NPPF action points revised

[Hannah Bourne-Taylor]

Hi again,

If you haven’t emailed the government yet, here is a more detailed instruction, with the help of our resident expert planner, Mike.   

I remain sceptical of the NPPF because although it is a legal requirement, the policies within it have only a legal requirement to be considered so in other words, there lies a big loophole. 

See action points below. Mike will send a suggested SLN response soon. This is long but v important !!!! 

Best, and thank you Mike,

Hannah 

 

I contact you all to encourage you to send an email between now and the 10th

March to the government as part of the consultation for the NPPF (National Planning Policy Framework).

 

Any queries, let me know. This isn’t about getting a response – it’s about

letting them know formally so that there is a collective voice coming through as they assess.

In case you aren’t aware, the government could upgrade to Building

Regulations at any point as it’s secondary legislation so would only

require a consultation period and a relevant Minister to sign the Statutory

Instrument to amend. Also, there will be a relevant parliamentary bill in

the next session so keeping the pressure up is important.

Michael Gove as former Secretary of State (who infamously blocked this)

told me in person during the summer that mandating swift bricks is entirely

operable – which Scotland has just proven so easily – so don’t believe them

when they repeatedly fob us off.

 

 

 

As you know the government announced an update to the draft NPPF for England regarding swift bricks in December 2025.

National Planning Policy Framework: proposed reforms and other changes to the planning system -

GOV.UK

<https://www.gov.uk/government/consultations/national-planning-policy-framework-proposed-reforms-and-other-changes-to-the-planning-system>;

 

This is the action that in theory is great but will be too slow to come into force to make any meaningful difference, taking several years to filter through Local Plans and even then compliance levels can be low.

Anyone is invited to have their say until 10th March when the consultation

closes for the draft of the NPPF. The worst case scenario would be that

industry lobby groups successfully remove or water down the drafted policy.

Voicing our collective concern that policy is not enough would

help balance any counter lobby taking place and at the very least, if there

is a risk of them removing or watering down, then they may think twice. In

other words, we must keep telling them that we are watching their every

move as this government is not an ally to birds, nor are the civil servants

who had the audacity to tell me that they were blocking it as recently as

April due to swift bricks and boxes not working. Unbelievable. The RSPB’s

expert was incredible with putting them right immediately if anyone is

shocked by that as I was.

 

These types of consultations mainly go unnoticed by members of the public

and so the balance is often skewed as the industry lobby groups will be all

over them, so I can’t stress the power and importance of your voice here. 

 

-Emailing and writing would be ideal

 

-Signing off stating your swift group – if you are a member – would be great

 

-Getting everyone in your swift group to write and email would be ideal

 

*Email: *

 

PlanningPolic...@communities.gov.uk

 

*Write:*

 

Planning Policy Consultation Team,

Planning Directorate – Planning Policy Division,

Ministry of Housing, Communities and Local Government,

Floor 3, Fry Building,

2 Marsham Street,

London,

SW1P 4DF

Be sure to include the following information as you begin (in whatever

wording you want of course)

‘With regards to the N2: Improving the natural environment paragraph 017 –

incorporate swift bricks into all new developments’….. 

 

Optional points to include:

- I support the addition of swift bricks to the NPPF,

although I believe this should be in Building Regulations because:

the time taken between publication of the NPPF and adoption in Local Plans, plus subsequent time between award of planning permission and commencement of construction, is unacceptably long given the rapid rate of decline of populations of swifts and other cavity-nesting birds;

local authorities implement the NPPF inconsistently so there are variable requirements between authorities for both the Local Plan and wording of planning conditions, which is confusing for developers and leads to non-compliance;

a lack of post-construction site checks means that levels of non-compliance can be high;

enforcement action with regard to planning conditions can be "discretionary", and there is already evidence that some identified incidences of non-compliance are not resolved.

 -Westminster as recently as October 2025 has explained that mandating swift

bricks isn’t easy and yet Scotland made the decision to legislate in a

month, proving just how simple amending primary or secondary legislation

could be for swift bricks.

 

To improve the NPPF wording, please:

1. cross-reference the existence of NPPG Natural Environment 2025 paragraph 017 from the NPPF, because it will be easy for local authorities to observe the NPPF clause but overlook the existing and more detailed text in the NPPG. It would be even clearer if the full text of paragraph 017 is included in the NPPF;

2. refer to the necessity of a post-construction check in the NPPF, as including this requirement in the planning condition is the main route to achieving compliance with the relevant planning conditions.

[Mike Priaulx]

Hi all,

Just confirming I won't now be sending separate guidance on the NPPF consultation,

so please follow Hannah's advice below.

All the best,

Mike

Member of SLN Swifts & Planning Group

(NB I'm not actually a planner, but have worked in construction long enough that Stonehenge was one of my later projects :-))

NPPF action points revised

Hannah Bourne-Taylor <hannahbou...@gmail.com>: Feb 04 12:21PM