HGH Consulting


hgh Response to NPPF review consultation

The following represents hgh‘s response to the consultation on proposed changes to the National Planning Policy Framework (NPPF) 


We are a firm of planning consultants: 8 Directors and 24 other professional staff, together with a panel of strategic advisers which includes Steve Quartermain, Lord Matthew Taylor and Frances Wheat. Based in London, we operate across England and Wales, on a very wide range of projects, ranging from new settlements and SUEs at the large end of the spectrum, to individual homes at the small end. Most of our clients employ us to promote development, but we do not infrequently act for those who oppose development. We have in excess of 150 live projects at any given time, giving us as good a perspective as any group of people on what works well and what doesn’t in the planning system.


We start from a perspective that planning should be a force for good: a fair and rational way of helping society achieve its many objectives related to land use, and resolving the conflicts that arise. It is inevitably difficult and complex, and becomes more so as the world becomes more complex in many different ways. We also start from a view that things cannot be allowed to stand still: much in society could and should work better, and we constantly encounter new technological, social, economic and moral challenges that need to be understood and moulded (as far as possible) to bring maximum benefit to the current and future generations.


The NPPF is in our view a good document. It covers a great deal of ground in a sensible and concise form, and it strikes careful balances between factors that pull in different directions. It is an effective bedrock of the modern planning system.

However, it should be an evolving document, and we are supportive of it being reviewed and refreshed.

We have considered carefully the changes which are now proposed, and we recognise that some of them are desirable and deserving of support. However, we believe others are positively bad, and urge that they be dropped.

The Big Picture

It seems to us that the principal problem is that there is a fallacy at the heart of what is proposed. This is that, if local communities are handed more power, local planning authorities are less regulated, and developers build nicer buildings, more homes (including affordable homes) will get built in the places where the country needs them to be built. That is the politicians’ dream, but it is quite clear to just about everyone in the planning and property worlds that this utopian vision is considerably divorced from reality.

The difficult fact is that, in general, people do not want new development near them, however good it looks, and however self-sufficient it may be in terms of its infrastructure. They recognise the need for more homes and workplaces in general, but they simply do not want these things near them. That being the case, the more tools they and the politicians they elect are handed, the more they will resist development and the more conflict there will be in the system.

We certainly do not suggest any retreat from democracy. The government structures that were successful in getting new towns, motorways and other major development built in the 1950s and ’60s are probably not appropriate for the 21st century. Instead, we have to find ways of striking the right balances between society’s needs and communities’ preferences, and the NPPF plays an important role in that.

The existing NPPF (with a few small revisions along the way) represents a careful balancing act: for example, it gives provides strong protection for heritage assets, but provides mechanisms to enable change and even loss to take place. It does the same with Green Belt and AONBs. Likewise, it provides a carefully honed “carrot and stick” approach to housing and other development: LPAs are encouraged to prepare development plans that will keep them in control, but there are mechanisms (5 year supply, tilted balance, HDT, etc) that will enable societal progress to continue even where the LPA has not prepared a plan.

Some of the currently proposed amendments to the NPPF represent a deliberate attempt to upset the balance, tipping it in favour of those who would stifle change and against the wider interests of a society that requires change. In our view this is a bad thing, and not something that we can support.

In our response to both the consultation paper and the tracked-changes version of the NPPF, we have tried to be constructive, supporting changes where we believe them to be positive. However, we urge that our concerns about and our opposition to some of the proposed changes be taken seriously.


Background mage: Mike Erskine on Unsplash


Roger Hepher, Executive Director, hgh Consulting
[email protected]

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