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DRAFT NATIONAL PLANNING POLICY FRAMEWORK
NB
This is not designed to be a comprehensive description
of the document
This
was published on 25 July and the consultation period
ends on 17 October.
The
NPPF will replace almost all current National planning
policy contained in Planning Policy Statements,
Planning Policy Guidance, and sundry other documents,
reducing it from around 900,000 words and 1,000 pages
to just 52 pages.
The
golden thread is the presumption in favour of
sustainable development. The Government’s top
priority in reforming the planning system is “to
promote sustainable economic growth and jobs“, and to
ensure “that the sustainable development needed to
support economic growth is able to proceed as easily
as possible”.
The
intention is that the existing plan-led approach will
continue but the emphasis will be on development plans
being kept up to date in identifying and accommodating
development needs.
The
draft makes it clear that “planning must encourage
growth and not act as an impediment”.
Despite the emphasis on “sustainable development “ the
draft offers little by way of a definition. The
Ministerial foreword says “sustainable means ensuring
that better lives for ourselves don’t mean worse lives
for future generations” and “development means
growth”.
Later
the draft says that delivering sustainable development
means planning for prosperity (an economic role),
planning for people (a social role) and planning for
places (an environmental role); and these should be
pursued in an integrated way looking for solutions
that deliver multiple goals.
The
Local Development Framework approach will be replaced
by Local Plans which should be in place as soon as
possible. They must be succinct and will be examined
by a Planning Inspector. Plans must be based upon and
contain the presumption in favour of sustainable
growth and have clear policies showing how the
presumption will be applied locally. They must plan
positively for development, cover a 15 year horizon
(and beyond), set out strategic priorities, allocate
sites for development, identify land which it is
genuinely important to protect from development and
contain a strategy for environmental enhancement of
the area. The Local Plan is meant to be a single
inclusive document eliminating the need for most if
not all SPDs.
In
the absence on an up to date and consistent Local Plan
planning applications will be determined in accordance
with the NPPF, including its presumption in favour of
sustainable development.
Local
Plans must be based upon a clear set of evidence about
the economic, social and environmental characteristics
and prospects of the area, including a strategic
housing market assessment.. The intention is that the
supply of housing of all types will be boosted. Plans
must identify and maintain a rolling supply of
specific deliverable sites sufficient to provide five
years worth of housing against the assessed housing
requirement, and an additional 20% “to ensure choice
and competition in the market for land”. Generally,
no allowance may be made for windfall sites in the
first 10 years of supply, or in the rolling five years
supply. To promote sustainable development, housing
in rural areas should not be located in places distant
from local services.
There
is an emphasis on promoting good design and protecting
and enhancing rights of way and access to open space.
There
is a new Local Green Space designation but the
emphasis is on “local” and the NPPF makes it clear it
will not be appropriate for most green spaces.
There
is a duty on planning authorities to cooperate on
strategic planning across local boundaries and this
will need to be evidenced in Local Plans.
Much
continues to be made of Neighbourhood Plans but it is
clear that these must be consistent with Local Plans
and will be subject to local examination before they
can be put to a referendum. This means that
Neighbourhood plans will be able to opt for more
housing and other development than provided for under
the Local Plan, but not less.
Although this is still a consultation, Planning
Inspectors have already been told that the draft NPPF
may be cited as a material consideration at appeal.
What
does it mean for Horsham?
It is
not clear what the status of the current LDF will be
pending the development of the new Local Plan because
it presumably “lacks conformity”, not having been
written with a presumption in favour of sustainable
development. But it must be better than no plan. Or
at least it would have been but for the Council’s
decision to scrap its Interim Statement designed to
cover the current shortfall in deliverable housing
sites over the next five years.
Under
the LDF process planning authorities were not allowed
to include, or repeat, National planning policies
because these were deemed to be given. With the
demise of almost all the existing National policies it
is likely that planning authorities will want to
include some aspects of these in their Local Plans.
Whether the Inspectors will allow such reintroductions
must be in doubt so considerable skill will be needed
to devise Local Plans which provide appropriate
safeguards without appearing to recreate old National
policies at local level.
HDC
will be reviewing its housing needs assessment over
the next few months. Given that the Local Plan must
encourage economic growth it seems inevitable that we
will need to provide for considerable numbers of new
homes, even if much of the business expansion is in
other parts of the Gatwick Diamond. Much will depend
on how the term “sustainable” is defined as things go
forward but it is entirely conceivable that the
outcome will simply be an accelerated expansion of
existing larger communities and towns. The NPPF is
silent on new towns.
The
need to keep the Local Plan both short and all
inclusive begs the question of what will happen to the
local design statements which are currently dopted as
SPDs.
The
role of and interest in Neighbourhood Plans will only
become apparent over time. One can see these being
attractive to small, cohesive communities and here
they might augment or replace local design
statements. But in the case of large towns like
Horsham probably only the District Council could
reasonably be expected to coordinate the production of
a Neighbourhood (or Town) Plan.
Even
assuming the NPPF goes ahead without substantial
change it will not be until Inspectors start examining
the first Local Plans that it will become clearer
whether the new system is truly plan-led, or instead
becomes a developer-led free for all .
Meanwhile we can expect developers to test the
robustness of the current LDF by bringing forward
applications for land not currently identified for
development and citing the NPPF on appeal.
JSS
15 August 2011
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