Consultation Responses

Our response to the Law Commission's review of the Landlord & Tenant Act 1954 recommends shifting to a contracted-in approach and removing security of tenure for leases of five years or less. We also highlight how reforming the Act would support redevelopment, refurbishment, decarbonisation and economic growth.

Our response raises concerns about the proposals to expand the scenarios whereby a landowner could be deprived of market value for certain forms of brownfield and land allocated for housing in a local plan. Our submission notes the proposals could have unintended consequences of increasing uncertainty in the land market ultimately leading to fewer sites coming forward for housing development in overall terms.

We welcome the proposed new approach and support any measures which simplify and speed up the development process whilst protecting and restoring nature. Developers who want to use existing approaches, however, should be able to “opt out” of the new arrangements. Consultation with the sector will be key, including consultation on the design of the new developer contribution.

The BPF has submitted its 2025 Spending Review Representation, highlighting the property sector’s vital role in economic growth, housing delivery and clean energy. We call on the Government to remove barriers to investment, boost institutional funding and embrace PropTech innovation to support a thriving industry that contributes £110bn annually and sustains 2.5m jobs.

We welcome the opportunity to respond to the HM Treasury consultation paper on the case for a UK Green Taxonomy. Our response focuses on the fundamental question of whether a UK Green Taxonomy would help the real estate sector, and the UK economy more broadly, achieve its sustainability ambitions.

Our response notes that compliance with a new regulatory regime is likely to be more challenging for landlord-run heat networks and does not easily fit within existing landlord and tenant/housing legislation. We also call for certainty to allow existing property developers, landlords and other stakeholders to prepare for the impact of new regulation.

Our response welcomes the proposals to introduce a national scheme of delegation to create a more consistent approach to determining which applications go to planning committees, and which can be decided by planning officers. We also provide feedback on how councillor training can be made effective in practice as well as commenting on how the operation of planning committees can be improved more broadly.

The Government has ambitious targets to deliver 1.5m homes over this parliamentary period and increase the delivery of social housing. Such ambitions can only be achieved with ambitious policies, and the support of all sources of investment – public, not-for-profit, and for-profit.

To help meet there targets, we recommend the Government considers a rolling 10-year statement, so long as there is a default position and presumption in favour of continuing to roll the current agreement, rather than a reopening of the debate each year.

Earlier this year, we submitted evidence to the House of Lords Built Environment Committee, highlighting the challenges high streets face in repurposing underused properties. Key obstacles include high conversion costs, structural constraints and issues with our planning system. Tackling these requires reforms in business rates, streamlined planning and strong local partnerships to drive revitalisation.

We have responded to the Government’s Invest 2035 consultation, highlighting the vital role of the property sector in supporting high-growth industries. While we welcome the focus on subsectors, we emphasised the need for strategic planning, improved infrastructure and addressing barriers such as planning delays. We also stressed the property sector’s contribution to economic productivity and its potential to drive sustainable innovation.

The Government is considering what form brownfield passports might take as it seeks to support more brownfield development. This represents the BPF’s response to a discussion paper issued at the end of September 2024.

The BPF strongly welcomes the consultation proposals to put development activity at the heart of the Government’s growth agenda and achieve a step change in housing delivery. We suggest ways in which the positive multi-tenure approach to housing can be improved further as well as setting out how the promising proposals for planning for employment can be even more impactful to deliver more economic growth and jobs.