There is a little footnote in paragraph 14 which is about those times when there is a housing shortage, and the presumption in favour of sustainable development. This little footnote clarifies what "recently brought into force" means, and this determines whether full weight should be given to your neighbourhood plan. What it says is that your plan needs to be less than 2 years old. This basically means that to keep your plan effective, you need to start reviewing it before the ink has dried. And even then you still won’t win. Let’s face it, although it is theoretically possible, I don’t think any group in the country has managed to get a plan through the system in under 2 years. Even Local Plans have a ‘5 year review’ expectation, and they don’t have to go through a referendum. Why isn’t your plan at least ‘good enough’ for 5 years?To make this point >>> complete Q4 of the response form!
One point that is welcome is that housing requirement figures for designated neighbourhood areas will be set through strategic plans (see paragraphs 66 and 67). This give local people the opportunity to input into this process, particularly as a simple formula-based approach to determining a figure is not going to be appropriate in some areas.To make this point >>> complete Q14 of the response form!
There are some parts of the NPPF that haven’t changed, that perhaps should.Paragraph 51 on prematurity is one such example. At the moment, as soon as some landowners find out that their site is not likely to be included in the plan (ie as soon as the results of the site options consultation are published), they feel they have nothing to lose by submitting a speculative outline application to get in ahead of the neighbourhood plan. Yet the prematurity argument doesn’t kick in until after the pre-submission and the examination consultations, which is easily another 4 to 6 months. We need the NPPF revised to say that, in areas progressing a Neighbourhood Plan, major applications will be considered premature by the time the pre-submission draft is published unless it is clear that the proposals are supported by the community.
To make this point >>> complete Q10 of the response form!
Another example is the simplistic stance that the "most recently adopted plan" takes precedence (paragraph 32). Which means that generic policies in a revised Local Plan, that are not tailored to an area, should arguably trump more detailed policies in an adopted Neighbourhood Plan. Wouldn’t it be better to get the planning authority to publish a statement to clarify which Neighbourhood Plan policies (or parts) would remain in force, and those which are superseded, as part of their plan-making process?To make this point >>> complete Q6 of the response form!
There a many other points I could add, but if you are still awake, you can always contact me if you are interested…The link to the consultation and response form is here: