Response to the Government’s proposed reforms to the National Planning Policy Framework

Inclusion London’s consultation response to the proposed reforms to the National Planning Policy Framework and other changes to the planning system

Construction cranes in front of skyscrapers being built

The National Planning Policy Framework (NPPF) is a key document that sets the tone and direction for local planning policies. It can play a strong role in helping local authorities meet their obligations under the Public Sector Equality Duty (PSED) and ensuring that housing plans comply with the Equality Act.  

We are concerned that the Government’s proposed reforms to the NPPF fail to address the housing needs of Disabled people and do not explicitly encourage the delivery of accessible, adaptable housing and wheelchair accessible housing, of which we are in great need.  

We are disappointed that the Government’s current proposals do not make any reference to the link between the lack of accessible housing in the country, including the shortage of wheelchair accessible homes, and the rise in health inequalities among older and Disabled people and therefore do not contain any proposals to address this issue. 

In our response to the consultation, we have included a series of recommendations aimed at improving the NPPF, to ensure local authorities deliver the homes Disabled people need.

You can read our full response to the Government’s consultation here:

Our key recommendations  

We are calling on national Government to: 

Explicitly encourage the delivery of accessible homes, including wheelchair user homes by:

  • Explicitly referencing Part M of the Building Regulations and the categories 2 and 3 in the NPPF. The optional ‘Category 2’ accessible and adaptable housing standard should be made obligatory for all new build homes. 
  • Revising the NPPF to require all local plans to include a specific policy and target for new wheelchair accessible and adaptable M4(3) homes, with a target of at least 10%. 
  • Requiring the Planning Inspectorate to challenge any local authority if their plan fails to: 
    • Set specific requirements for the delivery of a proportion of all new homes to meet M4(2) and M4(3) standards. 
    • Include sufficient evidence addressing inclusive design and access for Disabled people in housing, public spaces, and the wider built environment. 
  • Incorporating an explicit, clear definition of “accessible housing” in the NPPF glossary, referencing Part M of the Building Regulations. 

Build more accessible social rent housing by:

  • Introducing mandatory social housing targets that all Local Authorities should be expected to meet. This is essential to alleviate the housing crisis for Disabled people and ensure that sufficient social rent homes are built. 

Ensure enforcement of accessible and affordable housing standards and targets by:

  • Making sure local authorities have the resources they need to challenge housing developers who use ‘viability assessments’ to say they can’t afford to make accessible or affordable housing. 
  • Challenging developers’ 20% profit expectation when building new homes to ensure delivery of accessible and affordable housing. 

Help local authorities improve how to assess Disabled People’s Housing Needs and meet their obligations under the Public Sector Equality Duty (PSED) by:

  • Revising the NPPF to include an explicit requirement for councils to assess Deaf and Disabled people’s housing needs and include this data in local plans. 
  • Developing a standardised and robust methodology for local authorities to collect data on Disabled people’s housing needs, including their impairments, accessibility needs, and proximity requirements to support networks and services. 

Foster engagement with Deaf and Disabled People and Disabled People’s organisations by:

  • Amending the NPPF to explicitly require consultation with Disabled people during the pre-application phase of new local plans to guarantee meaningful engagement. 
  • Ensuring that local authorities improve consultation practices with Deaf and Disabled people and their organisations, particularly during the pre-application stage, to strengthen our voice in planning processes. 

Put Deaf and Disabled people’s needs and aspirations at the centre of the Government’s ‘vision-led approach’ to transport planning by:

  • Investing to improve the accessibility of the national transport infrastructure and the street-space to enable Disabled people to navigate the built environment.   
  • Co-producing any vision-led approach to transport planning with Deaf and Disabled people and our organisations. 

 

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