The Jubilee Mosaic

The Society supports the government’s intention in reducing the current extensive volume of central policy and guidance on planning matters and in giving local communities a greater say in planning decisions affecting their areas. There is much in the Framework that it supports such as the plan driven approach, pre-application engagement , the establishing of local standards (eg for car parking) and the importance given to neighbourhood plans.

It is however seriously concerned that the effect of the changes in this guidance will not achieve these objectives, and will move the balance drawn between developer and community interests to the detriment of communities. It is also concerned that the Framework appears to see environ-mental concerns and infrastructure deficiencies as of limited importance. Additionally, there is a real danger that, in reducing national policy to this extent, valuable guidance is lost.

It challenges the Treasury led assumptions that, in any fundamental way, the planning system is hampering economic recovery and that a more overt pro-development stance will in some way kick-start the economy. Global markets and the sovereign debt crisis are, among others, the real drivers.

Local Communities already see the system as heavily weighted towards development interests and local planning authorities have always had to give good reason for refusal of applications. The appeals system allows 33% of applications refused by local authorities – an adequate ‘safety valve’.

Neither is the current lack of new housing the fault of the planning system. Latest statistics show that 86% of all applications decided by District Planning Authorities are approved. Even for major residential developments, 79% are approved. House building locally and nationally may well have ‘fallen off a cliff’, but the planning system is not the cause. The reasons are again financial – availability of mortgage funding, high initial deposits, lack of public funding for social housing. First time buyers cannot get mortgages and those on low incomes cannot get off the housing waiting list.

POINTS OF OBJECTION

Areas such as ours (Farnham in Waverley) are under severe development pressure with the area’s assets - its environment (towns, villages and countryside), its accessibility to London and good educational provision all drawing in more people. Its infrastructure (such as roads and schools) is strained and the environment, which is so valued, faces damage from those who seek to enjoy it. Those on low incomes have difficulty in purchasing in the housing market with high entry prices. There are many other areas like ours in the South East and elsewhere.

The Farnham Society is not opposed to development, but it has to be at a quantity and pace, and of a design, that can be absorbed without destroying the qualities of town and country and the distinctive identity, which we value highly.

The draft NPPF appears to significantly increase the risk of damage to our local community and its environment in particular. The Farnham Society specifically objects to

an unclear and misleading definition of ‘sustainable development’, in which the ‘development component’ dominates (Ministerial Introduction)

the unbalanced emphasis on growth (eg in paras 10,13) and its strongly pro-development stance - the references to the ‘golden thread’ and the default answer being ‘yes’.

the references in paragraph 10 to ‘planning for people’ should include a reflection of community aspirations and involvement which is as fundamental as other elements mentioned.

the presumption that where the plan is ‘absent, silent, indeterminate or out of date’, planning permission should be granted. In the absence of plan guidance, the application should be considered on its merits in the same way as any other application. (para14). There should be no built in assumption that permission will be granted. The purpose seems to be to penalise less assiduous Local Planning Authorities, but in reality it is local communities that are penalised.

the centrally imposed limits to community decision making : if local communities favour growth then the district/neighbourhood can make their own decisions. If the local wish is to limit growth, then that is not acceptable. Neighbourhood Plans are a welcome innovation as is the suggestion of their precedence over local plans (para 50). However, community expectations are likely to be disappointed by the significant limitations that result from the requirement for conformity with strategic plans. (paras 49-51)

the limited references to supportive infrastructure required such as schools, health, sewage disposal. While this is mentioned (para 31) in relation to plan making, and some infrastructure such as transport and telecommunications get specific coverage, others do not. There is little recognition, that these are a constraint to growth and that as they become increasingly strained, the quality of life for the community reduces

the weakening (para 39) of the ability of LPAs to require contributions towards infra-structure costs or provide even a modicum of lower cost housing through the contentious matter of ‘viability’. The discussions involved in such assessments are often commercially sensitive and therefore not transparent to the communities affected. If a project cannot ‘afford’ essential infrastructure and basic community requirements, then it should not proceed.

the lack of reference in para 20 to community involvement, collaboration and aspiration in plan making. It is important that this been seen as a central and not a subsidiary requirement, implied by leaving these considerations to para 25

the inclusion of the suggestion that Development Management is used to ‘hinder and prevent’ development (para 53). This implies a view of objections to development which denies objectors that right, and fails to recognise the ‘mediation’ role of the planning system where inevitably there are winners and losers – where there are always pluses and minuses. The primary objective of development management is to assess each development on its merits – its benefits and dis-benefits – in the context of local communities and wider policy.

the lack of any reference in Development Management to the importance of Enforcement in delivering a credible planning system, and the need for more effective and timely processes and penalties for breaching control.

an excessive requirement for LPAs to identify land for housing (para 109) through

meeting ‘the full requirements for market and affordable housing’

an additional allowance of 20% ‘to ensure competition and choice’

no allowance for windfalls in the first 10 years of the plan

Identifying more land in areas of high demand will compound problems leading to even higher demand later. Constraint in time over supply is essential to a flow of development which the community, its environment and its infrastructure can absorb.

While paragraph 110 allows Local planning Authorities to argue that the adverse impacts of meeting these’ objectively assessed’ development needs would significantly and demonstrably outweigh the benefits’, the message is clear and prejudices the outcome in high demand areas .

This situation is exacerbated by lack of a speedy and workable mechanism for considering housing market or wider areas, many of which cross local authority boundaries, other than a duty to cooperate – the consequence of ‘ throwing the baby out with the bathwater’ in abolishing the SE and other Regional Plans. Establishing working mechanisms will further delay up to date plan production demanding and absorbing more resources.

the lack of reference to developing brownfield land as a first priority for development (para 109)

an ambivalence in the approach to protecting business land, responding to short term market pressure and higher land values for alternative uses thus increasing business costs when recovery comes. (para 75)

the lack of a sequential test for office development in terms of location in town centres (para 77) thus increasing the pressure for peripheral growth.

the lack of protection for the countryside for its own sake or strong protection of the best agricultural land. (para 167)

a failure to consider the landscape value of areas outside AONBs and National Parks – in Waverley, Areas of Great Landscape Value often abut, protect and are of similar quality to AONBs (para 167)

The lack of any specific reference to the contribution culture, the arts, theatres, galleries, museums or libraries make to ensuring that communities thrive. PPS 4 accepts specifically that the arts and culture are important elements of town centre development. Such resources need a profile in the NPPF which gives them priority and a degree of protection against competing commercial uses.

The statement (para 151) that planning ‘permission should not be refused for well- designed buildings or infrastructure which promote high levels of sustainability because of incompatibility with existing townscape unless the concern relates to a designated heritage asset’. The quality of existing townscape should always be a substantial consideration and this statement considerably undermines that concern. It is not clear whether heritage asset includes Conservation Areas.

CONCLUSION

In the Society’s view the NPPF and changes to the planning system in the Localism Bill should provide convincing support for the following five principles

1. An approach to sustainable development that really balances environmental, social and economic priorities rebalancing the planning system in its favour.

2. A simplified approach to local planning which is quicker, cheaper and less bureaucratic on which final decisions are taken locally.

3. Democratic and local control which allows local people real engagement in developing a vision for and shaping the places in which they live and crucially in making decisions.

4. A requirement that local planning authorities to actively engage with rather than ‘consult’ local communities - a ‘bottom up’ approach.

5. Using and supporting volunteers to assist communities in developing plans reflecting local aspirations.

The Government would claim that the changes it has initiated do just that, but in our view, they fail to deliver that promise.

While there is much of value in the NPPF, its adoption as national policy as it stands may well damage Farnham and its surroundings. It re-defines sustainable development as growth, and will undoubtedly result in greater pressure for more building in this area than the current draft Core Strategy for Waverley envisages. The presumption in fovour of development will undermine local decision making and render the welcome concept of Neighbourhood Plans a rather hollow one.

The draft policies in the NPPF are underpinned by a drive to permit development, not by any real recognition of environmental limits or restraints, nor by problems which many area such as ours face with infrastructure deficiencies.

The planning system did not lead to the collapse of housing market or low levels of economic growth, but it is in danger of being appropriated to drive growth forward at the expense of communities and the environment.

The draft NPPF should be revised to set out a sustainable vision for England, removing the presumption in favour of development. It should recognise environmental and infrastructure limitations and promote economic activity which sustains and involves communities.

THE GOVERNMENT'S RESPONSE

Thank you for your letter of 17 October about the draft National Planning Policy Framework.

The aim of our reforms is to simplify a system that most people agree has become complex and confrontational, and to emphasise the central and critical role of the local plan to decision making. That is why we intend to abolish regional strategies using powers that are provided in the Localism Act and why the draft National Planning Policy Framework distils over 1,000 pages of national policy into around 50.

While many groups have welcomed the proposals, some have expressed concerns that they could lead to inappropriate development. We are determined that this will not be so. The policies will include rigorous protection for the Green Belt, for National Parks, Areas of Outstanding Natural Beauty and Sites of Special Scientific Interest, and give local people the right for the first time to protect other green space that is important locally.

We need homes for young people and for growing families, and we need Jobs in expanding businesses. But this must not - and will not - be at the expense of our natural and historic environment. The draft makes clear, for example, that sites of the lowest environmental value - including so-called brownfield land - should be used as a priority.

Similarly the presumption in favour of sustainable development, is not a loophole to allow any development. What the presumption says is quite simple: that local plans should set out what is needed in each area, that development in line with those plans should be approved without a delay, and that in the absence of an up-to-date plan, the policies in the draft National Planning Policy Framework should guide decisions -including its requirement for development to be sustainable.

We are now considering all the suggestions that have been made as part of the consultation and we will ensure that the policy the Government adopts will continue to protect our much loved countryside while also enabling local people to plan for the sensible and well-designed development that provides the homes and jobs on which the future prosperity of their community depends.

James van Dorp