Purpose

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.

Content

That
the Lead Cabinet Member for Planning agrees:
a)   
to submit the response to the open consultation on
strengthening planning policy for brownfield development as set out
in Appendix 1.
b)   
that delegated authority is given to the Joint
Director for Planning and Economic Development to agree any minor
amendments to the response in order to
finalise the joint response.