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12th Jan 2012 Last updated at 15:15 CRA Consulted on National Planning Policy Framework
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The CRA has responded to a consultation document on the Government’s controversial planning reforms set out in the National Planning Policy Framework. Working closely with the BDFRA, the CRA has submitted detailed answers to planning questions set out in the 34 page questionnaire.
In many cases, the CRA has submitted responses in the “Strongly Disagree” category. The following are selected highlights from the questionnaire:
Presumption in favour of sustainable development:
We strongly object to the proposal that planning permission will be granted where the plan is ‘absent, silent, indeterminate or where relevant policies are out of date’. The vast majority of local plans and even recent core strategies are out of date, (the latter because of the change of emphasis in this document), thus presenting developers with an ‘open planning season’ for the next few years. There should be a transitional period until the new Local Plans are in place.
Similarly the phrase stating that local authorities should ‘approve all individual proposals wherever possible’ is unacceptable. We also object to the inference that a development can become sustainable by conditions, obligations or payment.
Planning has to be a balance between the needs of the economy, society and the built and physical environment. The presumption in favour of economic development totally ignores the basis of what is good planning in terms of the spatial development of environmentally sustainable settlements. In our opinion, a universally accepted definition of sustainability is required which gives due weight to environmental and social sustainability.
We recognise the need for more housing, but a large increase in the number of dwellings is not a sustainable solution in many areas of the country, particularly the over-crowded South East with its inadequate infrastructure. Refusing applications only where the ‘adverse impacts of allowing development’ would ‘significantly and demonstrably outweigh the benefits’ gives insufficient weight to environmental and social factors
Undemocratic approach
We are concerned that this is a totally undemocratic approach. The planning system has worked well for the last 60 years and is highly regarded throughout the world. The proposed Framework will destroy this fair and balanced approach. The Government states it is promoting ‘localism’ and pushing decision making down to local and neighbourhood levels. In fact the reverse is true. Future local plans will have to show that they are in conformity with the Framework and its overwhelming emphasis on growth at the expense of balance. The presumption to say ‘yes’ to growth will ignore local, well based concerns on matters such as the lack of an adequate infrastructure and service provision, harm to local settlements and landscapes, and loss of countryside.
Meeting demand and 20% additional developable land
The requirement for each local authority to provide an additional 20% of land for development is totally against the proposed emphasis on localism, ignores the fact that sustainable sites may not be available and will lead to increased development of greenfield sites before sustainable brownfield land.
In any event, it is unrealistic to expect local authorities in the SE of England to meet the demand for market and affordable housing when large areas of brownfield land exist in the more deprived areas of the country where there is a need for investment and revitalisation. It is not good enough to state that needs can be met by planning in conjunction with neighbouring authorities when, as in Surrey, they have similar problems, especially when much of the remaining countryside is designated Green Belt.
The emphasis on demand rather than need accentuates the problem. Is this is what is meant? Meeting the unfettered demand could be a disaster, particularly as there is so little reference to environmental constraints.
You can read the complete questionnaire at the link above.
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National Planning Questionnaire