- The government needs to provide further clarity around some of the proposed changes. Without this, local authorities may be uncertain over what they are required to do, and create potential for legal challenges to planning decisions, slowing down delivery.
- The new rules around greenbelt release are particularly unclear in relation to identifying land that is making a ‘limited contribution’ against the greenbelt purposes.
- We welcome a broad approach to urban infill and prioritising brownfield sites overall, but would caution that there can be exceptions to the assumption that brownfield sites are always of less value than greenfield sites. There is also a clear conflict between deciding where to build based on the previous usage of the land and other more strategic factors (such as the availably of infrastructure).
- The new standard method for assessing housing requirements is an improvement on the previous one (which resulted in areas that failed to deliver being given lower targets for future delivery). However, it takes no account of land availability. A large number of councils believe that they lack the land necessary to deliver, given habitat protections, geographical constraints and other difficulties. The Government should make it clearer which of the many things that restrict development should be treated as absolute with local authorities who cannot be expected to deliver their target clearly identified and assisted to deliver them elsewhere.
- Transitional arrangements are going to be challenging if the government is not to penalise councils who have already adopted local plans, and also achieve its housebuilding ambitions over this parliament.
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A Quality Home for All
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