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CPA Consultation Responses

CPA responds to as many consultations as we can that are relevant to the planning system or natural environment.
These are mainly to MHCLG (the Ministry of Housing, Communities & Local Government), and to DEFRA (Department for Farming and Rural Affairs). We also make submissions to Inquiries and Committees at the House of Commons and House of Lords.
Responding to consultations can be time consuming and onerous, and frustrating when we are not listened to. But please let us know if you are aware of a new national consultation.

woman holding lots folders

(​Image by KamranAydinov on Freepik)

CPA Submission to Land Remediation Relief - August 2026
CPA responded to a Treasury consultation on Land Remediation Relief, which was primarily aimed at businesses.

We agree with the substantive definition of derelict land set out in the consultation document but would like to propose that paragraph 1.8.1 (d) is removed. It states that land is not to be regarded as in a derelict state “if it is in any economic, social, amenity, ancillary or interim use, including use for parking, storage, access, advertising, open space, or recreation“. Derelict land that is, nevertheless, used for these sorts of purposes could be extremely detrimental to local communities, affecting their financial (property values, for example), mental and physical health and wellbeing. Such purposes can also impact economic growth in the area due to more welcome businesses considering the neighbourhood unattractive.

We are delighted to see that some of the issues we previously raised have been addressed in your proposals and would welcome the opportunity to host an online meeting with you to discuss other potential initiatives that would help to meet your key objective of providing viable and cost effective support for brownfield remediation and development (which we wholeheartedly support), including, for example:

  • where land has been intentionally made derelict, a fee should be payable by the landowner to provide compensation to, for example, local residents whose homes may be rendered unattractive, unpleasant places to live, or local councils which may incur costs to prevent health and safety issues arising  
  • changes to VAT rules to remove VAT on brownfield developments and introduce it on all greenfield proposals
  • ensuring there is adequate, up-to-date information about brownfield sites recorded on each district’s brownfield register, including information about the contamination and state of dereliction in relation to each site – this could be done with support from local communities and will be a useful indicator of potential claims to factor into future budget estimates
  • ensuring that developers adequately mitigate and fund the impacts from their developments (the consequences of approving unsustainable development results in additional costs for the public purse, meaning less funding is available to address priorities, we provide some examples of this in our recent report, Who Pays for Unsustainable Development)  
  • given those costs to the public purse, and the information in the updated CPRE State of Brownfield report, which confirms that “there is enough brownfield land to build 1.4m homes in England, and more than half of these sites already have planning permission (either outline permission or better), meaning they could be built on rapidly“, the Treasury should request that the MHCLG mandates a brownfield first policy in the next iteration of the National Planning Policy Framework (unless brownfield first is made compulsory, developers will continue to propose inappropriate, unsustainable developments on greenfield sites, and brownfield land will remain contaminated and derelict, regressing, rather than regenerating, our urban areas). 
CPA Submission to HoL Built Environment Committee on New Towns - July 2026
CPA responded to a call for evidence from the House of Lords Built Environment Committee on the Government’s plans for the next generation of new towns. This was the 3rd module of the inquiry and looked at the practical, physical challenges facing the construction and development sector in delivering new towns.
We said the greatest overlooked challenge is financing. Successful new towns are multi-decade infrastructure and financing programmes. Until this distinction is recognised, Government risks repeating many of the mistakes that have characterised previous generations of new towns.
Link: ​CPA Submission
CPA Submission to HoC EFRA Committee: Land Use in Uplands - June 2026
CPA responded to the House of Commons Environment, Food and Rural Affairs Committee on proposals for land use changes in upland areas.
We said that whilst government documents (such as the Land Use Framework) and current policies may suggest there should be a balance in respect of competing demands, including for the natural capital assets mentioned in the question, experience confirms that balance does not exist in practise. The government’s growth agenda is selective and does not, for example, include enhancing or augmenting the value of our natural capital, including that which supports food production, nature’s recovery, climate mitigation, water management, and public access.
Link:​ CPA Submission
CPA Submission to Proposed Changes to Permitted Development Rights - June 2026
CPA responded to a consultation on changes to Permitted Development Rights (PDR) for schools, assets of community value and defence establishments.
We said we were extremely disappointed that this consultation does not signal an intent to rectify the current omission in PDR regulations that PDR does NOT apply to areas that host irreplaceable habitats. We strongly believe that this must be remedied with urgency as we are aware of PDR being used as, for example, a reason that a ‘temporary’ road can be constructed across a peat moss. When challenged, the developer responded that “There is no guidance or legislation which sets out that Permitted Development rights cannot be used in areas of irreplaceable habitats”.

Protection of irreplaceable habitats from PDR should apply to all PDR submissions, including those from the MOD.

CPA Submission to Proposals for a new GCSE in Natural History - June 2026

In June 2026, the government announced a consultation on proposals for a new GCSE in Natural History.

We said we are delighted that future pupils will have the chance to acquire a deep knowledge of the species and habitats that make up the natural world in the UK. We also fully support the fieldwork requirement element of this topic.

We think there is a gap relating to the planning system and the impact of consequential development on habitats and species. The recent weakening of protections for habitats and species is accelerating the harms to the natural world and will result in already declining species populations reducing further, due to (for example) habitat loss, disturbance, and air, noise, light, vibration, dust and water pollution.

We believe the subject aims should include an additional objective: to understand how habitats and species are impacted by development, demonstrating knowledge of regulations to protect the natural environment, the impact of weakening those policies and regulations and the measures that can be taken to manage and mitigate those impacts, including understanding how to value natural capital through reference to, for example, Dasgupta (The Economics of Biodiversity: The Dasgupta Review) and the Treasury’s Green Book.

The introduction of this objective could open up additional opportunities for students to work with Councils, developers, ecologists and campaign groups for their fieldwork exercise and, given that there is an acknowledged shortage of Council planning officers and independent ecologists, the inclusion of this to the subject content may also provide work experience opportunities that could lead to genuine career prospects.

CPA Submission to DEFRA: BNG Exemption for Brownfield Sites- May 2026
CPA responded to DEFRA on a proposed possible exemption from Biodiversity Net Gain (BNG) for some brownfield residential development.
We said that if the government remains committed to BNG, why are they repeatedly seeking ways to enable developers to avoid BNG. We wholeheartedly support the aim of prioritising brownfield sites for development but believe there are other options to minimise viability constraints. Nature should not, once again, be asked to pay the price!
Link:​ CPA Submission
CPA Submission to Environmental Audit Committee on the Role of the Treasury in Climate and Environment - May 2026
CPA responded to a call for Evidence from the Environmental Audit Committee on the role of the Treasury in shaping the UK’s response to climate change, nature loss and wider environmental sustainability. The Committee noted that as the Government’s central economic department, HM Treasury plays a key role not only in fiscal decision making, but also in setting the economic frameworks through which climate and environmental issues are understood across Government.
We said we have seen no evidence of any climate and nature consideration by the Treasury. In fact, we see the opposite. The Treasury has pressurised regulators to regulate for growth. This is an alarming shift in focus.
Link: ​CPA Submission
CPA Submission to the New Towns Draft Programme - April 2026

In March 2026, the government announced a consultation on the draft New Towns Programme, on the preferred 7 locations and the government’s proposed offer to the potential new towns locations.
The 7 chosen locations in the New Towns Programme are:

Tempsford
Crews Hill and Chase Park, Enfield
Leeds South Bank
Manchester Victoria North
Thamesmead, Greenwich
Brabazon and the West Innovation Arc, South Gloucestershire
Milton Keynes

We said in our response that there were remaining fundamental flaws with the New Towns process:

  1. Absence of an overarching strategy
  2. Failure to follow Treasury Green Book requirements
  3. Requirement for substantial Government investment
  4. The case for high-density, brownfield, urban regeneration has not been explored
  5. Greenfield new towns will cause significant harm to the environment
  6. High risk of failure under the current model
  7. Over-reliance on developer assurances
And we remain concerned at the apparent ease with which promoters of the Forest City (450,000 homes for 1,000,000 people in rural Suffolk/Cambridgeshire) have been able to meet and liaise with government ministers.

Link: CPA Submission

CPA Submission on Planning Committee Regulations Reform - March 2026
CPA responded to an MHCLG consultation on proposed reforms to Local Authority planning committee rules and regulations, such as bringing forward statutory guidance for a national scheme of delegation and defining the size of planning committees.
We said that the government’s own response to their previous consultation on Reform of Planning Committees in June 2025 opens with the statement that “Planning is principally a local activity because decisions about what to build and where should be shaped by local communities and reflect the views of local residents”. We requested that they therefore enable applications to be determined by the planning committee if the development does not reflect the views of local residents.
Link:​ CPA Submission
CPA Submission to Human Rights Committee on Security, Safety and Protest - March 2026
CPA responded to a call for Evidence from the Human Rights Committee on one aspect of a call for evidence to examine whether the Government has struck the right balance between its duty to protect the public and its duty to respect the right to protest.
We said there needs to be more understanding of what drives the electorate to protest. The data published should include reference to the alternative options those protesting had available to them prior to reaching the point of protest being the most appropriate action. For example communities faced with inappropriate and unsustainable development have no right of appeal and are likely to have no other option but to protest. 
Link: ​CPA Submission
CPA Submission to the HCLG Committee on Modernising Elections - March 2026
CPA responded to a call for evidence from the HCLG Committee on democratic engagement, foreign political donations and modernising elections.
We said there is currently a huge lack of trust between the electorate and parliament. This is due to the government waging a war on nature that was not set out in its manifesto. The government and prospective future governments MUST be required to use data which is credible and can be validated by the public. The government’s target to build 1.5million homes, for example, is not based on housing NEED (which would instead set a target for social housing for each district), as outlined in our recent report (Homes for Everyone). 
We agreed with Chris Hinchliff MP that there should be a ban on housing developers from donating to political parties. As confirmed in his letter, housing policy should be decided on merit, not money, and it is clear from our recent report (Who pays for Unsustainable Development) that the costs of the influence of the developer lobby are being inappropriately passed to the public sector/taxpayer, households and nature.
We would extend this ban to developers funding think tanks, lobby groups, and/or holding prominent roles within government agencies.
Link: CPA Submission
CPA Submission on Permitted Development Rights for Onshore Wind Turbines - March 2026
CPA responded to a consultation on new PDR that would allow small-scale, non-domestic wind turbines to be installed without the need for a planning application, subject to a set of conditions and limitations, to support small-scale onshore wind deployment.
We said that no development higher than 15m should be within 500m of any residential dwellings, and that we welcomed additional conditions to minimise visual impact on nearby heritage sites and important landscapes.
Link:​ CPA Submission
CPA Submission to Environmental Audit Committee on Data Centre Sustainability - March 2026
CPA responded to a call for Evidence from the Environmental Audit Committee on what kind of implications will data centres have for energy and the environment? How will they impact the already tortuous queues for grid connections and the Government’s plans to bring down energy bills? And what impact will their energy consumption and water usage have on the decarbonisation efforts and viability of other sectors?
We said that whilst we understand the drive to accelerate the number of data centres in the UK, their immense impact on the environment, nature and resources (such as water use) must be considered strategically and controlled tactically.
Link: ​CPA Submission
CPA Submission to MHCLG on Consulting the SoS on Planning Decisions - March 2026
CPA responded to a consultation from MHCLG seeking views on new proposals for a requirement for LPAs to consult the Secretary of State where they are minded to refuse an application, and a single new proposal for LPAs to consult the Secretary of State where they are minded to allow an application.
We said we would not support the Secretary of State overturning anticipated decisions that protect communities from inappropriate or unsustainable development (such as megawarehousing located close to residential properties). And that the government will be aware that natural capital assets are an essential element of their growth ambitions. It should, therefore, be acknowledged that the ONS natural capital accounts demonstrate the importance of the value of nature to the wider economy, which should be taken into consideration when making decisions that may impact our natural capital or ecosystem services.
Link: ​CPA Submission
CPA Submission to Accelerating Electricity Connections - March 2026
CPA responded to a consultation on the electricity network connections process to address speculation and prioritise future capacity for strategic demand including data centres.
We said we were concerned that the government is taking a rather piecemeal approach to identifying strategic demand projects. And that the immense impact of these developments on the environment, nature and resources (such as water use) must be considered strategically and controlled tactically.
Link:​ CPA Submission
CPA Submission to Environmental Audit Committee on Air Pollution - February 2026
CPA responded to a call for Evidence from the Environmental Audit Committee at the House of Commons on Air Pollution. MPs will explore the impacts air pollution has on health across different communities in England, and on the environment, such as through reduced crops, acid rain or biodiversity loss. They will explore whether Government’s current air quality targets are adequate to protect health and the environment, and how these compare with standards by other bodies, such as the World Health Organisation.
We said the lack of requirement to focus on sustainable transport solutions, particularly in major developments, means that targets are not being achieved. Where new road schemes are being proposed, national policy should ensure that planning authorities are mandated to consider alternative (non-road) options to significantly reduce the adverse effects of the proposed schemes and they should be required to demonstrate why more sustainable, less harmful solutions are not able to be delivered.
Link: ​CPA Submission
CPA Submission to Environment Agency on Water Abstraction - January 2026
CPA responded to a consultation from the Environment Agency on water abstraction frameworks and the ‘need for water’ in infrastructure planning.
We said we are concerned that the importance of sustainability and the cumulative impact on water resources is not more prominent within the framework, along with the mitigation hierarchy for understanding the environmental and ecological impact of any proposed scheme.
Link: ​CPA Submission
CPA Submission to MHCLG on the NPPF - January 2026
CPA responded to the NPPF (National Planning Policy Framework) consultation. This draft version of the NPPF included several major changes to plan making and decision making.
We said the NPPF needed a better definition of Sustainable Development which was lacking, and so we provided MHCLG with our own suggestion.
Link:​ CPA Submission
CPA Submission on Plans to Accelerate Digital Infrastructure - January 2026
CPA responded to a government call for evidence on perceived barriers that may exist in the planning system in relation to infrastructure deployment “where otherwise low-impact upgrades or new equipment deployment potentially face avoidable delay and cost”. 
We said that significantly increasing the existing height limits for such infrastructure is likely to have a huge impact on local communities and landscapes (particularly landscapes in protected areas). We believe there should be no increases in limits or reductions in planning safeguards in protected areas. On other sites, the regulations should confirm that any structure that is proposed to be more than 15m in height should be located at least 500m from the nearest residential property.
Link:​ CPA Submission
CPA Submission to House of Lords Regulators and Industry Committee on Economic Growth - December 2025
CPA responded to the House of Lords Regulators and Industry Committee inquiry into the relationship between regulators and economic growth, in light of the Government’s ambition for regulators to support investment and innovation and drive growth.
We said that the government’s emphasis on economic growth is much too narrow. It is exclusively focused on financial prosperity, rather than the wealth to be achieved from a more balanced approach. Ensuring climate mitigation and nature’s recovery, for example, benefit society as a whole and there are economic gains to be achieved from healthy social infrastructure and a thriving natural environment which should be recognised.
Link: ​CPA Submission
CPA Submission to Public Accounts Committee on Environmental Regulation - December 2025
CPA responded to the Public Accounts Committee on the government’s plans to streamline regulation.
We said the government’s emphasis on economic growth is much too narrow. It is exclusively focused on financial prosperity, rather than the wealth to be achieved from a more balanced approach. Ensuring climate mitigation and nature’s recovery, for example, benefit society as a whole and there are economic gains to be achieved from healthy social infrastructure and a thriving natural environment which should be recognised.
In March 2026 the Committee released its findings (here) concluding that environmental regulators are spread too thin to protect nature while delivering reforms.
Link:​ CPA Submission
CPA Submission to Public Accounts Committee on Unlocking Housing - December 2025
CPA responded to the Public Accounts Committee who were looking at factors that could unlock housing delivery.
We urged the Committee to request genuine evidence of the government’s claim that a shortage of land underpins the housing crisis. As can be seen from the data within our recent Homes for Everyone report, there are around 1 million unbuilt homes with planning permission and sufficient brownfield sites to build a further over 1 million homes. There are over a million empty homes, including some 70,000 that are unoccupied council/social housing properties. There are also an estimated 165,000 privately-owned commercial and business premises that remain empty across Great Britain.
Link:​ CPA Submission
CPA Submission on Reforms to Statutory Consultees - December 2025
CPA responded to a consultation on reforming the list of statutory consultees for planning applications. 
We said that the government’s focus on “Ensuring the statutory consultation system supports economic growth” is much too narrow, and the process should also ensure there is sufficient progress with climate mitigation and nature’s recovery.
Link: ​CPA Submission
CPA Submission to Transport Committee: Railways Bill - November 2025, and Joined-up Journeys - August 2025
In November 2025 CPA welcomed the consolidation of rail services under the umbrella of Great British Railways (GBR) and understands that the Bill will establish GBR as the main body responsible for delivering rail passenger services, including setting fares, selling tickets, etc. We agree that this will reduce fragmentation and hope it will result in a simpler, easier, more user-friendly system for passengers.
That said we are concerned that the Bill does not provide the power for the Secretary of State to provide funding to GBR for passenger services.
 
In August 2025 we responded to an Inquiry on achieving and measuring transport integration. The Transport Committee looked at how Government might mould transport services, networks and options around the journeys that people need and want to make in their daily lives.
We said we need a transport system which feels joined up to the user with the ability, no matter where you live, to get from a to b via affordable public transport, within a practical time period, with a range of options based on the distance to be travelled.
Link:​ CPA Submission to Railways Bill
CPA Submission to 3rd Cycling and Walking Strategy - November 2025
CPA responded to the 3rd Cycling and Walking Investment Strategy. In a tick box response we agreed with all proposals that would encourage active travel and remove barriers to people cycling and walking.
Link:​ CPA Submission
CPA Submission to Public Bill Committee: Public Office (Accountability) Bill - November 2025
CPA submitted evidence to the House of Commons Public Bill Committee as they meet to scrutinise the Public Office (Accountability) Bill. We said we would like to see an explicit extension of the duty of candour and assistance to the processes involved within the end-to-end planning system, that the Green Claims Code should apply to those in public office, and there should be compliance with the Civil Society Covenant.
Link: ​CPA Submission
CPA Submission to Office for National Statistics: Topics for the 2031 Census - November 2025
CPA responded to the ONS (Office for National Statistics) on topics about households and transport in the 2031 Census. We asked for more details about how households were forming, their health and working/transport patterns. We also asked that National Park geographies should be included as they are planning authorities.
Link:​ CPA Submission
CPA Submission to Climate Change Committee: 7th Carbon Budget - October 2025

The Climate Change Committee (CCC) is required under the Climate Change Act 2008 to provide advice on the level of the UK’s carbon budgets. Carbon budgets set a cap on the total greenhouse gas emissions the UK can emit over a five-year period and are a key mechanism for ensuring progress towards net zero. The CCC has recently published its advice on the level of the Seventh Carbon Budget (CB7), which will cover the period 2038–2042. This advice sets out the scale of emissions reductions required, the balance between different sectors of the economy, and the role of technologies, behaviour change and economic growth in achieving the targets.

We made a submission on aspects of the carbon budget in relation to planning. In March 2026, the Environmental Audit Committee released its report (link here). We were pleased that our points were recognised. We were the only response quoted for footnote 74, one of three for footnotes 61 and 73, and one of four for footnotes 62 and 181, and we were also quoted on footnotes 166, 188 and 192.

Link:​ CPA Submission

CPA Submission to Parliament: English Devolution and Community Empowerment Bill - September 2025

CPA responded to a call for evidence from the House of Commons Public Bill Committee on the English Devolution and Community Empowerment Bill. The bill sets out standard powers that will be available to ‘mayoral strategic authorities’. This term encompasses mayoral combined authorities and mayoral combined county authorities in England, and also the Greater London Authority. The bill also includes powers for the Secretary of State to mandate local government reorganisation, to a unitary pattern of local government across England.
We focused our response on planning issues, expressing our surprise, given the title of the Bill suggests it will bring ‘community empowerment’, that this is sadly very limited to only community right to buy.  We encourage the government to introduce other reforms to genuinely empower communities, including. amongst others:

  • mandating that high-quality early, meaningful and constructive engagement and consultation, in line with the Gunning Principles, the Civil Society Covenant and the Green Claims Code, is carried out from the earliest stage of any initiative proposed by a public body  
  • ensuring that all public bodies have a ‘Statement of Community Involvement’, which is developed (and, where necessary, updated) in consultation with the communities they serve
  • introducing balance of influence, and reducing bias, in the planning system, including by providing a right of appeal for communities, particularly when an application does not comply with local development plan policies, and by providing funding to communities who are successful in securing permission to judicially challenge a planning decision
  • ensuring that all citizens are able to actively participate in planning-related meetings, hearings and inquiries, by mandating the provision of online access and recordings of all such events.
Link: ​CPA Submission
CPA Submission to MHCLG: Streamlining Infrastructure Planning - September 2025
CPA responded to MHCLG on its consultation on streamlining infrastructure planning. This consultation sought views on several key proposals that would support the application process for development consent under the Planning Act 2008, such as new guidance about consultation and engagement following removal of statutory pre-application consultation requirements through the Planning and Infrastructure Bill, the use of Initial Assessments of Principal Issues (IAPI) to focus examinations, guidance for public bodies about their role in examinations and changes to secondary legislation related to the examination of applications including compulsory acquisition.
We said that the public should be fully consulted on the principle of development, prior to any NSIP being proposed. 
This means ensuring that the consultation on National Policy Statements must meet the requirement for “high-quality early, meaningful and constructive engagement and consultation”, to ensure that consultation takes place before a decision is made, and that conscientious consideration is given to feedback from communities and citizens. There should be no compromise of the commitments agreed in the government’s Civil Society Covenant.
Link:​ CPA Submission
CPA Submission to House of Commons Environmental Audit Committee: Environment in Focus - September 2025
CPA responded to a call for topics for future investigation from the House of Commons Environmental Audit Committee.  They asked for potential topics with 250 words on ‘The Environment in focus’ proposals on what the Committee should investigate next and why, within the areas of climate change, the environment and nature. The winning proposal will form the basis of a new inquiry by the Committee.
We suggested the EAC should investigate failures to align the planning system with nature/climate goals, the harms caused to the environment by the government’s policies and government rhetoric about delays within the planning system caused by environmental/ecological considerations.
Link:​ CPA Submission
CPA Submission to DEFRA: Modernising Environmental Permitting - September 2025
CPA responded to DEFRA on its consultation on reforms to the environmental permitting framework for industrial emissions. The consultation sets out a wide variety of regulatory reform.

We said we were supportive of aspirations to deliver cleaner power, improved air quality and less polluted waterways, and appreciated the focus on supporting innovation in emerging technologies and hoped it will include nature-based solutions.  We also welcomed the aim to deliver more efficient and effective regulation, whilst recognising that cutting bureaucracy must not result in increased risk of harm. However we pointed out our concerns about the cumulative impact of the government’s multiple changes to policy and regulations that could result in more ecological and environmental harms, fewer safeguards for public health and social wellbeing, ultimately undermining the safety of the public and bird/wildlife species.  This does not appear to have been considered in any of the consultations to date.
Link: ​CPA Submission
CPA Submission to HM Treasury: Land Remediation Relief - September 2025
CPA responded to HM Treasury on its consultation about land remediation relief. We welcomed the focus on incentivising the regeneration of brownfield land and reducing the pressure to develop greenfield sites and said we would be keen to see the brownfield first approach mandated in policy (it is currently possible to propose developments on greenfield and Green Belt land, even where there is significant suitable, available and achievable previously developed land in district Strategic Housing and Employment Land Availability Assessments – SHLAAs/SELAAs).
Link: CPA Submission
CPA Submission to House of Commons Justice Committee: Access to Justice - August 2025
CPA responded to a call for evidence from the House of Commons Justice Committee on how advice and legal services are adapting to secure access to justice across civil, criminal, and family law.  It will focus on the scope for future innovation in the nature of services, funding, regulation and technology to support effective access to justice in England and Wales.
We focussed our response on justice in the planning system, which we believe is a component of civil law.  The current government is adversarial, calling communities Nimbys, Blockers and Zealots, and referring to those requesting judicial review as obstructive, suggesting that they are propagating a ‘challenge culture’ .  This is unreasonable and their attempts to accelerate growth at any cost undermines scrutiny, democracy and the rule of law.
Link:​ CPA Submission
CPA Submission to Parliament HCLG Committee: Affordability of Home Ownership - August 2025
CPA responded to a call for evidence from the Housing, Communities and Local Government Committee at Parliament on the topic of housing affordability and particularly access to home ownership for first time buyers.
We said that market house prices have been manipulated by large corporations and have risen sharply over the last few decades as the big developers have acted as a ‘cartel’ to inflate house prices to maintain their profit levels and dividends. We suggest that ​first time (and other) house buyers are frequently gazumped by investors.
Link: ​CPA Submission
CPA Submission to DEFRA: BNG Minor/Medium/Brownfield Thresholds - July 2025, and ​BNG for NSIPs - June 2025
CPA responded to DEFRA on its consultation about changing thresholds and possibly removing obligations for Biodiversity Net Gain on smaller sites; Improving the implementation of Biodiversity Net Gain for minor, medium and brownfield development.
We also responded to the consultation on how Biodiversity Net Gain should be applied to NSIPs – Nationally Significant Infrastructure Projects.
Link: CPA Submission on BNG Site Thresholds
Link: CPA Submission on BNG for NSIPs
CPA Submission to CMA: Proposed Commitments by Housebuilders after Anti-competitive Conduct Investigation - July 2025
CPA responded to a consultation by the Competitions and Markets Authority following an investigation into suspected breaches of competition law by the 7 largest housebuilders. The CMA was asking whether they should accept proposed commitments by the housebuilders to pay a “fine”, agree new processes and thereby avoid further investigation into any
anti-competitive conduct.
We said the “fine” and the proposals by the housebuilders do not go far enough and that the remedy proposed is so insignificant (in both financial and process terms) that it will not deter similar breaches in the future (from these and other providers).
Link:​ CPA Submission
CPA Submission to DEFRA: Expanding the Role of the Private Sector in Nature Recovery - June 2025
CPA responded to a call for evidence from DEFRA on expanding the role of the private sector in nature recovery.  The government is interested in better understanding how to support and incentivise business to invest in nature recovery. They are interested in how to enable those economic sectors which impact or depend upon nature the most to invest in reducing the environmental harms of their operations while growing natural capital. They want to hear from businesses, investors, and innovators on how to protect the natural foundations of the economy – and in doing so, secure sustained and resilient growth nationwide.
We said they were starting from the wrong premise that everything must support economic growth. And ​given that the voting public consistently expresses a desire for policymakers to take stronger action to protect the environment and the countryside, there should be an overarching objective that requires all businesses to avoid harm to the natural environment, firstly by choosing where development is located, or by taking other actions to protect the most valuable land
Link: ​CPA Submission
CPA Submission to MHCLG: Implementing Measures to Improve Build Out Transparency - June 2025
CPA responded to an MHCLG technical consultation seeking views on proposals to introduce a new statutory build out framework which requires information to be submitted at different stages of the planning and development cycle and the power to decline to determine applications.
Link: CPA Submission
CPA Submission to MHCLG: Working Paper on Speeding Up Build Out - June 2025
CPA responded to an MHCLG working paper which invited views on further action the government should take to speed up homes being built. It sits alongside the government’s technical consultation on requiring transparency and accountability measures for build out rates on housing sites (see above). 
Link:​ CPA Submission
CPA Submission to MHCLG: Working Paper on Reforming Site Thresholds - June 2025
CPA responded to an MHCLG working paper on reforming site thresholds by removing and streamlining disproportionate requirements on small and medium sites, while maintaining and strengthening requirements on major development. It explores how different site sizes should be treated within the planning system and considers the case for removing barriers specific to developers in this part of the sector.
Which all sounds fine, until you realise that this just leads to a situation which exempts small sites (under 10) and possibly medium ones (10-50) too, from providing all sorts of necessary infrastructure and biodiversity gains.
Link: ​CPA Submission
CPA Submission to MHCLG: Reform of Planning Committees - June 2025
CPA responded to an MHCLG technical consultation seeking views on proposals around the delegation of planning functions, the size and composition of planning committees and mandatory training for members of planning committees.
Which all sounds fine, until you read the consultation which effectively removes the right of the public, and even elected councillors, to consider a large tranche of application sizes and types in public forum.
Link: CPA Submission
CPA Submission to Lords Built Environment Committee: New Towns Delivery - March 2025
CPA responded to a call for Evidence from the Lords Built Environment Committee for an inquiry into new towns and expanded settlements. Over a series of short, targeted modules, the Committee aims to discover whether new towns and expanded settlements are an effective means of delivering housing and, if so, how to ensure they are successful.
Link:​ CPA Submission
CPA Submission to DfT: A Railway Fit for the Future - March 2025
CPA responded to the Department for Transport consultation on “A Railway Fit for the Future”. The government were seeking views on new policies to be included in the forthcoming Railways Bill, which will enable the establishment of Great British Railways (GBR). They see GBR as a single directing mind that will run rail infrastructure and passenger services in the public interest.
Link: ​CPA Submission
CPA Submission to DEFRA: Land Use in England - March 2025

CPA responded to the consultation by DEFRA on land use in England in March 2025.  The government said “At a national and local scale, we need better spatial planning. For too long, a haphazard approach has been taken to the way infrastructure is sited or homes are built. In order to grow the economy and meet the challenges of future decades, we need to use our data to make better decisions. This will also bring better lives – supporting homes to be built where there is access to water and clean air, and major infrastructure built where it least disrupts nature.”

We said the document appeared to start from the premise that there will be a need to change land use or production on agricultural land.  This is incorrect.   All the suitable, available and achievable brownfield land should be used first, followed by brownfield land that requires remediation.  Housing and employment space should not be considered for greenfield sites until all that brownfield land is fully utilised. We prepared a summary briefing, link below. And to read our full response, also link below.

Link: CPA Briefing
Link: CPA Full Submission
CPA Submission to MHCLG: Working Paper on Streamlining Infrastructure - February 2025

CPA responded to a working paper from MHCLG, rather than a formal consultation, on a new approach which proposes  “a number of measures that could be taken to streamline the consenting process for national infrastructure and to enable faster decision-making, whilst ensuring the process is fair and certain.”

We said that there are enormous risks associated with aiming for speed for speed’s sake, without thinking about what outcomes are required. Given the aim is to achieve an “outcomes-focused system”, it would seem obvious that, in fact, what matters is getting the right infrastructure in the right place, with minimal harm to the environment, communities and the local economy where that infrastructure is to be located.

Link:​ CPA Submission
CPA Submission to Integrated National Transport Strategy - February 2025
CPA responded to the Integrated National Transport Strategy “call for ideas” in February 2025.  We said ​if the strategic intention is to enable modal shift to more sustainable transport options, this MUST be reflected across all policy areas.
This should ensure that new road building is agreed by exception only. All public funds should be prioritised for sustainable passenger and freight transport (and for maintaining existing roads).
Link: CPA Submission
CPA Submission to MHCLG: Working Paper on Planning Committees - January 2025
CPA responded to the Integrated National Transport Strategy “call for ideas” in February 2025.  We said ​if the strategic intention is to enable modal shift to more sustainable transport options, this MUST be reflected across all policy areas.
This should ensure that new road building is agreed by exception only. All public funds should be prioritised for sustainable passenger and freight transport (and for maintaining existing roads).
Link: CPA Submission
CPA Submission to Environmental Audit Committee: Flood Resilience - January 2025

CPA submitted a response to the UK Parliament Environmental Audit Committee who asked for evidence on flood resilience.

​Land use strategies which cover all the ecosystem and natural capital services provided in an area are an essential tool for ensuring that climate mitigation, future food security and nature’s recovery are all considered as an equal priority alongside growth and development.

We said that the starting emphasis should be on natural flood management techniques, such as wetland restoration, river re-wiggling, pond creation and tree planting. Peatland and wetland restoration, for example, provides many benefits in addition to supporting huge levels of water capture and storage (including carbon sequestration and biodiversity gains).

Link:​ CPA Submission
Link: Environment Audit Committee Call for Evidence
CPA Submission to Environmental Audit Committee: Environmental Sustainability and Housing Growth - December 2024

CPA submission in December 2024 to the UK Parliament Environmental Audit Committee who asked for evidence on the Government’s proposed new NPPF.

Our submission states that CPA does not believe that the revised NPPF will support the protection and enhancement of the environment.   The approach taken by the Government to setting housing policy risk placing growth and targets above all other factors, at great risk to the natural environment.    The environment is barely an afterthought and, instead of setting policy that aims to meet the need for homes (as opposed to demand) while also protecting the environment, Government has placed the onus squarely on meeting un-evidenced housing targets that do not solve the housing crisis.  

Our assertion, in a paper due to be published soon, is that we can have homes for everyone (people and nature included) long before we have to tap into our precious green spaces.  This can be done by insisting on a greenfield last approach in which greenfield can only be built on once a council has demonstrated that it has renovated empty homes, repurposed commercial buildings, encouraged letting of rooms in houses, reused all brownfield land, maximised density and seen the majority of planning permissions built out.  Clearly this will need support and financing from the Government.

​We note that, while Labour’s manifesto pledge was for 1.5m homes, its proposed Standard Method results in 1.85m homes and that, in addition to this, there will be new towns of 10,000 homes or more.  As far as we are aware, there has been no Sustainability Appraisal for the proposed NPPF, the Standard Method, for the new towns, nor for the cumulative impact of these initiatives.

​Link:​ CPA Submission
Link: Environment Audit Committee Call for Evidence
CPA Submission to MHCLG: Working Paper on Development and Nature Recovery - December 2024

CPA responded to a working paper from MHCLG, rather than a formal consultation, on a new approach which proposes  “using funding from development to deliver environmental improvements, and moves more responsibility for these improvements onto the state rather than developers. The aim of this approach is to free up and accelerate development while ensuring better environmental outcomes.”

We said that the starting point should not be that nature is in the way of development. Nature is not only essential for our existence, but brings many benefits, too, as set out in the Dasgupta Review. There is a risk with the proposals in the working paper that developers will manipulate the system to use it as a ‘pay to harm’ approach to obtaining consent for inappropriate projects in the wrong place.

Link: CPA Submission
CPA Submission to New Towns Taskforce: Call for Evidence - November 2024
CPA submission on 13 November 2024 to the New Towns Taskforce led by Sir Michael Lyons. The consultation was a “call for sites” for potential new settlements of over 10,000 dwellings. But that rang so many alarm bells that we felt compelled to write.  We see this as approaching the selection of new towns from the wrong direction. Surely start with a national land-use strategy to work out where you need development?
​Link:​ CPA Submission
CPA Submission to MHCLG: Working Paper on Brownfield Passports - October 2024
CPA responded to a working paper from MHCLG, rather than a formal consultation, on Brownfield Passports. We said communities should drive Brownfield redevelopment initiatives such as these in the most suitable locations in their areas, including repurposing commercial and retail sites for residential, where that is appropriate.
Link: CPA Submission
CPA Submission to Office for Environmental Protection - September 2024
The Office for Environmental Protection (The OEP) was established by the Environment Act 2021 to protect and improve the environment. They do this by holding government and other public authorities to account against their environmental responsibilities and the law. This consultation was about an update to their starting strategy.
Link: CPA Submission
CPA Submission to MHCLG: Proposed Reforms to the NPPF - September 2024
CPA submission on 6th September 2024 to Government proposals to change the National Planning Policy Framework and to introduce a new mandatory standard methodology for calculating housing targets.
Link:​ CPA Submission
CPA Submission to DLUHC: Street Vote Development Orders - February 2024
CPA submission on 1st February 2024 on government plans for Street vote development orders, described as “an innovative new tool that will give residents the ability to propose development on their street and, subject to the proposal meeting certain requirements, vote on whether that development should be given planning permission.”
Link: CPA Submission
CPA Submission to Competition and Markets Authority: The Housing Market - December 2023

The CMA has published the initial findings of its housebuilding market study, and is suggesting far-reaching, community-excluding, changes to the planning system. 

Obviously, no-one would disagree with its starting premise that everyone needs a place to live.  But this study has blundered straight into the elephant trap and assumed that the market (developers) can deliver all housing need.  The seemingly dramatic under-delivery against housing targets that the report cites is because the market will not meet social housing needs.  It never has.  

There are two studies, and a series of detailed questions in the reports themselves.

Link: CPA Submission
CPA Submission to DLUHC: Reforms to Plan-making - September 2023
CPA submission on 6th September 2023 to Government proposals to make plans simpler, faster to prepare and more accessible. We agree that local plans do need standardising, digitising and simplifying, and communities do need to be engaged better and earlier, so the proposals set out in this consultation are a positive step forward. We propose a Community Engagement soundness test for Inspectors to evaluate at examination stage.
Link: CPA Submission
CPA Submission to DLUHC: Reforms to Permitted Development Rights - September 2023
CPA submission on 6th September 2023 on plans to extend PD rights. In general we are in principle very supportive of the need to re-use existing buildings for housing and, in the countryside, also for commercial purposes. But Permitted Development powers are already extremely wide ranging – in some cases far too wide ranging already and we explain our concerns.
Link: CPA Submission
CPA Submission to DEFRA: Protecting Hedgerows - July 2023
​On July 12th 2023 CPA made a submission to DEFRA in response to its consultation on protecting hedgerows ​
Link: CPA Submission
CPA Submission to National Highways: RIS3 Shaping the Future of England's Strategic Roads - June 2023

CPA made a submission on 21st June 2023 to the proposals made in National Highways’ Initial – Report Shaping the future of England’s strategic roads. The report outlines National Highways’:

  • view on the current state of the strategic road network (SRN)
  • potential future needs
  • proposed priorities for the next road period (RP3), covering the financial years 2025-26 to 2029-30
Link to National Highway’s Consultation: shaping-the-future-of-englands-strategic-roads
Link: ​CPA Submission
CPA Submission: Strategy and Policy Statement for Energy Policy - June 2023
In June 2023 the government held a consultation on its policy for the delivery of energy infrastructure and how to provide the legal framework for planning decisions. The link to the consultation page and the accompanying policy statements, the link is here:
Link: CPA Submission 
CPA Submission to Commons Levelling-Up Committee: Planning Reform - March 2023
CPA submission stating that we support in general the aims of the Levelling Up and Regeneration Bill (LURB), for a genuinely plan-led system, stronger voice for communities, community infrastructure by developers, clear design standards that reflect community views, enhanced protections for our precious environmental and heritage assets.
Link: committees.parliament.uk/writtenevidence/119717/pdf/
CPA Submission: Reforms to National Planning Policy - February 2023
CPA submission to proposals in the Levelling Up and Regeneration Bill (LURB) on Reforms to National Planning Policy, where we suggested a better method of calculating housing “need, and a much more sensible Standard Method with constraints included at the start, and using up-to-date household and affordability projections.
Link: CPA Submission
CPA Submission: Proposals to reform the Human Rights Act - March 2022
Article 6 of the Human Rights Act protects our rights to a fair and public hearing.  This means that if a public authority is making a decision that has a impact upon your civil rights or obligations (in this context, your civil rights and obligations are those recognised in areas of UK law such as property law, planning law, family law, contract law and employment law) you have a right to a fair and public hearing, which is held within a reasonable time, giving you all the relevant information, allows you representation and is followed by a public decision.  In addition, you also have the right to an explanation about how the decision-making authority reached its decision.
Link: CPA Submission  
CPA Submission to National Highways: RIS3 Route Strategies Consultation - December 2021
In December 2021, CPA submitted a response to National Highways consultation on Road Investment Strategies 3.
We said that Government should stop building new roads, as the Austrian government has recently announced, but that in the event that the RIS3 programme does go ahead then there need to be changes to the way options are evaluated.
We would like alternatives to be compared directly with new roads, and we believe that externalities such as illness from air and noise pollution, plus road deaths and injuries, should be taken into consideration. We also believe that a natural capital assessment must be made of all habitats to be lost if a road is built.
Link: CPA Submission
CPA Submission: ​National Infrastructure Planning Reform Programme Consultation - December 2021
In December 2021, the CPA submitted a detailed response to the National Infrastructure Planning Reform Programme consultation. 
We are concerned that the consultation focuses on speed and that the current system is too reliant on infrastructure projects that are proposed at a stage at which alternatives (that may be better for communities, the planet and the public purse) are not able to be considered.
The passing of the Environment Act provides the ideal opportunity to take a new approach. We must start by defining the problem, and then enable all stakeholders to discuss the full range of solutions. Read the rest of our suggestions by clicking on the link below.
Link: CPA Submission
CPA Submission to Environmental Audit Committee: Consultation on Natural Capital - December 2021
In December 2021, CPA submitted a response to the Environmental Audit Committee on their questions as to how Government uses GDP in setting macro-economic policy and how it affect the development of environmental policy and of cross-departmental action to achieve the UK’s environmental goals?

Our recommendations were:

  • A Treasury team to be set up to lead and coordinate Natural Capital initiatives cross-government;
  • Natural capital and inclusive wealth should be prioritised in the Green Book so that it is the starting point for the evaluation of all projects. The Green Book should be updated to incorporate the Dasgupta Review findings;
  • Natural capital to be placed at the heart of the planning system so that professional judgement is supported by analysis and appropriate tax & accounting incentives:
  1. Natural capital calculations to be compulsory in local plan making;
  2. Paragraphs 8 & 11 of the NPPF to be re-worded to include natural capital;
  3. Tax & accounting incentives to be aligned with environmental outcomes;
  4. Alternatives to be assessed using natural capital analysis and to include ‘do nothing’
  • Appointment of an experienced corporate figurehead to liaise with parties most affected by a move to inclusive wealth instead of GDP..
Link: CPA Submission
CPA Submission to Lords Select Committee for the Built Environment - September 2021
In September 2021, CPA submitted a response to the House of Lords Built Environment Committee, which launched an inquiry on the demand for new housing in the UK and how barriers to meeting this demand can be overcome.
In summary we proposed that the inquiry should recommend the following actions:
  • A review of the national housing target, with Census 2021 data as the trigger;
  • That Government policy should deliver for housing need, not just demand, and for renters as well as home buyers, while investment in social housing must be prioritised;
  • The need for far greater and more meaningful community participation, not less, across the planning system, so that outcomes are improved for everyone. And that genuine community participation should be a core component of all future planning policy, including mandatory referendums for Local Plans.
You can read our full submission by clicking on the link below.
Link: CPA Submission

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