Draft National Planning Policy Framework (NPPF)
Comments from Chester Civic Trust (CCT)
The Chester Civic Trust (CCT) is a local voluntary organisation influencing the quality of our built environment. We have well over 400 members drawn from all walks of life. The trust is a registered charity with no political affiliations, recognised by the local authority as a non-statutory consultee and our independent views are widely respected by local decision makers.
The area covered by CCT equates to the whole of the previous City of Chester local authority area. It covers not only the historic city but also a large surrounding rural area. It has a lengthy boundary with Wales.
Overall Comments
1. CCT agrees with the Government that the current planning system is too centralised, bureaucratic, and often remote from the communities it affects. We welcome the changes that free communities from unnecessarily prescriptive central government policies, and empowers local councils to deliver innovative solutions that work for their local area.
2. The reduction of national planning policies from over 1,000 pages into a user-friendly, accessible and much shorter document is welcomed. However, there are a number of occasions where brevity has been at the expense of clarity; CCT believes that communities and their environments will suffer as a result.
3. Whilst members of Chester Civic Trust agree that good planning should help provide new housing, act as a catalyst for growth and jobs, protect the environment, and give local people a genuine say in developing the character of the places where they live and work, they are concerned that the draft Framework appears to be skewed to favour economic over social and environmental considerations.
4. The CCT believes that removing the priority for brownfield development is wrong. When re-drafted, the Framework should give local planning authorities the ability to require new development to reuse previously developed land before building on greenfield sites.
5. It is surprising that there are no policies aimed at securing balanced employment and housing development across the country to support a growing population and to promote growth.
6. CCT believes that the NPPF should cover all forms of land use and so should include sections on Waste Management and Travellers.
Delivering Sustainable Development
The presumption in favour of sustainable development
Para 14. The problem that may arise from the ‘presumption in favour of sustainable development’ where the local plan is absent, silent or out of date is that not even up to date plans can have policies relevant to all development possibilities. This may lead to lengthy local plans that try to anticipate every possible development and this will be counterproductive.
If existing local plans can’t be used to determine development proposals, the NPPF will not be sufficient to cover local circumstances, as it is too broad brush, leaving a policy vacuum where inappropriate development would be allowed through on appeal. This will be a particular problem for sensitive historic cities such as Chester where the existing local plan has yet to be replaced with the local development framework.
Para 17. It is doubtful if many neighbourhoods would be willing to plan positively for more development especially where they see the impact of new development as a threat to their existing local amenity.
Para 18. Reference to good design is welcomed but the draft NPPF is weak on how should this be judged and what weight should be placed on this against the ‘presumption in favour’.
Core planning principles
Para 19. The emphasis that planning decisions should be ‘plan led’ is welcomed but the lack of resources in LPAs due to public sector spending cuts will limit capacity to achieve widespread coverage of up to date plans for some time to come. The NPPG is neither sufficiently detailed nor relevant to local circumstances to fill the gap and relevant regional strategies are to be abolished.
Plan Making – Local Plans
Para 20. “Objectively assessed development needs that should be met” cannot be done solely at the local planning authority level. Strategic planning at the sub regional and regional is also very important. This should be part of the statutory planning process so that problems of local co-operation can be overcome.
Para 26. The phrase “as soon as practical” is too vague. A more precise figure in terms of months or a particular date for certificates of conformity to be in place should be given here.
Housing and business requirements
Para 28 and 29 Will the requirement to work with neighbouring authorities extend across national boundaries? In particular, will the Welsh Planning Policy document include a similar requirement?
The need for all types of housing should include student accommodation where this is appropriate e.g. in university cities
Historic environment
Para 37. The requirement to have up to date evidence about the historic environment in the area is welcomed. This will beneficial for historic cities like Chester.
Planning strategically across local boundaries
Para 45. The NPPG should state what happens if adjoining authorities cannot agree on strategic planning priorities, especially if the adjoining authority is in Wales?
Para 46. These are weak mechanisms to support co-operation across LPA boundaries in the absence of a formal common plan dealing with identified ‘strategic priorities’. How will these common policies be tested and co-ordinated comprehensively if they are in individual plans that reach examination at different times? This will not work in practice.
Why should an LPA meet unmet requirements for development from a neighbouring authority without the need to conform to an over-arching strategic plan? What is the incentive apart from the proposed ‘duty to co-operate’?
Development Management
Paras: 56, 57,and 58. The encouragement for pre-application engagement and front-loading consultation is welcomed. The local civic trust could offer expertise to developers relevant to local areas in planning, architecture, conservation and local community issues in advance of a planning application being made. Hard-pressed LPAs may struggle to find time or afford expertise for effective pre-application advice.
Planning for People
Housing
Para 111 (first bullet point) should include accommodation for students (where appropriate)
Design
Para. 120. The need for LPAs to have local design review arrangements in place and the need to refer appropriate projects for a national design review (via CABE) is welcomed. The local civic trust could assist with this requirement.
Para 121. The statement that permission should be refused for development of obviously poor design that fails to take opportunities available for improving the character of an area and the way it functions is welcomed. The question is how this will be weighed against the ‘presumption in favour of sustainable development’ and if no up to date local plan policies are available.
Para 122. The need for developers to engage with the community in developing the design of new development is welcomed, but what if they don’t.
Sustainable Communities
Paras 130 and 131. The proposals for the designation of ‘local green spaces’ is welcomed.
Planning for Places
Historic Environment
Para. 178. CCT supports the requirement for a strategy for ‘the conservation and enjoyment of the historic environment’, but the NPPG should be clear about the weight this will be given in development management decisions.
Paras 187 and 188. CCT supports the requirement that the impact of new development on the setting of heritage assets should be considered. This is particularly important in historic cities like Chester where inappropriately designed new development (of which there are some recent examples) can spoil the setting of historic buildings and townscape.
19 September 2011
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