I completely understand if not
everyone wants to spend time ploughing their way through the draft national
planning policy framework. Not all of
you reading my blog are insomniacs (or maybe you are?) But for communities working on neighbourhood
plans – or who are now sitting back having got said plan through its referendum
– it is worth making a few points back to the planning ministers to make sure
all this effort is not undermined by some careless wording in the national plan.
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:
https://www.gov.uk/government/consultations/draft-revised-national-planning-policy-framework
