In December 2022, the Government published a tracked change version of the National Planning Policy Framework (Framework) and a Prospectus seeking views on shaping wider planning reforms.

The draft Framework (subject to consultation) is intended to swiftly deliver the Government’s [apparent] commitments to housebuilding. The implications of the draft Framework for the residential sector are stark and troubling and a clear response to the Tory backbench rebellion over housing targets.

Whilst the focus of planning policy making has always centred around the residential sector, housing and economic growth have always been symbiotic. The ‘proposed immediate’ policy implications on the residential sector are already filtering down, with a number of Local Plans stalling or collapsing as planners grapple with the consequences on housing needs and Green Belt. A policy vacuum in local plan making affects every sector. We are operating in a plan-led system with very few up-to-date Plans and seeing this play out first hand.

One of the more concerning proposals in the Framework is the review of the soundness tests and the proposed removal of plans no longer having to be ‘justified’ or being ‘positively prepared’. This would allow for a lower bar for assessment and suggests there will be void in evidence to justify a plan or policy. This is problematic for developers, communities and stakeholders. Watering down the need to properly evidence Local Plans in my view is wholly misconceived. Simplifying the plan-making system, and speeding it up to have no debate, is very worrying as it discourages a debate about what proper sustainable growth is for an area.  

However, there are some positives and helpfully the Prospectus sets out that there is a wider national policy review coming. I will be buckling up and putting my seat belt on for the levelling up journey. I hope that the logistics sector finally gets some meaningful airtime as the Government is seeking views on how they might develop policy to support the levelling up of economic opportunity.  Prologis welcomes the suggestion in the Prospectus that levelling up is central to attracting investment and driving growth. We want to see a full review of the Framework that will properly reference our sector given the contribution we make to the UK economy. 

At Prologis we take great pride in the developments we plan and deliver. The objective of building beautiful, well-designed places and refusing ugliness through the publication of National Model Design Codes will be significant and have far reaching consequences for our sector. Logistics buildings are built and designed to store goods at some point in the supply chain. They are designed for efficiency, volumetric capacity and to ensure the optimal flow of goods.  If the Government is to set simple, clear, minimum development standards in areas such as height, form and density we need proper engagement with the policy makers to ensure that high quality design can be allowed; but it will need to acknowledge the functionality our buildings require. The reference to beautiful and well-designed places will be an interesting area of debate that we would welcome.

Feature wall commemorating the brick workers of West London
Feature wall commemorating the brick workers of West London

 

Prologis is already raising the bar in the industry through our commitment to infrastructure investment, place-making, innovative design, ensuring our NSIPs can contribute to enhancing the environment for future generations, building a net zero carbon future and through provision of renewable and low carbon energy generation. The reforms are seeking to deliver better environmental outcomes and planning is imperative to conserving and enhancing the natural environment. As a business we have an enduring pledge to sustainability that means creating industry-leading parks and energy efficient buildings. We are dedicated to ensuring that all new developments are built to leading sustainability certification standards to reach our goal of carbon neutral in construction by 2025. The Governments’ ambition of Net Zero is fully supported by us.  

I wrote this piece because there is so much debate around getting behind the residential sector. I wanted to provide some balance from our side. We will be making representations to the Government consultation and welcome an opportunity to engage in a meaningful and proactive way with those drafting the policies.

Caroline Musker, Head of Planning, UK

Caroline Musker

Head of Planning, UK

Caroline Musker is the UK Head of Planning in the Prologis Capital and Deployment and Leasing team. Her focus is supporting the delivery of new and existing projects across the Prologis UK portfolio with regards to both the promotion of strategic sites and advising on development projects in the planning process. She joined Prologis in March 2022. Caroline has 18 years’ experience in planning work in the UK, in the private sector. Prior to joining Prologis she was a Senior Director at Lichfields where she was responsible for large scale employment, residential, mixed-use developments, energy and infrastructure projects. Her role included the promotion of strategic land, outline and detailed planning applications, planning appraisals and associated work. She has also successfully directed large scale multi-disciplinary teams. Caroline has been advising on DIRFT since 2004 and has acted as project lead for the implementation of the DIRFT III Development Consent Order since 2014. Caroline is a Member of the Royal Town Planning Institute.

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