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 Planning: strategic issues

August 2011 



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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