Home Builders Federation #NPPF Response

Here  Quite a short response, very few changes suggested.

1. The NPPF is an important reform to encourage positive planning at the local district and neighbourhood level. The HBF fully supports this objective which is vital if the country’s current housing crisis is to be properly and successfully addressed in the future.

2. It is essential to positive planning that the presumption in favour of sustainable development is expressed clearly within the NPPF. It is clear that “sustainable development” is not “unfettered development”. The HBF supports the definition of sustainable development as drafted.

3. We support the core planning principles set out in paragraph 19 of the draft NPPF and would not support a national “brownfield first”, sequential approach towards land
allocation and development.

4. We support the plan led approach of planning and the principle that such plans should reflect a robust evidence base. The requirement for local planning authorities to
have a clear understanding of housing requirements for their area as set out in paragraph 28 and the use of Strategic Housing Market Assessment and Strategic Housing Land Availability Assessment is welcomed.

5. The deliverability of plans is of paramount importance. Thus, any cumulative burden of local standards or policy requirements should not put delivery “at risk” rather than “at serious risk”.

6. The NPPF must give further explanation to the interaction between neighbourhood plans and local plans.

7. The duty to co-operate is a critical part of sound plan making. The NPPF must include guidance on what happens if authorities or agencies fail to co-operate. The duty should extend to more than “neighbouring authorities” and should, similarly, extend into Wales and Scotland where appropriate.

8. We support the primary objective of development management set out in paragraph 53. We also support the priorities set out in paragraph 54 regarding the weight to be
placed on the benefits of economic and housing growth.

9. The NPPF should specifically refer to the fact that, in a plan led system, local authorities that do not have a plan in place cannot use prematurity as the sole reason for refusing a planning application. Such a position would be contrary to the presumption in favour of sustainable development, at the heart of the NPPF.

10. Some further guidance is needed to support the NPPF. This could be produced by practitioners in conjunction with government. Issues such as Strategic Housing Market
Assessment, Strategic Housing Land Availability Assessment and other key issues contributing to the robust evidence base on which plans are made would be most appropriate.

11. Local planning authorities should be aware of the issues of market signals and drivers when making plans and decisions on planning applications.

12. Assessments of the full requirement for all types of housing should be carried out using a robust and transparent evidence base as required by paragraph 109. This should include all of those specified categories of housing requirements currently set out in paragraph 21 of PPS3. This includes families, older people (including the need for specialist elderly person accommodation) and disabled people. Given the increasing numbers of older people, there needs to be a positive focus on planning for and meeting the full range of housing and accommodation requirements of this part of the population. We support the need for local authorities to ensure that they can identify and maintain a rolling 5 year supply of specific deliverable sites for housing consistent with the above assessments.

14. The requirement for local authorities to set requirements for specific size, type, and tenure of housing in particular locations (as required by paragraph 111) is too onerous
and runs the risk of being too inflexible and slow to react to market signals and demands.

15. We agree with paragraph 118 regarding design to not allow planning policies to dictate particular styles or taste and to allow for innovation and those in paragraph 117
that advise against policies being unnecessarily prescriptive or detailed.

16. Local Green Space designations should not carry the same weight as green belt policies since the two designations clearly perform different functions.

17. While the review of green belt areas will frequently be a strategic decision under which the duty to co-operate should apply, in some cases it would be right for a local authority to review its green belt boundary as part of the balance of meeting its development needs.

First Impression of the SEAs on Regional Strategy Revocation #NPPF

Unbelievable.  They seem to be pretending to be impact assessments, i.e. coming to the view first and them filling in the text afterwards.

Assume that the local and neighbourhood plan process will resolve all problems, absolving the SEA of all responsibility of assessing the impacts.

It does not assess the carbon or other impacts of shifting development from a few concentrated areas to a very widespread range of more dispersed and more rural locations.

Very difficult to see how they could stand up to legal challenge.

Will look into some of them in more detail when I get the chance.

Environment Agency #NPPF Response


Key points

We believe the NPPF should state clearly that delivering environmental outcomes is an objective of the planning system with equal status to economic development.

We believe the NPPF should give greater support for prudent use of natural resources including sustainable water management.

We believe the NPPF should clearly state the need for the planning system to protect and enhance water quality, especially helping to meet the objectives of the Water Framework Directive.

We believe that more weight should be given to Local Planning Authorities (LPAs) having regard to River Basin Management Plans, so that development is not approved without sufficient safeguards to protect the natural environment.

We would be happy to suggest minor changes to text which would strengthen the NPPF, without unnecessarily adding to its length.


DCLG Statement on the publication of RSS Revocation Reports #NPPF

Press Release

Pressure to build on the Green Belt is being removed with the revocation of Regional Plans according to environmental assessments published today.

The Coalition Government is committed, through the Localism Bill now passing through Parliament, to abolishing Regional Plans, which imposed housing targets on local communities and put pressure on councils to cut the Green Belt in 30 towns across the country.

The process of returning decision-making powers on housing and planning to local communities moved up a gear with the publication today of environmental assessments of the revocation of each Plan for consultation. The reports make it clear that revoking Regional Plans will mean there is less top down pressure on communities to review Green Belt.

Subject to Royal Assent of the Bill and the environmental assessments, the final abolition of each individual Regional Plan will be commenced after the assessment process has been completed.

Local Government Minister Bob Neill said:

“This Government is putting an end to unpopular, undemocratic Regional Plans, which imposed development on communities and threatened the countryside.

“These reports make it clear that revoking the Plans will protect communities and the environment from top down pressure to build on the Green Belt.

“We are putting planning powers into the hands of local people to take charge of local housing challenges in a way that makes sense for them while protecting the local countryside and green spaces they value.”


Notes to editors


1. Regional Spatial Strategies were introduced in 2004 and provided binding planning frameworks including nationally set housing targets at a regional level. They were drawn up by regional planning bodies and councils had to prepare their “Local Development Documents”, based on the Regional Spatial Strategy.


2. The Coalition Government is revoking these Regional Plans through the Localism Bill. We have undertaken voluntary assessment of the likely significant environmental effects of the revocation of the eight existing Regional Plans. The assessments have been carried out in line with the procedure set out in the Strategic Environmental Assessment Directive.


3. Eight Environmental Reports are being published on the Department’s website today 20 October 2011, on which we are seeking comments from organisations and individuals. The period of consultation will be 12 weeks ending on 20 January 2012. Subject to the assessment process we expect the orders revoking the existing Regional Plans to take effect next Spring. The reports are available here:www.communities.gov.uk/planningandbuilding/planningenvironment/strategicenvironmentassess.


4. The abolition of Regional Plans provides a clear signal of the importance attached to the development and application of local plans. Local plans drawn up with the help of the community will become the basis for local planning decisions, and future reform will make it easier for local councils to agree and amend local plans with their local community, in a way that maximises the involvement of neighbourhoods. The Localism Bill will also introduce a duty to cooperate on local planning authorities, county councils and public bodies which will require them to engage constructively, actively and on an ongoing basis in the planning process.


5. Towns and areas that were planning Green Belt reviews because of Whitehall-imposed targets will now be able to make their own decisions where new development is built. They include: Bath, Bedworth, Bournemouth, Bristol, Bromsgrove, Broxbourne, Cheltenham, Chertsey, Coventry, Gloucester, Guildford, Harlow, Hatfield, Hemel Hempstead, Leeds, Lichfield, Maidenhead, Newcastle-under-Lyme, Nottingham, Nuneaton, Oxford, Redditch, Redhill, Reigate, Rushcliffe, Stevenage, Solihull, Tunbridge Wells, Welwyn, and Woking and Worcester and in West Yorkshire beyond Leeds.


6. The Government is introducing a stronger locally-led planning system, where local communities decide where development goes and receive benefits from that development through the New Homes Bonus and Community Infrastructure Levy. Communities will also have the power to prevent encroachment on the Green Belt and will benefit from a new special protection for green spaces under the Localism Bill.


7. The draft National Planning Policy Framework also safeguards valued, national protection for our countryside including Green Belt, Areas of Outstanding Natural Beauty and Sites of Special Scientific Interest to protect them from encroachment.


Environmental Reports on abolition of Regional Plans published – but unavailable #NPPF

The SEAs have been deposited in the HoC Library but dont yet have ‘deposit number’ and available for download, terrible website you need to know the deposit number before you can find and download them.  This will take a couple of days.

Lets hope the DCLG put up a website for the consultation as soon as possible.

New written statement to common on abolition of regional strategies #NPPF

Abolition of regional strategies

The Parliamentary Under-Secretary of State for Communities and Local Government (Robert Neill): As part of its stated commitment to protecting the environment, the Government decided to carry out environmental assessments of the revocation of each of the existing regional strategies, on a voluntary basis.

It is the Government’s clear policy intention to revoke existing regional strategies outside London, which impose housing targets on local communities and put pressure on councils to review the Green Belt in 30 towns across the country. But this is subject to the outcome of the environmental assessments and will not be undertaken until the Secretary of State and Parliament have had the opportunity to consider the findings of the assessments.

I wish to inform the House that the Government is undertaking public consultation on the environmental reports, copies of which have been placed in the Library of the House.

Ill link to the documents in a moment

Adam Dodgson – ‘call it Brian’ its still a plan

Adam Dodgson at PAS Blog

one key phrase I’m hearing is “of course we have had to stop work on the core strategy to see how we can turn it into a local plan”. The following is not a criticism of any of those authorities, but I want to just throw this out here:

Your core strategy IS your local plan…

Today, this is called a ‘Core Strategy’. Some time next year, it will be called a ‘Local Plan’. Call it ‘Brian’. Call it whatever you like.

Reminds me of when work ceased for a couple of years on local plans and UDP when people got there heads around core strategies and LDF – a plan is a plan and a good plan will find its way and have common themes whatever the system.  Plan making should never pause for a moment.

Dealing with the Noise – Next Steps on the #NPPF – our Plan of Action

Many thousands of consultation responses what do you do?

It can be overwhelming and I have seen some local authorities overwhelmed by it, or sometimes taking 6 months to get through a few hundred responses.

Fortunately a large scale response is a logistical problem it should not be too great a planning problem.  That is because the large majority of responses will offer limited information – they are and will be of the ‘dont concrete over the countryside’ sort.   Even if every local planning authority, every significant housebuilder, every likely agency and NGO responded you would get less than a  thousand responses, and of those  only a minority will have something specific to say on how the framework should be changed.

These are the key responses because they have the highest information content, they are the ones to start with.  Form thereon in its a case of diminishing returns, another example of the 80:20 rule.

We don’t know what the departments plan of action is with the consultation is.  We don’t know if they will be publishing the responses prior to the final document and the consultation summary.  Lets hope so and lets hope they are pressed on this today in the commons.  Given the need for a final run around Whitehall before finalising they really only have until mid feb, 3 1/2 months, or three months excluding christmas.  That is fairly tight but doable – but it really does require a structured process and hopefully one that involves key stakeholders and no sign of that so far.

So in the absence of this we have to keep going.  Consultation responses as I said is about information, forgive me for a bit of information theory here but is useful.  A draft strategy is like a signal with a lot of noise, if you compare the final document to the earlier draft the difference is the ‘noise’.  The purpose of consultation is to eliminate this noise.

Consultation responses clearly focus on this noise homing on on parts which should change.  But from the perspective of the body agreeing to changes there is also the possibility that consultation responses will add to the noise by suggesting changes which would worsen certain problems.  Some responses of course may have no information content at all.  The trick then is to pick out the maximum information content responses.

The problem with a complex strategy is that it may have parts that are close to the final version and parts which are very noisy indeed, that is they are far from the final document.  Responses on those sections will add little information, other than it is noisy, unless they propose a drop in section.  As you will see looking at responses to some of the weaker paras of the NPPF suggestions for changes are all over the place.

Which Is why my strategy is always to section off responses, trying to match the information rich responses to the information rich parts of the document.

So if parts of a strategy are capable of amendment and a response has very constructive suggestions on that section you can start with those.  If the section is fairly stand alone you can fairly quickly then complete revisions which are capable of an early provisional sign off.  Then you can ensure that other more major changes are compatible with these by now fairly fixed sections.

Having seen many of the key constructive responses we are convinced that it is possible to produce a far better document  in a reasonable timescale.  We plan to continue working on our alternative draft because we think it can be helpful – youll see why in a moment.

A) We plan to start on sections of the NPPF which are fairly standalone and where with some tweaks and a few suggestions from key groups they can be made acceptable

-First we will start with the Heritage section where there are good responses from English Heritage, the Historic Town’s Forum and a few of the larger local trusts.  Still chasing up bodies such as the Victorian society etc. to see if they responded.  CHanges dealing with thee concerns can be made in only a few days.

-The other modular section which is capable of amendment is the Natural Environment/Biodiversity section (putting aside flooding, noise etc.) , though the changes needed here will be greater. There are also lots of suggestions here from many groups.

B) Then we plan to move on to the standalone sections which may need larger changes, Design for example.  Some good responses here but because these sections are more problematic many of the consultation responses are more critical.  They key here is finding from the responses what people want and need from the NPPF on this issue and then comparing this to the alternative draft wording and seeing how that can be improved.

C) Then we plan to turn to the tougher parts, such as the definition of sustainable development, the ‘presumption’, housing.  Many of the responses here are very critical and it is clear large parts will need to be rewritten. Of course we had anticipated this and offered suggested replacement sections.  Again we need to go through the consultation responses and see if they chime with our suggested version, making changes where necessary.

D) Finally we plan to turn to the really tough parts, areas where new policy needs to be added (Brownfield first) and where the text of the NPPF can’t be determined until detailed transition arrangements, or mechanisms relating to the duty to cooperate or neighbourhood planning, have been worked through.  It will be difficult to work through these areas without detailed Chatham house rules discussions with the DCLG and other stakeholders.

So the priority is to produce ‘heritage fixed’ and then ‘biodiversity fixed’ new versions of the alternative draft, the first by early next week, the second by the end of next week, before moving on to the tougher parts and then hopefully moving on to wider discussions.





6+ hour debate on the #NPPF in Commons today

Order of business – straight after business questions at 1.30 till 6

Watch here


Mps will really have had the chance to digest the 11,000 plus consultation responses wont they, especially as they havnt been published yet. The timing of the debate isnt helpful would have been much better in November or early December, that is if the DCLG does actually agree to publish the consultation responses and isnt forced into an FOI request.