The National Planning Policy Framework (NPPF)

Today, I responded to the consultation on the Government’s draft National Planning Policy Framework (NPPF). To give a flavour of the representation, I have listed a few extracts below:

The “presumption in favour of development”

The document contains a “presumption in favour of development.” It also states that “decision-takers at every level should assume that the default answer to development proposals is yes” and that councils should grant consent where local planning documents are “silent, indeterminate or dated.”

We share the concerns of the National Trust who believe that the new planning rules could mean “unchecked and damaging development … on a scale not seen since the 1930s” and the Campaign for the Protection of Rural England who believe the reforms “will place the countryside under increasing threat and leave local communities and planning authorities largely powerless in the face of developer pressure.”

We oppose the “presumption in favour of development” and would welcome a more balanced approach to the assessment of planning applications, that appropriately weighs up both the merits and disadvantages of individual schemes.

A plan-led system?

Mebyon Kernow – the Party for Cornwall is a strong supporter of a plan-led system in planning. But here in Cornwall, the undemocratic imposition of a single unitary authority (in place of seven former councils) has meant that the development of a Local Development Framework for Cornwall has suffered considerable delay.

If the “default answer to development proposals is yes … where local planning documents are silent, indeterminate or dated” that therefore puts Cornwall and its communities at a great disadvantage and many more sub-standard developments may be allowed as a consequence.

Significantly increasing the supply of housing

The document seeks to “significantly increase” the present level of house building. It does not however seek to understand the different needs of the different parts of the United Kingdom in coming forward with this and its associated policies.

In Cornwall we have experienced faster population growth than almost all other parts of the United Kingdom, accompanied by uncontrolled house building. Cornwall’s population was less than 350,000 in the early 1960s before large-scale in-migration commenced. By 1991 the population had ballooned to 468,500. It is now 535,000 people.

In 1991, there were approximately 190,000 occupied dwellings in Cornwall. Over 45,000 more properties have been built in the last 20 years – the vast majority of which was unrestricted market housing – many of which became buy-to-let investment properties or second homes. Such level of development is unsustainable and cannot be continued blindly into the future.

We therefore oppose “significantly increasing the supply of housing” in a Cornish context and call on the Government to allow areas like Cornwall more freedom to slow the level of house construction to give our communities a breathing space, and to allow local councils to focus on the delivery of proper local needs housing.

Local-needs housing

At the same time, local people are finding it increasingly difficult to find housing that is affordable. This Framework appears to do nothing to address this imbalance. Indeed, we believe it is the case that the Government is doing too little to deliver affordable housing for local-need. The introduction of an “affordable rent” model (at 80% of inflated private sector rents) in place of social rent, cuts in investment, etc, is making the delivery of local-needs affordable housing ever more difficult.

Neighbourhood Plans

The document also promotes the concept of “Neighbourhood Plans” which the Government claims will give “communities direct power to plan the areas in which they live.” But the reality is that the NPPF states that these plans must be aligned with national and key principal council documents, taking away any significant local discretion on strategic issues.

Protection of the countryside

Mebyon Kernow is particularly concerned that the proposed NPPF waters down the commitment to “protect the countryside for its own sake” and its own intrinsic value. This relates to both protected landscapes and those areas which have no statutory protection as such.
Greater protection must be afforded to land which is worthy of protection. This includes agricultural land, which will form the basis of our ability to produce food in the future, when food scarcity may become an issue.

Second homes

The NPPF is silent on the issue of second homes, which is a key problem in Cornwall, and a factor that excludes local people from the housing market and leaves many coastal villages little more than havens for holiday makers. It is time that legislation was introduced that allowed Councils to stop and then reduce the spread of second homes.

A lack of clarity - a lawyers’ charter?

Throughout the NPPF there is great uncertainty. It refers to Local Plans, but the document does not define what it means by this. Does this include Local Development Frameworks, such as the one being produced in Cornwall? Or is it a Local Plan like the old detailed district plans? Must work on LDFs be ceased and work on a new document commenced? Or is the Government simply using a term that is different from the one used by the previous Government?

Similarly, what is meant by the terms such as “sustainable development,” “rural,” “need” and “demand”, for example? And how can the terms “need” and “demand”, be used so interchangedly?

It is our view that this lack of clarity which makes the NPPF more a lawyers’ charter and a basis for litigation than a document that promotes a planning system that would be truly sustainable.