RIBA responses to government consultations on housing and planning
Whoever you are, wherever you live and whatever your situation, you should have the right to expect your home to be affordable, safe and sustainable.
Through our consultation responses, the Royal Institute of British Architects (RIBA) works closely with the Ministry of Housing, Communities and Local Government to rethink how houses and communities are planned, designed and built.
Ministry of Housing, Communities, and Local Government: Proposed reforms to the National Planning Policy Framework and other changes to the planning system
September 2024
This consultation sought views on the government's proposed approach to revising the National Planning Policy Framework (NPPF) in order to achieve sustainable growth in our planning system.
We support many aspects to the government's proposed approach, such as the removal of beauty references in the NPPF, measures for better cross-boundary cooperation, and the release of grey belt land for development. However, we recommend that more must be done to deliver high-quality, sustainable homes, promoting the use of architects, increasing local planning authority capacity, reinstating the five-year housing land supply, and ensuring affordable housing includes homes for social rent. We also advocate for mixed tenure housing and a "brownfield first" approach to the planning system.
Department for Levelling Up, Housing and Communities: An accelerated planning system
May 2024
This consultation sought views on proposals regarding a new Accelerated Planning Service, planning extensions, expansion to appeals processes and on the ability to make planning permission amendments.
We recommend that Government increase investment in local planning authorities (LPAs), facilitate timely processing of planning applications through both accelerated and standard routes, take steps to prevent a two-tier approach in navigating the planning system and ensure there is adequate resources alongside any new performance measures.
Read our full response to the consultation on an accelerated planning system. (PDF)
Department for Levelling Up, Housing and Communities: Changes to various permitted development rights
April 2024
This consultation seeks views on proposals relating to permitted development rights.
We recommend that Government take actions to fully resource local planning authorities (LPAs) for the strategic development of homes and places, and to introduce a National Retrofit Strategy to upgrade housing stock for energy efficiency. We also call for the consultation on the measurement and reduction of embodied carbon in the built environment to be brought forward, and for the removal of restrictions on heat pump installations near property boundaries and in blocks of flats.
Read our full response to the consultation on changes to various permitted development rights (PDF)
Department for Levelling Up, Housing and Communities: Strengthening planning policy for brownfield development
March 2024
This consultation sought views on how to strengthen national planning policy to support approaches to brownfield development, and views reviewing the threshold for referral of applications to the Mayor of London.
We urge a holistic approach to housing, focusing on sustainability and quality, calling for full resourcing of local planning departments to ensure high-quality brownfield development and to address professional shortages. We also oppose the proposed blanket increase in the Housing Delivery Test threshold for sustainable development on previously developed land.
Department for Levelling Up, Housing and Communities: Street vote development orders
February 2024
This consultation sought views on the detailed operation of street vote development orders. Our response recommends that government ensures local planning authorities are sufficiently resourced to manage the increased workload from street vote development orders. We stress the importance of involving architects and qualified designers to uphold best practices throughout the implementation of these orders.
We also urge government to conduct a detailed review of the effectiveness and potential adverse impacts of street vote development orders, taking swift action to mitigate any issues that arise.
Read our full response to the consultation on street vote development orders. (PDF)
Levelling Up and Housing, Communities Committee inquiry: Children, young people and the built environment
January 2024
This inquiry investigates how improved urban planning in England can enhance the well-being of children and young people and benefit the broader population.
Our response advises that the government should adopt a holistic approach to young people's needs in the built environment, including examining how both national and local planning policy can facilitate young people's engagement.
Read our full response to the inquiry on children, young people and the built environment. (PDF)
House of Lords Built Environment Committee: Modern methods of construction – what’s gone wrong?
November 2023
This inquiry sought to understand the barriers to the increased delivery of Methods of Construction (MMC) homes and to what extent the government's approach to supporting MMC development is effectively overcoming and resolving these barriers.
We advocate for the implementation of monitoring processes to track the adoption of Modern MMC in housing projects, the establishment of baselines to encourage MMC utilisation and an examination of incentives to support and promote MMC usage. We also suggest mandating Post-Occupancy Evaluation (POE) for all government-funded projects employing MMC and endorsing the broader application of POE across all projects to enhance accountability and learning in construction practices.
Read our full response to the HoL Built Environment Committee inquiry on MMC. (PDF)
All-Party Parliamentary Group for Council Housing: council homes investment inquiry
October 2023
This inquiry sought views on proposals to increase the number of council houses being built as a central part of the solution to the housing crisis.
We recommend nationwide investment in high-quality, sustainable council housing, new social housing funding, support for local planning authorities, a National Retrofit Strategy for energy efficiency, Post Occupancy Evaluation, and exploring opportunities for new council housing in areas with existing infrastructure and housing demand.
Read our full response to the APPG inquiry on council housing. (PDF)
Department for Levelling Up, Housing and Communities - Levelling Up and Regeneration Bill: Implementation of plan-making reforms
October 2023
This consultation sought views on proposals to implement the parts of the Levelling Up and Regeneration Bill which relate to plan-making, to make plans simpler, faster to prepare and more accessible.
Our response welcomes the opportunity to provide input on plan-making reforms in the Levelling Up and Regeneration Bill. We support the government's aim to simplify and expedite the process, but highlight concerns about the current complexity and lengthy nature of plan-making, hindering community involvement and necessary development.
We suggest comprehensive support for local planning authorities, architect involvement in consultations, and pilot testing of proposed time frames. We also endorse adapting to local needs and emphasise a focus on local issues and inclusive community engagement in plan templates.
Read our full response to the consultation on the implementation of plan-making reforms. (PDF)
Department for Levelling Up, Housing and Communities: Permitted development rights and additional flexibilities to support housing delivery
September 2023
This consultation contains proposed changes to the Town and Country Planning (General Permitted Development) (England) Order 2015, as amended.
Our response recommends ending the use of PDR for converting commercial buildings into residential units until they meet full planning permission standards.
It advocates for architects in all building designs, strengthening local planning departments with design expertise, prioritising high quality affordable housing and focusing on sustainability in long-term housing solutions to address the housing crisis.
Read our full response to the consultation on permitted development rights. (PDF)
Department of Health and Social Care: Older People's Housing Taskforce - call for evidence
September 2023
This consultation sought input on understanding today's older housing market and needs, with a focus on shaping the future.
Our response focuses on the importance of addressing accessibility, sustainability and safety in housing. We advocate for a National Retrofit Strategy to enhance energy efficiency, with architects playing a key role in designing inclusive, age-friendly homes.
We stress the significance of holistic considerations like quality, location, and sustainability in shaping new housing developments, as well as propose adapting existing older housing stock and private rentals to meet accessibility standards.
Read our full response to the consultation for the Older People's Housing Taskforce. (PDF)
Levelling Up, Housing and Communities Committee inquiry: disabled people in the housing sector
September 2023
This inquiry examined the role of government, local councils and developers in ensuring the delivery of suitable housing for disabled people and what the government can do to support disabled tenants in the private rented sector in England.
Our response recommends that the government address key aspects of housing accessibility. This includes launching a consultation on higher minimum accessibility standards for new homes, bolstering local planning departments with design expertise, facilitating home adaptations for older housing and disabled tenants in the private rental sector, encouraging developers to prioritise accessible homes and ensuring the installation of sprinklers in places housing vulnerable individuals to enhance safety.
Read our full response to the inquiry on disabled people in the housing sector. (PDF)
All-Party Parliamentary Group for Housing and Planning: developer contributions inquiry
September 2023
The APPG is calling on local government, housebuilders, social and affordable housing providers and other interested academics, charities and businesses to submit evidence about the government’s proposed Infrastructure Levy and explore proposals to improve existing Section 106 (S106) and Community Infrastructure Levy (CIL) mechanisms.
Our response advocates for an all-encompassing Infrastructure Levy, addressing non-financial obligations, supporting affordable housing, and mitigating regional disparities. Replacing Section 106 with this levy is recommended for planning certainty. Local planning authorities need better resources, and safeguards against privatising public spaces must be established.
Read our full response to the consultation on the developer contributions inquiry. (PDF)
Department for Levelling Up, Housing and Communities: Environmental Outcomes Reports: a new approach to environmental assessment
June 2023
This Environmental Outcomes Reports (EORs) consultation sought views on the government’s proposals for a new approach to environmental assessment.
Our response emphasised that any new regime must be ambitious and flexible to ensure local councils can go further and faster to deliver environmental protection. Planning departments should be sufficiently resourced to handle the shift to a new regime.
We are concerned that the regime may be too narrow – the impact of climate change, as well as population and human health must be incorporated. We encourage the government to engage with stakeholders as they continue the development of EORs.
Department for Levelling Up, Housing and Communities: Technical consultation on the Infrastructure Levy
June 2023
The Infrastructure Levy is a reform to the existing system of developer contributions – Section 106 planning obligations and the Community Infrastructure Levy - in England. This consultation sought views on the design of the Levy and of regulations that will set out its operation in detail.
RIBA welcomes the Levy’s potential to rectify regional imbalances caused by Section 106 (S106) contributions. Our response recommends ensuring that genuinely affordable housing provision is protected, regional disparities are mitigated against and local planning authorities are comprehensively resourced.
Read our full response to the Technical consultation on the Infrastructure Levy. (PDF)
Department for Levelling Up, Housing and Communities: Increasing planning fees and performance: technical consultation
April 2023
This consultation sought views on proposals to increase planning fees and to improve the performance of local planning authorities.
RIBA welcomes the consultation and its focus on diversifying skills and recruitment within local planning authorities. Our response recommends that the government invests in building up the capacity of planning departments, ringfences income from proposed planning application fee increases, works to diversify routes to the planning profession and ensures wider community engagement with planning processes.
Read our full response to the Planning Fees Consultation. (PDF)
Labour National Policy Forum (NPF): Supporting Families
March 2023
This policy commission called for written evidence on what is important for the next generation to have a childhood in which they can thrive. It sought recommendations on how to build more social housing and ensure greater investment in genuinely affordable homes.
Our response emphasises the importance of safe, secure housing and access to green space. We also highlight the importance of addressing the resource gap in local authority planning departments, with particular focus on the shortage of qualified design expertise. New development must support mixed communities and inclusive community engagement.
Read our full response to the Labour Party National Policy Forum Consultation: Supporting Families. (PDF)
Department for Levelling Up, Housing and Communities: Levelling Up and Regeneration Bill - reforms to national planning policy
February 2023
This consultation sought views on proposed changes to the National Planning Policy Framework (NPPF).
Our response welcomed the focus on levelling up and boosting housing supply throughout the consultation but advised that proposed changes to housing land supply requirements would not deliver the number of new homes we need.
Quality and place are also key considerations: to ensure this, we recommended that planning departments should be resourced to recruit and retain qualified designers, and that existing infrastructure is taken into account when looking to increase density. Environmental considerations are also of vital importance, and we welcomed the attention given to carbon measurement.
Read our response to the proposed changes to the National Planning Policy Framework. (PDF)
Department for Levelling Up, Housing and Communities: A Decent Homes Standard in the private rented sector: consultation
October 2022
This consultation sought views on the introduction and enforcement of a Decent Homes Standard in the private rented sector in England.
Our response welcomed this commitment to setting a minimum quality standard for private rented properties but advised that greater ambitions should be made to improve thermal comfort and energy efficiency through reintroduction of the Landlord's Energy Saving Allowance.
Integration of this policy into strategies like PRS reforms and the Decent Homes Standard are how the UK can expect to feasibly reduce carbon emissions and achieve sustainability targets.
Read our full response to the consultation on a Decent Homes Standard in the private rented sector. (PDF)
Department for Levelling Up, Housing and Communities: Compulsory purchase - compensation reforms
July 2022
This consultation sought views on amending the compensation provisions in relation to the assessment of prospective planning permission where land is acquired by compulsion.
Our response recommended that hope value should be removed from the Land Compensation Act and compulsory purchase compensation should be set at existing use value plus a modest premium, compulsory purchase orders should be used as a last resort and local authorities require further planning and design resource within the planning system to create sustainable and well-designed communities and deliver change.
Read our response to the consultation on Compulsory purchase - compensation reforms. (PDF)
House of Lords Built Environment Committee: Meeting the UK's Housing Demand
September 2021
This inquiry examines the demand for new housing in the UK and how barriers to meeting this demand can be overcome.
Our response urged the government to address the resources gap in local authority planning departments as well as highlighting the importance of obtaining advice from professional experts. Additionally, we reiterated the need for Post Occupancy Evaluation of housing projects and the damaging effects of some Permitted Development Rights.
Read our response to the inquiry on meeting the UK's housing demand. (PDF)
Housing, Communities and Local Government Committee: Permitted Development Rights
April 2021
This inquiry examines the impact that an expansion of the Permitted Development Rights (PDR) system has had, and will continue to have, on the planning system and the government's targets for new homes and economic growth.
Our response urged the government to reverse recent changes to PDRs so that they may only be applied when development or change of use does not have any significant impact on people’s health or wellbeing, or on the environment.
Read our response to the inquiry on permitted development rights. (PDF)
Read our response on behalf of the HoME Coalition. (PDF)
Ministry of Housing, Communities and Local Government: National Planning Policy Framework and National Model Design Code consultation proposals
March 2021
This consultation sought views on draft revisions to the National Planning Policy Framework and the draft National Model Design Code, which provides detailed guidance on the production of design codes, guides and policies to promote successful design.
Our response urged the government to promote the use of suitably qualified professionals as the best route to achieving good design outcomes. Additionally, we would like to see further amendments to strengthen environmental policies and clarification on inclusivity within community engagement.
Ministry of Housing, Communities and Local Government: Right to Regenerate: reform of the right to contest
March 2021
This consultation set out a number of questions relating to the effectiveness of Strand 2 (land owned by a local authority or certain other public bodies) of the Right to Contest under the Local Government, Planning and Land Act 1980.
Our response encouraged the Commission to introduce a presumption in favour of retaining public land.
Read our response to the consultation on Right to Regenerate. (PDF)
Ministry of Housing, Communities and Local Government: Supporting housing delivery and public service infrastructure
January 2021
This consultation contains proposed measures to support housing delivery, economic recovery, and public service infrastructure.
Our response highlights concerns about the impacts that permitted development has had on the quality, safety and sustainability of new homes. While several proposals within the consultation will address some of these issues, we remain of the view that there is little evidence to justify the need for the use of permitted development as a means of accelerating the development of new homes.
Ministry of Housing, Communities and Local Government: Raising accessibility standards for new homes
December 2020
The Ministry of Housing, Communities and Local Government consulted on how to raise accessibility standards, recognising the importance of suitable homes for older and disabled people.
Our response called on government to mandate the current M4(2) requirement in Building Regulations to ensure all new homes meet minimum accessibility standards and adequate space standards.
Read our response to the consultation on raising accessibility standards for new homes. (PDF)
Ministry of Housing, Communities and Local Government: Planning for the Future
October 2020
The government launched the White Paper: Planning for the Future to reform the planning system in England. The suggested reforms are the most radical reforms to the English planning system in decades.
Our response highlighted that Planning for the Future must be the start of a wider conversation about how the built environment in England responds to environmental, economic and demographic changes. The RIBA also noted that more detail on how the new system would work is urgently needed.
Read our response to the White Paper on Planning for the Future. (PDF)
Building Better, Building Beautiful Commission
May 2019
The Building Better, Building Beautiful Commission launched a call for evidence on how to improve the design of homes and neighbourhoods through the planning and development process, including seeking views on the role of beauty in the planning system.
The RIBA has called on the Commission to ensure that beauty is incorporated into a broader definition – quality design – which is focused on securing positive outcomes for the people that will use and interact with the places being built.
Read more about our response to the Building Better, Building Beautiful Commission.
Housing, Communities and Local Government Select Committee: modern methods of construction
February 2019
The Housing, Communities and Local Government Select Committee launched an inquiry into the use of modern methods of construction (MMC) to deliver new housing. The inquiry investigated how national and local government can support the use of MMC and encourage innovation in the sector.
We recommended that the government should change its procurement process to recognise the wider benefits of development and move away from a focus on best price and promote the use of Post Occupancy Evaluation.
Read our response to the inquiry on modern methods of construction. (PDF)
Ministry of Housing, Communities and Local Government: planning reform – supporting the high street and increasing the delivery of new homes
October 2018
The government’s 'Planning Reform: Supporting the High Street and Increasing the Delivery of New Homes' consultation proposes to introduce flexibility to react to local circumstances by allowing employment space to be converted into residential easily.
Our response warned of the damaging consequences that would result from expanding a policy which since it was established in 2013 has led to a drastic decline in standards across England.
Read more about supporting the high street. (PDF)
Communities and Local Government Select Committee: housing and older people
March 2017
The Communities and Local Government Select Committee inquiry examined whether the housing on offer for older people is sufficiently available and suitable for their needs and, in doing so, considered how they may wish to live.
Our response called on government to introduce a distinct, clear planning use class for older people and make it less onerous to adopt accessibility requirements into local plans.
Read our response to the inquiry on housing and older people. (PDF)
Public Accounts Select Committee: housing - state of the nation
February 2017
In recent years, the need for housing in England has grown faster than its supply, and housebuilding needs to increase across the country. This inquiry asked what government needs to do to meet the rising demand for housing.
Our response highlighted the need for government to promote the use of post-occupancy evaluation and commission the Chief Planner to produce an annual report providing high-level monitoring of quality and delivery within the built environment.
Read our response to the State of the Nation inquiry. (PDF)
