengthened as a result of the implementation of the NPPF as the presumption of sustainable development requires all parties to engage with local communities in an evidence based manner.

2.6 However, in order to ensure that the NPPF can better support the delivery of future sustainable economic growth, we believe that it is important that the NPPF is capable of ensuring the viability and deliverability of future development proposals and so we have set out some suggestions for improving the NPPF in section 3 below.

3.0 Response to consultation questions

Does the NPPF give sufficient guidance to local planning authorities, the Planning Inspectorate and others, including investors and developers, while at the same time giving local communities sufficient power over planning decisions?

3.1 We believe that the NPPF provides sufficient guidance to those that are involved in the planning process. Fundamentally, the NPPF provides strategic guidance in a manner that brings more clarity and certainty in the operation of the planning process which the current Planning Policy Statements (PPS) are unable to do.

3.2 Moreover, by providing strategic guidance to the planning system, the NPPF is able to provide local communities with a framework that they can tailor to their own local circumstances through the development and adoption of a Local Plan together with any relevant subsidiary Neighbourhood Plans.

3.3 Whilst it is clear that the absence of an up-to-date and consistent Local Plan will mean that planning applications are determined by the NPPF (paragraph 26), we believe the Government need to make it clear that local authorities will need to work with developers to establish appropriate viability and deliverability levels (paragraphs 39-43). All industries, not least residential development, are subject to constant change and evolution and so it is in everyone’s interests to ensure the planning system enables businesses to respond to those future changes in a timely and effective manner.

3.4 A similar issue exists on the duty to cooperate, where we believe that evidence of local authorities successfully cooperating on cross-boundary issues needs to include working with developers (paragraph 46). In fact, we recommend that the Government includes reference to evidence of local authorities working with developers/trade bodies on viability and deliverability levels under the "Effective" bullet point in paragraph 48 in order to ensure that the planning system is deliverable from a business perspective.

3.5 Clearly more detailed guidance or best practice will be required to support the deliverability of the NPPF and relevant clauses in the Localism Bill (e.g. neighbourhood planning). We understand that the Government has made it clear that it will in the future largely be up to industry bodies and associated professions to produce whatever guidance or best practice that they feel may be needed. Whilst we agree with this position, we believe that it is important that the NPPF states that guidance and best practice will only gain a ‘materiality’ status for use in the planning system if it can be demonstrated that the following criteria/tests have been achieved:

· has been produced in response to widespread feeling that there is a need for it;

· has been drawn up by a broad and inclusive group of bodies, rather than a particular interest group;

· is clearly evidence-based; and

· has been the subject of widespread consultation.

3.6 Finally, the Planning inspectorate will have a crucial role to play in ensuring that the operation of the future planning system achieves the objectives of NPPF set out in section 2 above. We would expect that the Planning inspectorate will apply the Plan making and Development management policy in a consistent and robust manner. Consequently, we believe it would be appropriate for the Planning inspectorate to have the ability to issue a certificate of conformity for planning applications in a similar manner to issuing certificates of conformity to local authorities for local plans.

Is the definition of 'sustainable development' contained in the document appropriate; and is the presumption in favour of sustainable development a balanced and workable approach?

3.7 We believe that the definition of sustainable development set out in the NPPF is not only appropriate but a necessary element of any balanced and workable planning system. Moreover, we agree with the manner that Government has set out the definition of sustainable development in paragraphs 9-12 of the NPPF so that it provides a focal or anchor point for the supporting policies.

3.8 In fact, neither the definition nor the presumption of sustainable development are completely new additions to the planning system. Various Governments over previous years have included sustainable development in their planning policies since the inception of the planning system in 1947. Where the NPPF differs is that it makes the presumption and definition of sustainable development transparent both in terms of primacy and content. This will therefore remove the need for endless debates about the focus on whether development is required and different definitions of what is sustainable at planning inquiries and appeals.

3.9 In this respect, we believe that the NPPF could be strengthened by directing local authorities to focus on using some key metrics in the evidence used to produce their economic (e.g. GDP), housing (eg. new houses) and environmental (e.g. emissions) policies that support their Local Plan. By requiring local authorities to focus on key metrics it will enable developers and the planning system to clearly evidence how their developments are sustainable.

3.10 From our perspective, there is a clear and present need for the NPPF to enable a significant increase in the long term production of new housing to significantly above 200,000 houses per annum. However, the benefits of achieving this goal are not just social (ie. affordability and deprivation) as set out in the Housing policy of the Planning for People section of the NPPF, but importantly the production of housing delivers large benefits to the economy. We believe that this needs to be referenced in the "Supporting economic development" part of the Planning for Prosperity section in the NPPF so that future developments can be assessed on both the economic (i.e. GDP) as well as the social benefits it will deliver.

Are the 'core planning principles' clearly and appropriately expressed?

3.11 On the whole, the Core planning principles set out in paragraph 19 of the NPPF are clear and appropriately expressed.

3.12 The exception to that rule is the lack of specific reference to viability and deliverability in the principles listed as bullet points. To ensure clarity, we believe that there should be specific reference made to viability and deliverability in the second and third bullet points. This is a vital point because if local planning authorities delay consideration of planning applications on the grounds that they have not quite finished producing their Local Plans, then this will seriously compromise the viability and deliverability of schemes that can deliver sustainable growth.

3.13 We therefore recommend that an additional principle or bullet point be added to paragraph 19 as outlined below to ensure that local authorities support planning applications in a timely manner and not delay consideration on ‘prematurity’ grounds:

· planning applications should be determined in a timely manner by local authorities in order to ensure the viability and deliverability of proposed developments is achieved

3.14 We have concerns about the lack of linkages across the various policies in the NPPF which we deal with in the next section.

Is the relationship between the NPPF and other national statements of planning-related policy sufficiently clear?  Does the NPPF serve to integrate national planning policy across Government Departments?

3.15 Whilst the policy statements made in the NPPF and reported outside of the NPPF are sufficiently clear, we do have a concern that there is a lack of clarity in the linkages between policies.

3.16 Our particular concern naturally relates to Housing and specifically to the delivery of a wider choice of quality of new homes (paragraph 11). Here, economic and social realities (ie. lack of Government grant, reductions in real disposable incomes and lifestyle changes associated with divorce/separation or older age) will require residential developers to continually change the way new homes are delivered. This will have implications for the future size, type, tenure and range of housing that the local authorities are required to identify (second bullet point of paragraph 111).

3.17 By way of example, we currently have a variety of choices of tenures (see Appendix 2) that we offer on all of the new houses we are currently building. We envisage that this creative approach to meeting market needs will require further changes in housing design and management of our future development pipeline.

3.18 We therefore suggest that in order to maintain the viability and deliverability of residential developers’ plans, there is a recognition that a presumption for sustainable development exists where proposed developments are able to evidence the ability to satisfy housing demand as opposed to the ‘narrow’ points on size, type, tenure and range of housing (paragraph 28 Strategic Housing Market Assessment and paragraph 111 second bullet point).

3.19 In addition, we believe that the NPPF should be less prescriptive in defining affordable housing for planning purposes and we would like to see local planning authorities be given the scope to define what is "affordable" in the context of their housing markets in keeping with the principles set out in the Localism Bill.

Does the NPPF, together with the 'duty to cooperate', provide a sufficient basis for larger-than-local strategic planning?

3.20 Overall, we believe that the provisions in the NPPF and its linkage with the ‘duty to cooperate’ requirement in the Localism Bill will provide a good framework for larger-than-local strategic planning.

3.21 However, we are concerned that not enough emphasis or direction is given by the Government in the NPPF to ensure that this will happen. Clearly the NPPF states that the presumption of sustainable development exists if there is no cross-boundary cooperation amongst local authorities where that is required. However, we would like to see references in the NPPF to Government withholding funding streams (eg. to Local Economic Partnerships) in addition to the point we made earlier about the need for local authorities to evidence cooperation (see 3.4 above).

Are the policies contained in the NPPF sufficiently evidence-based?

3.22 We believe that because the NPPF builds on evidence-based national policies and the evidence-based approach to Local Plans for which extensive guidance and best practice already exists, by definition its policies are sufficiently evidence-based.

Appendix 1: About Places for People

Places for People is one of the largest property development and management companies in the UK, with more than 62,000 homes either owned or managed in a mixture of different tenures. With over 2,000 employees, it is a unique organisation that provides a diverse range of products and services to build quality, safe and sustainable communities. Places for People is active in 230 local authorities.

Places for People regards itself as a housing and regeneration organisation that puts people first. We provide solutions that not only cover a range of different housing tenures but also offer a range of support services including affordable childcare, elderly care and financial services – all the things that contribute to making neighbourhoods of choice; prosperous, popular and truly sustainable.

Places for People currently has around 40,000 affordable rented properties, over 6,000 properties available for market rent and just under 10,000 properties where we retain a freehold stake as part of either shared ownership or ‘right to buy’ arrangements in a number of developments throughout the UK. We also own and manage around 6,000 homes for older and vulnerable people. Our portfolio is designed to ‘Create neighbourhoods of choice for all’ and covers the following broad mix of products:

· Places for People Neighbourhoods – investment, regeneration and placemaking

· Places for People Homes – neighbourhood and property management

· Places for People Individual Support – support for independent living

· Places for People Property Services – in-house maintenance services

· Places for People Development – master planning and building new developments

· Places for People Financial Services – financial products for customers

· Places for Children – early years childcare

· Cotman HA - managing around 3,000 homes across East Anglia

· Emblem Homes and Blueroom Properties – homes for sale and rent

We want all our neighbourhoods to be places where people are proud to live. To do this, our developments need a mix of homes, easy access to shops, schools, healthcare and leisure activities, safe public spaces, good transport links and job opportunities.

When we create new places for people to live we plan a mix of tenures and house types designed for communities that have people from different social backgrounds. All of our homes whether for sale or for rent are designed and built to the same high standards with the same specification, making different tenures indistinguishable.

Appendix 2: Tenure choice

September 2011