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28 September 2011
Department for Communities and Local Government
National Planning Policy Framework
Zone 1/H6
Eland House
Bressenden Place
LONDON
SW1E 5DU
Dear Sir
DRAFT NATIONAL PLANNING POLICY FRAMEWORK
I am writing in response to the consultation on the
draft NPPF. I have separately tried to fit our
comments into the on-line template but found this less
than satisfactory because the questions do not cover
the entirety of the document, or the comments we want
to make, and it was impossible to convey a sense of
narrative.
The Horsham Society is one of the largest amenity
societies in the south of England with over 1250
members. Our location within the Gatwick Diamond
exposes us to a wide range of development pressures
and planning, both strategic and local, is a major
concern of the Society.
We welcome the objective to simplify the planning
process, particularly the over-complex LDF process.
Few outside the professional planning arena understand
it and as a result it seems remote and unconnected to
local people. A single Local Plan is a good idea.
The present National policy framework is over-wieldy
and inaccessible. Because of the way it is organised
into subject areas it is susceptible to being
over-influenced by interest groups and is difficult to
understand as a whole. But it is important not to
throw the baby out with the bath water. Care needs to
be taken that the NPPF provides sufficient detail to
enable Authorities to control development where and
when appropriate. There is a real risk that specific
omissions from the NPPF will be seen as being more
significant than intended.
The emphasis on economic growth and economic benefit
may have damaging consequences in the longer term.
For example, green space surrounding settlements and
heritage assets once lost cannot be replaced even if
the economic case for change is not maintained in the
long run. It will be very difficult to put a price on
the economic benefit that open space and heritage
assets bring to a community.
The lack of a sound definition of “sustainable
development” will lead to interminable debate,
countless appeals and geographic inconsistency. It
needs to be firmed up and capable of commonsense
interpretation without recourse to the Courts.
There is potential for conflict and misunderstanding
between the presumption in favour of sustainable
development and the concept of plan led development.
There needs to be a clear presumption that if a Local
Plan identifies sufficient developable land to meet
properly identified local need, and the Plan is
endorsed by an Inspector at public examination, that
it will be able to resist applications for development
(however “sustainable”) outwith the Plan.
The loss of a presumption in favour of brownfield
development is a mistake. Unless this is reinstated
developers will always choose
greenfield sites in preference thus slowing or
stopping the essential process of regeneration in all
but the highest value locations.
There is an unresolved tension between National
priorities, Local Plans and the localism implicit in
Neighbourhood plans. It is unrealistic to believe
that consultation and regard for local views will
solve this.
Whilst it is reasonably clear how Neighbourhood plans
might be put together by villages or even small towns
where there is a strong community and sense of
belonging, it is hard to envisage how it would work at
anything more than the most simplistic level in
larger, more complex towns without the support of the
local planning authority. This would appear to
undermine or negate the neighbourhood concept.
There needs to be a recognition within the NPPF of the
importance of place making, community cohesion and
their relationship to the appropriate size of
settlements. Some towns, such as Horsham, have
already reached (arguably, over-reached) the maximum
size consistent with retaining a sense of belonging
and common cause. Simplistic adoption of
sustainability criteria could lead to existing
communities getting ever larger.
Settlement coalescence is a major threat to local
communities and green belts have an important role to
play, as do strategic gaps which we consider should be
reintroduced as a planning tool. It should be easier
to establish new green belts, or strategic gaps, and
the emphasis in central policy should be on testing
their appropriateness and scale rather than
discouraging them.
Specific encouragement should be given in the NPPF to
the creation of sustainable new towns and villages as
an alternative to further growth of existing
settlements.
The proposed Local Green Space designation is welcome
in principle but rather than suggest it for
exceptional use national policy should encourage its
use, particularly to protect the small but essential
green spaces that are a feature of many of our urban
areas.
Whilst, as with current policies, the draft supports
the need for good design there is little or no
evidence that the quality of design, particularly new
housing estates, has improved; indeed the reverse is
true. Increasing demands for sustainability surely
require a radical new approach to housing design but
developers are risk averse and planning authorities
appear to lack the will or the means to bring about
change.
The requirement on local authorities to plan for the
infrastructure required to support development fails
to recognise that there are vital elements which are
entirely outside their control or influence such as
health and hospitals, railways and national road
transport. There should be a requirement on national
infrastructure agencies to take account of and help to
facilitate local needs and wishes in drawing up their
strategies.
The suggestion that authorities should be required to
provide for additional allowance of 20% above the
assessed housing need is a crude and excessive
response to a problem that requires a different
solution. There is a significant weakness in the
present planning system which allows large developers
to accumulate land banks, and to fail to build out
sites which have planning consent, which removes
flexibility and competition. Local Authorities need
to be given powers to require developers holding land
which has been identified as suitable for housing
either to build out at the rate assumed in the Local
Plan, or their planning consents, or to offer it for
disposal at current land value to other developers
prepared to do so.
Yours faithfully
John Steele
Secretary, Planning Sub Committee |
