Bob Neill’s Heritage #NPPF letter to the Telegraph

Telegraph Letters

SIR – John Hipkin (“It’s not just the countryside that’s now at risk,” Comment, October 5) is mistaken. The planning reforms will not downgrade protection for the historic environment. They will actually make it clearer, and encourage better upkeep to prevent neglect or decay.

The draft maintains strong protections against urban sprawl and gives local communities the power to decide where to protect or develop, through their local plan. Listing buildings and scheduling for ancient monuments will continue. Any development that might cause significant harm to an important heritage asset would not be allowed unless stringent tests were passed to justify an exceptional violation.

Residents, rightly, expect their council to discharge its legal duties including heritage protection, and councils should set their budgets to allow them to do that.

Despite the huge public deficit, funding for councils this year was fair – the average reduction was just 4.4 per cent. Councils should look to prioritise efficiency savings or share services with neighbouring authorities.

We are already in discussions with heritage groups about where they think things could be made clearer.

Bob Neill MP (Con)
Local Government Minister
London SW1

Is it just me of is there a logical disconnect between the first and last sentences.  Surely it is for users of the NPPF to decide if it is clearer or not?

Perhaps mr Neill can point us to the paragraph against urban sprawl in the NPPF and others can point him to the paragraphs restricting sprawl in PPS7 etc. that are noticeably missing.

Perhaps also Mr Neill can let, as long promised, local authorities to set their own planning fees as many budgets assume.

West London Football Club Moves and Machinations

Nothing is more difficult in town planning than to get a football club to decide on their future ground.

Guardian reports that Fulham is planning to ‘redevelop’ Craven cottage from 25,700 to what 35,00, 45,000, no all of 30,000 one wonders what the point is, especially as Fulham Road is such a tough site half of it listed and well away from public transport, and with some of the most wealthy and litigious neighbours you could imagine.

Recent speculation suggested Fulham had been looking to move to a new stadium while a potential ground share with their west London neighbours QPR or Chelsea had also been reported.

It now looks like Chelsea will be bidding for some of the surplus BBC lands now being released.  There is a problem, none of them are big enough.  The site of the old White City Stadium itself is way to small, even if you knocked down the award winning Allies and Morrison offices/studios next door (which you wouldn’t want to do), and even if you did something dramatic like having a stadium bridging over over Wood Lane.  If Chelsea is to move to White City, which makes perfect sense they need to go to one of the bigger sites their (Such as unigate depot – unlikely because of its high value) or do a deal with the Council to re-gig some of the estate/social housing land their.

Craven Cottage (capacity 42,500) would be a perfect ground share for Fulham and QPR, and the Riverside Fulham ground would be worth a lot of money if released.

3rd (and hopefully final) version of our #NPPF alternative draft posted

Cross post from Campaign Against Sprawl

We have posted a new version of our alternative draft of the NPPF.

We have also completed our questionnaire response including the response to the impact statement

We have also published a table of para by para changes we think are needed.

And a justification of the alternative draft policy innovations and changes from the NPPF consultation draft.

This is the first draft which contains all of the policy content, changes  and stress we wanted.  It has also been subject to a thorough proof check (thanks the world Jan) and a lot of feedback and ideas.  A lot of silly errors and mistakes have been corrected.

Bar a final checking consistency of all of the package and a professional index that will be that and we intend to send the response in on Weds 12th to avoid last minute DCLG mailbox congestion.  The alternative draft is the top document, so if any of the others in the package are misaligned please refer to the alternative draft.

Throughout our approach has not been to draft the NPPF as we would like it in an ideal world but to redraft the NPPF in a way which met current imperatives in a manner which might prove acceptable across the party spectrum, regaining a cross-party consensus in planning suitable for troubled times.  In an ideal world there would be a lot more upfront on urban regeneration and much more throughout on infrastructure co-ordination.  But mechanisms for this simply arn’t in place at the moment.

It was important to ‘freeze’ the document before the end of the consultation to help other groups finalising their response. However once we have seen other para by para responses we can continue to refine it and seek agreement, that is if the government at last puts forward some ideas and structure for a talk process. We have suggested a project plan for such a process we have yet to hear a response.

There is also the first real stirrings of groups beginning to come together to pool their ideas for changes.  Its not as quick as we and others would like but things are moving.

The Main Developments Since the Previous Draft

Like Planning Policy Wales those policies that need not be repeated in local plans are indicated – in this case in bold.

Some small tweaks to the language used in the section on the definition of sustainable development.

The chapter on making planning decisions has had a lot of work.  A few gaps, such as on probity, have been filled and a few errors corrected.  We have also had a chance to throughly go through the abortive PPS on development management and pick up on what was useful and essential.

We have tweaked the single planning and design statement section and now includes reference to up front affordable housing offers.  This links with a later section designed to prevent delays from negotiating affordable housing section 106s, which we know is a key concern of ministers.

A key section on planning permissions not being bought and sold from the planning obligations circular has been included. as well as a reference to wherever possible planning obligations heads of terms  being agreed prior to application decision.

This chapter includes a new section ‘Local Decision making’ pulling together key issues to be considered at the point of decision.  It also stresses the need for good reasons where a development contrary to the plan, the NPPF, officers advice or advice of a statutory consultee.  It recommends local review mechanisms in place where this occurs, a pragmatic second best to third party rights of appeal and potentially avoiding call in of some cases.

The ‘good planning test’ has been tweaked a bit to clarify issues professional had raised.  We have also clarified the weight to be given to emerging plans and made the link to transitional arrangements is made clearer in the following chapter.

In the plan making section we have picked out in section 3-7 the key components of plans and how they link together.

On the evidence base requirement we have clarified how the issue of ‘suppressed households’ and housing affordability is to be handled.

On viability we include links to RICS and HCA advice on this matter (in an ideal world the SOS should ask them to produce a joint guide).

On strategic planning a small clarification on the appropriate scope of strategic planning (3-32), as well as clarification on when the results of joint working need to trigger a local plan dealing with more than local land use requirements (3-35).

On transitional arrangements, the weight to be given to development plans is now stressed in a more legally appropriate form of words (3-49).

On design we now have a proper definition of inclusive design.

Transitional arrangements for existing design guidance is set out (4-10).

Correction of some errors in the housing section (esp para 7-8)

The idea implicit in the previous draft – that there was a quid pro quo, more housing land for better, more sustainable and more affordable housing is clearly set out (7-21) named a housing compact.

Transitional arrangements are suggested in a number of areas where local areas have relied on national policy.  This includes affordable housing site size thresholds, exceptions sites and parking standards.  These are key local concerns.

A couple of key points from the affordable housing practice guide are included to avoid a policy gap – i.e. mortgagee in possesion and specification of providers.  The definition of affordable rent is tweaked to reflect what is actually going on on the ground – i.e. negotiations on market rent discounts, and so the government does not box itself in with an overly specific discount level in national policy.

Correction of a few errors in the section on appropriate uses in the Green Belt.

The wording on the encouragement on the use of the Passivhaus standard has been tweaked.

We have defined low carbon energy (page 59) which is rather important in assessing certain applications such as incinerators.  We have included some more glossary definitions including of zero-waste.

Herefordshire reduces housing targets by 8%

Consultation here deleting the largest and most accessible urban extension – because of ‘public concern’ (since when was that a material planning consideration by itself).  Something of a pattern here nationally.   The sites previously considered most sustainable get deleted just because they are controversial and the targets get adjusted down accordingly.  Chances of getting through the examination without being reinstated – slim.

Guardian – ‘relatively small changes’ to #NPPF planned to placate ‘the countryside lobby’


Cabinet supporters of a more interventionist economic policy are now considering a major housing construction programme as the next step after QE. Key figures such as Oliver Letwin, David Cameron’s key policy adviser based in the Cabinet office, have been working behind the scenes since the summer on the packages announced this week, but they also recognise far more needs to be done to promote growth.

Ministers are looking at putting a limit on how long construction firms can hoard land on which they have permission to build. Firms could be required to release the land for someone else to build on the property.

A new housing programme will be outlined by the coalition in November, and it is viewed as the next major practical step the government can take to boost the economy – apart from pushing for a settlement to the euro crisis

They are confident they can overcome resistance from the countryside lobby by making relatively small changes to the new national planning policy framework.

My Take

It is good that housing construction is being considered as it would produce a boost to demand.  Myself and Brian Green have produced ideas over how this can be done in a way which is debt neutral.   Watch this space for more developed ideas.  However as I said yesterday if done in the manner suggested in the NPPF much of the economic benefits will be dissipated in unearned landowner profits and increased energy and transport costs.

The land hoarding issue has been looked at before.  At Wealden we looked at making planning consents for housing personal effectively expired if not commenced in terms of a build out programme after 3 years..  We dropped the idea though when the OFT report came out exonerating in part house-builders.   It would be an easy reform to make though probably best not through planning legislation but competition or land tax legislation.

Lets hope that the government will suggest more than small changes.  They may have made the calculation that even if their were brownfield first and protect countryside policies put back in then the realities in high demand areas such as the SE, SW and East mean that an increasing proportion of houses will go on greenfield anyway.  My sense is the debate has shifted, and campaigning has helped shift it.  The real issues now area a) how serious is the government about urban regeneration and b) if growth is going to happen will it be smart growth, will it be compact it from and served by public transport, saving unneccessary greenfield land loss.