16.03.2026
DHA Planning has submitted its formal response to the Government’s consultation on proposed reforms to the National Planning Policy Framework (NPPF) and wider changes to the planning system.
To find out more, please read on....
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The response draws on DHA’s experience across planning, transport, infrastructure, viability and development delivery, and focuses on how national policy can best support a clear, plan‑led system capable of delivering viable development in practice.
While DHA broadly supports the Government’s objectives to simplify policy, accelerate plan‑making and support sustainable development, the response highlights several areas where greater clarity, flexibility and proportionality will be essential if reforms are to achieve their intended outcomes.
DHA welcomes the proposed restructuring of the NPPF, particularly the clearer distinction between policies relating to plan‑making and those guiding decision‑taking. This separation is seen as a positive step in providing greater certainty on how policy should be applied at different stages of the planning process.
In principle, DHA supports the introduction of National Development Management Policies (NDMPs) where they can reduce unnecessary duplication in Local Plans and help streamline plan preparation and examination. However, the effectiveness of NDMPs will depend on how they interact with local policy and whether they genuinely simplify decision‑making.
DHA supports the role of Spatial Development Strategies (SDS) as a framework for strategic growth, particularly in addressing housing and infrastructure needs at a wider geographic scale. However, the response cautions against restricting Green Belt review solely to locations identified within an SDS, as this could limit the ability of individual Local Plans to meet development needs effectively.
The importance of up‑to‑date Local Plans remains central to DHA’s response. Regular review, including updates at least every five years, is essential to ensure plans remain responsive to changing economic conditions, housing needs and delivery constraints.
DHA also raises concerns that the current policy approach to cross‑boundary cooperation lacks sufficient strength. Without more effective mechanisms, there is a risk that unmet development needs will continue to be displaced rather than meaningfully addressed.
The proposed changes to the tests of soundness are a key area of concern. DHA does not support the removal of the requirement for plans to be “justified”, as this risks weakening the evidence‑based foundation of plan‑making and undermining the robustness of the examination process.
The response also highlights growing concern around the increasing complexity of planning application requirements. DHA advocates a more proportionate approach, including the introduction of a universal national validation checklist, to reduce inconsistency between local planning authorities and improve efficiency for applicants and decision‑makers alike.
In terms of decision‑taking, DHA emphasises that reforms should avoid encouraging premature refusals, particularly where technical issues could be resolved through continued engagement with consultees prior to determination.
Viability reforms raise significant concerns for DHA, particularly where development plan viability assessments are intended to restrict application‑stage viability reviews. The response stresses that site‑specific viability considerations remain essential, given fluctuating market conditions and unforeseen development costs.
DHA also highlights the need for greater flexibility within Section 106 agreements, recommending legislative changes to allow planning obligations to be modified within five years where schemes become unviable and risk stalling.
In relation to affordable housing, the response supports a more flexible delivery approach, including the use of cash contributions in lieu of on‑site provision where appropriate. This is particularly relevant on medium‑sized sites where Registered Providers may be unwilling or unable to acquire smaller affordable housing schemes.
DHA strongly supports policies that reinforce the presumption in favour of sustainable development, particularly where they help remove barriers to housing and economic delivery.
The response welcomes the emphasis on development around transport nodes, but recommends broadening the definition of well‑connected locations to include high‑frequency bus corridors, rather than focusing solely on rail‑based accessibility.
DHA does not support fixed minimum density requirements around stations, noting that nationally prescribed density thresholds may be inappropriate in less urban or rural contexts and could prevent otherwise sustainable development from coming forward.
Greater planning support for renewable and low‑carbon energy infrastructure is welcomed, particularly where such proposals are afforded substantial weight in the planning balance. DHA also strongly supports policies that enable employment land and business development to respond flexibly to changing market conditions.
DHA Planning broadly supports the direction of the proposed reforms and the Government’s ambition to simplify policy and accelerate delivery. However, the response emphasises that successful reform will depend on maintaining a flexible, evidence‑led and commercially realistic planning system, capable of delivering homes, infrastructure and economic growth on the ground.
If you would like to discuss any of our key points further, please feel free to contact Jonathan Buckwell from DHA Planning.
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