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.