In its response to the consultation on draft revisions to the National Planning Policy Framework and a new draft National Model Design Code, CIHT has outlined the need for these proposed reforms to go further.

Andrew Hugill, Director of Policy and Technical Affairs, CIHT said:

The ‘Manual for Streets’ is highlighted as key guidance in the National Model Design Code and CIHT is currently working with the Department for Transport (DfT) and the Ministry of Housing, Communities and Local Government (MHCLG) to develop a revised version (Manual for Streets 3 (MfS3)) which will incorporate content and principles from Manual for Streets (MfS) and Manual for Streets 2 (MfS2).

To ensure high uptake of the principles in Manual for Streets its position must be strengthened and should become clear government policy. This would enable local authorities, developers, the planning inspectorate, and professionals engaged in developing better places to have the confidence to utilise this guidance.

The importance of Manual for Streets in creating better places has been recommended by several key reports:

• The House of Lords Select Committee on National Policy for the Built Environment ‘Building Better Places’[1] report recommended the use of MfS by all local authorities.
• Strengthening MfS position was a specific call in the Building Better, Building Beautiful Commission’s ‘Living with Beauty’ report[2].
• The Cabinet Offices Policy Lab carried out a scoping study into the use of MfS in 2019 and amongst its recommendations said DfT & MHCLG should align MfS3 with the National Planning Policy Framework (NPPF). There is the opportunity to make MfS3 one of three types of guidance which sit underneath the NPPF along with Planning Policy Guidance and Visual Guidance.
• UCL’s ‘A housing design audit for England’[3].

The latest response by CIHT to the National Planning Policy Framework and National Model Design Code: consultation proposals highlights that proposed changes to chapter 9 on Promoting Sustainable Transport are very minor in nature.

Andrew Hugill, Director of Policy and Technical Affairs, CIHT said:

The integration of planning and transport plays a fundamental role in making development sustainable and the siting of this development must be at the core of planning policy.

The choice and availability of sustainable travel choices is a key factor for sustainable development. This needs to be a fundamental part of the planning process and recognise that transport authorities and operators need to be involved throughout the planning process from initiating the local or strategic plan to the determination of planning applications, thereby becoming part of the solution rather than a hurdle to be overcome.

Revisions to the NPPF need to ensure that the requirement for sustainable transport provision not only features in some policy statements but is consistently and coherently underpinning decision-making throughout – e.g., the location of development; the way development is accessed; changes to the basis of refusal of applications (removal of key current statements on “severe” etc. as in the current NPPF); the need for net gains in sustainable transport provision. 

A recent survey by CIHT of professionals active in the sector showed that 80 percent of respondents thought that proposed revisions to chapter 9 were not strong enough to promote sustainable development [4].

CIHT has previously raised concerns in our response to ‘MHCLG’s Planning for the Future White Paper[5]’ that it failed to address the critical inter-relationship of planning and transport.

Andrew Hugill, Director of Policy and Technical Affairs, CIHT said:

On this basis - the proposed radical changes to the planning system as then set out will fail to do any better than before. CIHT believe that the white paper should support and require the delivery of a fully integrated planning and transport process, from the policy right through delivery. Importantly this must also extend for the lifetime of the development and related infrastructure and services.

Ends

A full copy of the consultation response will shortly be available at https://www.ciht.org.uk/knowledge-resource-centre/resources/consultations/  

[1] https://publications.parliament.uk/pa/ld201516/ldselect/ldbuilt/100/100.pdf

[2] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/861832/Living_with_beauty_BBBBC_report.pdf

[3] A housing audit for England, UCL (2020) https://www.ucl.ac.uk/news/2020/jan/new-housing-design-england-overwhelmingly-mediocre-or-poor

[4] CIHT webinar: MHCLG and DfT present National Planning Policy Framework and National Model Design Code: consultation proposals (ciht.org.uk) – held on 12 March 2021 and attended by 185 delegates

[5] CIHT response to MHCLG’s Planning for the Future, https://www.ciht.org.uk/media/12351/planning-for-the-future-ciht-submission.pdf