Finally submitted this evening. Just a few minor changes in the last couple of days, including some new glossary definitions and a more thoroughgoing treatment of Green Infrastructure.
Campaign Against Sprawl
Final Response to the Draft National Planning Policy Framework
Please find enclosed our full response to the consultation.
This response has four components – each also available online:
The Questionnaire Response – this document following the letter.
The track changes of para. by para. comments
And our Alternative Draft of the Entire National Planning policy Framework.
Finally the detailed justification for our alternative draft.
The alternative draft is also supplied in its original desktop publishing form – including its numerous time saving automations (because of its size this is only supplied as a link and is not attached).
Many of our suggested changes are whole new or rewritten sections so it is not convenient to put these wholesale in the track changes database – but they are flagged at appropriate points. We have tried to keep this aligned with the database but this is difficult. In the event of any conflict the alternative draft takes precedence.
Summary of our response
- The document lacks a positive vision of planning, of place, of England.
- It is not balanced; it represents landowner interests above all others, even above economic development and employment.
- It effectively redefines sustainable development to equal property development – it will not promote sustainability, rather its converse.
- It will only be usable by experts; many of its phrases have meanings in planning precedent dating back to previous ages of planning. It undoes much of the progress of the last 25 years. Its parts interact in complex ways which it is clear even the government has not yet worked through, but which are already causing delay and confusion.
- It will lead to a ‘free–for-all’ because almost all plans will be rendered out of date overnight. This will lead to appeal-led planning, with a risk of sprawl rather than properly designed and planned development.
- As a nation we badly need more development, in the right place and well designed; but the NPPF will hinder this and the irony is it is already leading to a crude anti-development backlash.
- There are ways of salvaging the situation. We suggest new clauses to the final stages of the localism bill which combined with significantly rewritten parts of the NPPF would lead to a proper definition of sustainability, a workable presumption in favour of sustainable development, a proper transition period, plan-led rather than appeal-led planning and a simpler, quicker system. We would be willing to expand on these suggestions in further work.
on Behalf of the Campaign Against Sprawl
18 Bailey House
Berber Parade Woolwich