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 Planning: strategic issues

October 2011 

28 September 2011


Department for Communities and Local Government

National Planning Policy Framework
Zone 1/H6
Eland House
Bressenden Place



Dear Sir





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