Issue details

NOTE: This is an amended response to that published on the 19/03/2024. A substantive amendment has been added to the wording within Appendix 1, at question 1 and question 15. Additional wording has been added due a response from a Cambridge City Councillor and this is a joint Councils’ response.

The Department for Levelling Up, Housing, and Communities (DLUHC) is seeking views on how it might strengthen national planning policy to support brownfield development. It also seeks views on reviewing the threshold for referral of applications to the Mayor of London. The 3 consultation proposals are:

·     Changes to national planning policy to give significant weight to the benefits of delivering as many homes as possible and to take a flexible approach in applying planning policies or guidance relating to the internal layout of development.

·     Changes to the way the Housing Delivery Test operates in the 20 towns and cities subject to the uplift in the standard method. This would introduce an additional presumption in favour of sustainable development on brownfield land where the Housing Delivery Test score falls below 95%.

·     Reviewing the threshold for referral of applications to the Mayor of London.

Consultation closes on 26 March 2024 and further information can be viewed on the DLUHC webpage for the consultation: Strengthening planning policy for brownfield development - GOV.UK (www.gov.uk)

Feedback is requested via submission of written responses to the answered questions included within the document. The councils’ response is set out in Appendix 1. Given that the proposal relating to the threshold for referral of applications to the Mayor of London does not relate to Greater Cambridge, no response is proposed to the questions related to this.

Within the councils’ response, many of the key responses relate to the:

·       change to national planning policy to make clear local planning authorities should give significant weight to the benefits of delivering as many homes as possible

·       change to national planning policy to make clear local planning authorities should take a flexible approach in applying planning policies or guidance relating to the internal layout of development.

·       other planning barriers in relation to developing on brownfield land

·       how national planning policy better support development on brownfield land

·       how national planning policy better support brownfield development on small sites

The Councils response states that although we are supportive of development of brownfield sites, which reflects the existing NPPF, we express multiple concerns that strengthening planning policy around such areas through the options proposed will lower the quality of homes and lead to ‘quantity over quality’ on brownfield sites. All options proposed reduce standards of development and placemaking. This would lead to the erosion of development quality, sustainability, affordability, energy efficiency, and homes with sufficient space for families / working at home, for the provision of quantity. It also states that through the Local Plan as a comprehensive strategy, rather than piecemeal change, is the appropriate approach to allocating the best and most appropriate sites for residential uses, and this includes the re-use of brownfield sites.

Note that the response is proposed to be joint by Cambridge City Council and South Cambridgeshire District Council, subject to each council’s individual decision sign of process.