The consultation sought views on proposed revisions aiming to accelerate housing delivery, infrastructure, and environmental rules. 

The National Landscapes Association's full response is available here, and centres on six key points.

1. We welcome the change from ‘landscape and scenic beauty’ (current NPPF para 189) to ‘natural beauty’ N4 (1) in the proposed draft, as this aligns better with the underpinning legislation for National Landscapes.
2. We have concerns that some of the wording changes in the draft NPPF will inadvertently reduce protections and lead to the degradation of nationally designated protected landscapes. These changes include some crucial and long-standing tenets of the protection, merit and scrutiny afforded to these places by Local Planning Authorities, developers and others; removing these would convey the message that such scrutiny or merit is no longer warranted.
3. There needs to be a better way for decision-makers to differentiate between the many ‘substantial weights’ now proposed in the draft – the current parity of weights looks neat but fails to recognise the statutory, nationally designated status of National Landscapes and National Parks, which has a greater weight than other considerations without a statutory basis. We recommend that the ‘substantial weight’ of the draft should therefore be reverted to the current ‘great weight’ when referring to protected landscapes.
4. We think that Spatial Development Strategies (PM1) offer the opportunity to create genuinely holistic spatial strategies for delivering affordable homes, healthy and green neighbourhoods, space for nature, sustainable living and vibrant communities, sufficient provisioning and accessible routes and ways. Considering protected landscapes at a genuinely strategic scale should be a critical component of such strategies, and the NPPF revisions should require that National Landscapes, National Parks and National Trails are considered as critical national infrastructure or as key components of such Spatial Development Strategies.
5. It is critical that a consistent position is taken to major development in protected landscapes at both plan-making and decision-making stages. In the draft NPPF, there are several policies that create inconsistency, which we expect will give rise to confusion.
6. The emphasis in the current NPPF requires strategic policies and plans to address economic, social and environmental priorities together, as well as to conserve and enhance landscapes and address climate change. These are not carried forward into the draft NPPF. We are concerned that this discontinuity would have the effect of deprioritising the environment in plan-making, thus upsetting the balance of sustainable development.