10 June 2018
Q2 Do you agree with the changes to the sustainable development objectives and the presumption in favour of sustainable development?
No, we don’t agree with the presumption in favour of development while ‘sustainable’ as the underpinning principle has not been sufficiently defined at this point in the document. Much of the document seems to be defining sustainable simply as achieving a target for house construction rather than considering conservation, environment, sustainable transport, renewable energy and other aspects generally meant by the term ‘sustainable’.
Q3 Do you agree that the core principles section should be deleted, given its content has been retained and moved to other appropriate parts of the Framework?
No, the core principles underpin sustainable development so should be retained listed in detail.
Q4 Do you have any other comments on the text of Chapter 2, including the approach to providing additional certainty for neighbourhood plans in some circumstances?
11. b) There is no definition of ‘neighbouring’.
14. b) housing delivery is not in the control of the planning authority. There could be many reasons why developers don’t wish to develop the sites available and which have nothing to do with the planning policy framework.
Q6 Do you have any other comments on the text of Chapter 3?
16. c) The definition of sustainable mainly as providing a supply of new housing does not give local communities any say in the amount of development since housing targets are not worked out locally but centrally, and ignore many local circumstances.
Q7 The revised draft Framework expects all viability assessments to be made publicly available. Are there any circumstances where this would be problematic?
No, viability assessments should always be publicly available.
Q8 Would it be helpful for national planning guidance to go further and set out the circumstances in which viability assessment to accompany planning applications would be acceptable?
Viability assessments should be used only at the plan making stage, apart from in truly exceptional situations. This should be stipulated and what constitutes exceptional should then be described in detail so that there is strong guidance for what is exceptional. Viability assessments that accompany planning applications generally prevent the delivery of affordable housing and therefore, as a general rule, they should not be allowed to accompany planning applications.
Land values have been kept artificially high by the allowance of viability assessments with planning applications. If everyone knows that affordable housing targets will be enforced then the market price of the land will reflect this. The land can then be purchased at the correct price for a development that includes affordable housing and the development will then be viable. The expectation that affordable housing can be avoided by the use of a viability assessment results in a market price that reflects this expectation; the resulting higher land price then makes the inclusion of affordable housing unviable.
Q10 Do you have any comments on the text of Chapter 4?
We would like fees for retrospective planning applications to contain a significant uplift on standard fees, to encourage correct engagement with the planning system.
Q12 Do you agree with the application of the presumption in favour of sustainable development where delivery is below 75% of the housing required from 2020?
No. There are many reasons for the current under delivery of housing, some causes being within the control of developers (eg restricting the release of completed properties to keep buyers’ interest and prices high); some are the result of the social and political landscape (eg shortage of skilled labour); and of course economic and market conditions are important factors (eg uncertainty about the future); but unrealistically high land prices must be the single most significant factor. None of these factors are within the control of local authorities. This section should be omitted, especially since Sir Oliver Letwin MP’s report into build-out rates has not yet been published.
The majority of the respondents to the initial consultation opposed the proposed new methodology, which makes one wonder why it has been included.
Q13 Do you agree with the new policy on exception sites for entry-level homes?
No. The requirement for affordable housing should underpin all housing site planning and it should not be used as an excuse to build on sites that have not been identified in the plan. This would provide a loop-hole for developers to build on any available land and should be deleted.
Q15 Do you agree with the policy changes on supporting business growth and productivity, including the approach to accommodating local business and community needs in rural areas?
No. Developments outside settlements should not be permitted unless there is an overriding local need. Allowing out-of-town development where there is no public transport increases car use. Sustainable growth has to be low carbon to be sustainable.
Q16 Do you have any other comments on the text of chapter 6?
82. Why has the reference to economic growth being low carbon been deleted even though no substitution has been made? It must be made clear that sustainability is to underpin all development.
Q21 Do you agree with the changes to the transport chapter that point to the way that all aspects of transport should be considered, both in planning for transport and assessing transport impacts?
No. A key point in the original NPPF, that plans should support patterns of development which facilitate sustainable transport, has been omitted. Also omitted is the specific objective of cutting greenhouse gases. These points should be reinstated.
Q22 Do you agree with the policy change that recognises the importance of general aviation facilities?
No. Expansion of aviation facilities is not compatible with the UK’s obligations under the Paris Agreement.
Q25 Do you agree with the proposed approaches to under-utilised land, reallocating land for other uses and making it easier to convert land which is in existing use?
We would like to see a recommendation that brownfield sites are periodically assessed for regarding wildlife habitats and reclassified if they are found to be valuable for wildlife.
It is important that the pressure to provide housing sites does not lead to the loss of local businesses and services within communities.
Q26 Do you agree with the proposed approach to employing minimum density standards where there is a shortage of land for meeting identified housing needs?
Although minimum density standards may be appropriate in some areas, they would need to be applied with caution to preserve a pleasant living environment.
Q32 Do you have any comments on the text of Chapter 14?
The text in the original NPPF should be retained in many paragraphs instead of the revised:
147 Planning’s contribution has been downgraded from “plays a key role in helping shape places to secure radical reductions in greenhouse gas emissions” to “helps to shape places in ways that contribute to”. Also
“This [tackling climate change] is central to the economic, social and environmental dimensions of sustainable development” has been omitted.
The original text should be reinstated because development cannot be sustainable without tackling Climate Change.
148 The inclusion of overheating is welcome, but planning’s role in making liveable places in a changing climate should be clearer.
149 The clear instruction in the existing NPPF that “local authorities should plan for new development in locations and ways which reduce greenhouse gases” has been changed to “Development should be planned for in ways that can help to reduce greenhouse gas emissions through its location, orientation and design.” The original NPPF text gave a more central role for reducing greenhouse gases and should be retained.
Listing the “ways” to reduce greenhouse gas emissions is limiting.
The revised text has omitted the explicit support for energy efficiency improvements.
This is important because it gives weight to measure against other considerations.
150 What is meant by ‘a positive strategy for energy from heat’?
The text in the original NPPF of “Design their policies to maximise renewable and low carbon energy development” should be retained instead of “maximises the potential for suitable development”.
152. The proposed viability test is unnecessary since viability is applied to the plan.
153 The local community’s views should be considered for all development proposals, not just wind energy developments.
Q34 Do you agree with the approach to clarifying and strengthening protection for areas of particular environmental importance in the context of the 25 Year Environment Plan and national infrastructure requirements, including the level of protection for ancient woodland and aged or veteran trees?
The protection for woodland and aged trees is welcome, however under strengthening protection for areas of particular environmental importance we would like to see the Forest of Dean listed.
Q35 Do you have any other comments on the text of Chapter 15?
The revised NPPF does not adequately reflect the 25 year plan. Many requirements in the 25 year plan need to be included in the revised NPPF so that they become planning policy. Unless the 25 year plan and the NPPF are closely cross referenced, the policies in the 25 year plan will not be implemented.
Q37 Do you have any comments on the changes of policy in Chapter 17, or on any other aspects of the text of this chapter?
204. a) On-shore oil and gas development, especially unconventional hydrocarbons is incompatible with a transition to a low-carbon economy. Fracking releases methane which is a far more potent gas in global warming than carbon dioxide.
Too much weight is given to access to minerals. There should be more emphasis on finding other resources, such as recycled plastics in buildings and roads and renewable energy. Extraction of minerals is often harmful to the environment and to local communities. Minerals are often in places that are inappropriate in regard to planning policy plans and in regard to road provision. Access to minerals should no longer be regarded as an important need which overrides the usual planning requirements, with the exception of access to particular stone for the use of renovation of listed buildings.
In particular 202 f) should be omitted. There should be no landbanks. While a supply is assured then the industry will not seek innovative and sustainable solutions.
Q42 Do you think that any changes should be made to the Planning Policy for Waste as a result of the proposed changes to the Framework set out in this document? If so, what changes should be made?
Waste should be regarded as a resource to be reused.
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