ICE responds to consultation on draft National Planning Policy Framework

The National Planning Policy Framework (NPPF) is a document which acts as the rulebook for planning in England.

It advises local planning authorities and developers on what they can and cannot do when planning developments.

This update to the NPPF follows a reset of the tool in 2024, which the ICE also responded to.

The ICE’s response to this round of updates makes the following key points:

• The ICE welcomes this update to the NPPF. It represents a fundamental reset of the tool.

• The ICE strongly supports the commitment to improving the ‘rules-based’ nature of the planning system as demonstrated in the NPPF draft.

  These changes operationalise the strategic shift we have witnessed in the last year across the introduction of strategic documents like the infrastructure and industrial strategies.

  The next step will be demonstrating the feasibility of delivery to the public. Speeding up and simplifying the planning process is an important step towards doing that.

• Culture change at the planning inspectorate and local authority levels and improved coordination of decision making will be crucial to the success of these reforms and the implementation of the Planning and Infrastructure Act.

  There is also a need to implement the policy instruments that are already available, make better use of digital technologies and bring together key decision-makers – including ministers – to speed up change.

In response to specific consultation questions on proposed changes to sections of the NPPF, the submission includes the following additional points:

• The ICE strongly supports improved strategic planning at the sub-regional level.

  The definition and addition of local plans to the planning hierarchy rightly recognises the need for more detailed planning to be covered in lower-level documents, while the spatial development strategies (SDSs) set out a broader strategic plan for the area.

  SDSs must take full account of national plans and align appropriately to avoid carrying on the current approach, which sees subnational authorities largely determining the geographic spread of new housing in a way that is misaligned with national plans and needs.

• The ICE supports the possibility of joint local plans prepared by two or more local planning authorities where this would enable local planning matters to be dealt with most effectively.
• The ICE strongly supports the inclusion of the clear need to engage proactively with infrastructure providers. Early, strategic, engagement with infrastructure providers is central to enabling sustainable housing growth.
• There is a welcome shift towards connectivity-led planning which is an important improvement in the draft. Similarly, the change to a default ‘yes’ for development around train stations in existing settlements and well-connected stations outside of existing settlements, including on green belt land, is positive.

• Despite promises to enforce the mandatory adoption of sustainable drainage solutions (SuDS) by 2024, as laid out in Schedule 3 of the Flood and Water Management Act 2010, regulations remain stalled.

  In lieu of the full implementation of Schedule 3, planning tools like the NPPF have the opportunity to normalise and encourage the uptake of SuDS.