When someone mentions the ‘Draft National Planning Policy Framework Consultation’, the average person’s response will be to go glassy-eyed and reach for the Rennies.
Please will you allow me a thousand words to try to convince you that this is something where you need to pick up a pen - before the consultation period runs out in 17 October?
The Framework is the outcome of a basic Tory feeling that planning rules – the ‘centralist diktats of Whitehall’ – are restricting much-needed economic growth and development. The primary aim of the Framework, therefore, is to replace the existing 1,300 pages of rules with 52 pages of general principles.
What do you reckon to this? My fear is that, in what is essentially a quasi-judicial matter, the 1,300 pages were there because they covered every situation; I fear that ‘general principles’ will not be enough to stop all those situations where a development can ruin an area.
The underlying principle of the Framework is to free up planning so that it does not restrict development. To this end it includes (paragraph 13, but repeated endlessly) ‘a presumption in favour of sustainable development’ – basically, that where planning permission is sought for infrastructure, industry, housing, or local services, ‘the default answer to development proposals is “yes”’, as long as the development is ‘sustainable’. Some developments – such as wind farms – will be ‘sustainable’ by definition, since they provide low-carbon renewable energy.
What do you reckon to this? My personal feeling is that it would leave our precious places desperately vulnerable to ‘predator’ developments.
The Framework states that it is deliberately making its stipulations as minimal as possible (paragraph 5). It requires Local Authorities to prepare a ‘Local Plan’, including the presumption in favour of sustainable development; but, further, requires them also to avoid duplicating planning processes in the Neighbourhood Plans. And ‘Neighbourhood Plans’? Well, the Framework states that they ‘will be able to relax controls for particular development … where this will boost enterprise and growth’.
Are to beginning to get scared? Amidst all these requirements to allow more and more flexibility and freedom, what I am wanting to know is where would this Framework define and prohibit UNacceptable development?
In this respect, paragraph 14 contains an even more terrifying provision – that a Planning Authority must grant permission ‘where the plan is absent, silent, indeterminate or out of date’.
So here was have a Framework which has abolished 1,300 pages of planning rules, has itself remained explicitly vague, has instructed Local Plans not to impinge on areas addressed by Neighbourhood Plans, has instructed the Neighbourhood Plans to concentrate on development opportunities … and then tells developers that if they find a loophole in all this, planning permission must be granted. Worrying.
Above all, this convinces me that – if the Framework becomes law – the Town Council MUST develop a comprehensive Neighbourhood Plan, taking advantage of its proposed power to define WHERE development will take place, and also the ‘Local Green Space’ where our community might wish to rule out development.
Paragraph 19 contains a controversial idea. At the moment, developers must use brown field sites first, before they are allowed to develop green field sites. Paragraph 19, by contrast, would require planners to consider applications on land ‘regardless of its previous or existing use’. Bodies like the National Trust are opposing this because they see it as carte blanche to build on Green Belt land. Here in Newton Aycliffe we might be less hostile, because there are a number of brown field sites, long unused, which we now see as valuable green space within our communities, and we would prefer to see ‘islands’ of development beyond the current boundaries of the town, rather than ‘infilling’ on brown field sites which will ‘fill up’ and overcrowd our community.
There are lots of things in the Framework that you might want to support. Paragraphs 76-80 set out principles for the development of town centres which make generally hopeful reading.
Also, paragraphs 107-113 set out principles for the provision of housing, many of which you will probably agree with – not least, the right to ‘set housing density to reflect local circumstances’. This is what we have been trying to get for ages; why should we in the north-east (where land is plentiful) be forced to build housing estates at the high densities required down south (where land is scare) – why can’t we build spacious estates which will attract residents who don’t want to be crowded like sardines in a tin?
On the other hand, I personally am going to challenge paragraph 113, which would prohibit building isolated homes in rural areas, and paragraph 119, which states that – when it comes to architecture – ‘high quality and inclusive design goes beyond aesthetic considerations’ (i.e. that it doesn’t matter what a building looks like as long as it is doing its job). Paragraph 151, similarly, prevents planning authorities refusing permission on the grounds that a new building does not fit within an existing townscape as long as it has a wider social, economic or environmental benefit.
And I think we all need to oppose paragraph 146, which will make it virtually impossible to stop renewable energy development on green belt land. (Similarly paragraph 153 allows energy companies – after an authority has set criteria to define where it will accept renewable energy – to build wind farms ANYWHERE those criteria apply.)
Finally, paragraph 172 instructs planning authorities that, where pollution is an issue, they must assume that pollution control regimes will operate effectively, and judge the application only on whether the development is an acceptable use for the land, and not on what would happen if things went wrong. This, too, I find alarming.
If I was being negative, I would be saying that this Framework delivers us into the hands of the developers. The fear is that we will end up having to allow predator development on our most beautiful and precious sites because the Framework has taken away all our powers and rights to say no. On the other hand, there is a lot in the Framework with which you may want to agree.You can access the Framework online, and you can send in your comments by email or by post (to Alan C Scott, NPPF, Eland House, Bressenden Place, London SW1E 5DU). If you reply online, you can simply fill in a survey-monkey of 18 ‘ticky-box’ questions with space to comment.
Consultation ends 17 October.
I urge readers to respond.