London Tenants Response to Proposed reforms to the National Planning Policy Framework

Published on September 27, 2024

Published on September 27, 2024

London Tenants Federation response to Ministry of Housing, Communities and Local Government consultation on National Policy Planning Framework (NPPF) and other changes to the planning system.

Yes that is quite convoluted sentence!

The country’s new Labour government has decided to alter the previous administration’s policy on plans for building homes and other aspects of national infrastructure.

London Tenants Federation has responded here to this shortened consultation, by focussing on the parts of the consultation related to house building.

Building the Wrong Type of Homes

The government plans to build 1.5 million new homes in the next 5 years. London has been set a new target of 80,000 homes a year. In 2023 London managed to build 35,000 new homes, well short of its former target of 66,000 a year. This is largely due to the current private developers building model; building homes without knowing who will buy and what they will pay and developers land-banking (refusing to build on land with planning approved as increased supply reduces demand and what they can charge). This has left London without the homes it needs for Londoners and too few houses built to meet the chronic shortage of homes needed to house Londoners.

LTF believes unless government directly invests in local councils, who have a vested interest to build the homes its communities needs, then their target of 1.5 million homes will not be met. If by some miracle it is achieved, they will be unaffordable to Londoners, and those corporations and wealthy individuals overseas who are able to purchase, will be insufficient in numbers to buy up all the new developments.

Government must legislate to force developers to build within a specific timeframe when planning has been approved, or hand it over to councils to build. Whatever costs developers have incurred is their loss for failure to build.

Every Council Home Potentially Under Threat of the ‘Brownfield Passport’ Idea

There is a greater threat to our homes with Labour’s current wording.

The Government defines brownfield land as developed land, that is, or was previously, occupied by a permanent structure.‘* and ‘…the government wants to consider whether there are opportunities to go further still in terms of providing faster and more certain routes to permission for urban brownfield land, and in particular whether we could introduce a ‘brownfield passport’ to ensure that the default answer to brownfield development is “yes”.’ **

This means that any of our estates could be demolished and rebuilt under current proposals, as their plans favour demolish and rebuild instead of refurbish and retrofit. We must resist this repurposing and replacing of our homes and communities and cogently argue that this is wrong not just for London but for the country as a whole.

LTF thanks all of those who responded to our call for your views and comments on the consultation, we are sorry that the time was so short for your response, but government deadlines dictated the timeframe. Once again thank you for your insights which we have incorporated as best we could in the time we had.

*https://www.gov.uk/guidance/national-planning-policy-framework/annex-2-glossary#prev-dev-land

**https://www.gov.uk/government/publications/planning-reform-working-paper-brownfield-passport/brownfield-passport-making-the-most-of-urban-land