The public consultation on proposed reforms to the National Policy Planning Framework is open until 11.45pm Tuesday 24 September 2024.

There are three documents found here that you ideally need to read in order to respond:
Proposed changes – explanatory paper
NPPF: draft text for consultation (84 pages!)
Outcome of proposed method

How to take part in the consultation

• The Citizen Space online consultation portal found here,
• or by email to: PlanningPolicyConsultation@communities.gov.uk,
• or written responses to: Planning Policy Consultation Team, Ministry of Housing, Communities and Local Government, Floor 3, Fry Building, 2 Marsham Street, London SW1P 4DF.
• You can also write to our MP Rosie Duffield to indicate your concerns about the new proposals: enquiries@rosieduffieldmp.co.uk

The Government has published its proposals to provide 1.5 million new homes over the next five years. The totals indicated for the Canterbury District are not significantly different from those proposed in the Canterbury District 2040 plan. However, the changes proposed make the total mandatory.

The new ‘needs assessment’, based on current housing stock, is an arbitrary formula, justified on the basis that it provides a stable, proportionate baseline. It takes no account of actual local need and virtually removes recognition of any specific local constraints. The transition arrangements suggest that Canterbury will be able to proceed on the basis of is current plan, although it will do so in the context of a political and regulatory environment committed to approve the scale of development it has proposed.

What the consultation covers
As usual the documents are lengthy, but we have tried (below) to highlight key points on which you may wish to comment. You will be able to scroll down to the relevant sections to answer the questions if you choose to use the online portal.

You can simply send an email to the address (above) but ensure that you provide the required personal information. Confirm whether you are replying as an individual or submitting an official response on behalf of an organisation, and include: your name, your position (if applicable), the name of organisation (if applicable). Make it clear to which question or paragraph number each comment relates.

Points you may wish to consider
– While housing stock may be given a stable basis, it ignores completely the capacity, geography, heritage, infrastructure, and actual needs of a District if it were to try and sustain exponential growth.
– The scale of large-scale development envisaged for Canterbury and the surrounding district would lead to urbanisation and development coalescence (Blean-Tyler Hill-Rough Common, Brooklands Farm and Whitstable, Thanet Way, Winterbourne Fields at Dunkirk).
– The proposal to delete the requirement that “availability of agricultural land for food production should be considered” seriously undermines the need for food security.
– Wider landscape, biodiversity and heritage concerns are also undermined by the new proposals.

Key points
– New method to assess housing need to provide 1.5 million new homes.
– Baseline 0.8% of existing housing stock levels to drive delivery proportionate to existing size of settlements mandatory – planning for a lower figure only when local authority has exhausted all options and can demonstrate land and delivery constraints such as – existing National Park, protected habitats, flood risk areas. Must demonstrate they have taken all possible steps, including optimising density, sharing need with neighbouring authorities, reviewing Green Belt boundaries, before
a lower housing requirement will be considered.
– With exception of London, the new formula increases targets across all other regions
– Outcome for Canterbury – annual target for new dwellings:
current: 1141 – proposed:1178
– Canterbury average annual net addition of homes 2021-23 was 552.
– It deletes reference to ‘exceptional circumstances’ for alternative approaches. 
– Strategic planning across local planning authority boundaries to play a vital role in sustainable growth, key spatial issues, meeting housing needs, delivering strategic infrastructure, building economic and climate resilience.
– Density: plans should promote an uplift in density. [Should Canterbury be looking for increased density on already-approved sites?]
– The new NPPF ‘tilts the balance’ towards approval – permission granted unless it cuts across protections for safeguarded areas, like National Parks and habitat sites, or adverse impacts would ‘significantly and demonstrably’ outweigh the benefits assessed against the NPPF as a whole.
– Significant impacts on the transport network (capacity and congestion), or on highway safety, could be effectively mitigated through a vision-led approach. Development would only prevented on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe.
– Re agricultural land for food production – the requirement that ‘availability of agricultural land for food production should be considered when deciding what sites are most appropriate for development’ is proposed to be removed.
– Objective of the new NPPF – local plan adoption as quickly as possible, new NPPF system to be implemented Summer/Autumn 2025.