The National Trust’s ten point plan for reforms to the National Planning Policy Framework has been labelled “economically naive” by the British Property Federation.
The BPF welcomed the conservation group’s willingness to engage and agreed on a number of points, including calls to ensure brownfield sites are developed first.
But chief executive Liz Peace said the group’s “insistence that businesses cannot be considered part of their communities is both inequitable and economically naive”.
She said: “Businesses should be just as entitled as residents to have a say in how their areas are developed and communities need jobs if they are not to wither and die – or become just dormitory settlements.”
It is the latest in a series of clashes between developers and conservation groups which last week prompted the Prime Ministers intervention.
In a letter to the National Trust Mr Cameron sought to assure Dame Reynolds that the NPPF would balance social and environmental benefits with those of the economy.
Publishing the Trust’s demands yesterday, director general Dame Fiona Reynolds said the group’s task is now to play a full part in the consultation process “until we are satisfied that the final planning regulation reflects (Mr Cameron’s) assurances”.
The list of demands came on the same day the group’s anti NPPF petition reached 100,000 signatures.
Commenting specifically on each of the National Trusts “10 asks of the NPPF”, the BPF said:
1) Confirmation that the planning system should not be used as a blunt tool to ‘proactively drive development’.
BPF comment: We agree. Indeed, the draft NPPF says that the planning system must pursue economic, environmental and social factors “in an integrated way, looking for solutions which deliver multiple goals”, and we would have no problem if this were to be rephrased to make the document clearer.
2) Clarification of how planning should promote genuinely, robustly defined, sustainable development.
BPF comment: We agree that sustainable development should be robustly defined. This is what the draft NPPF, when taken as a whole, seeks to do and we would have no problem were the document to be rephrased to make this clearer. However, insisting that development must always have positive outcomes for the environment is likely to be impossible, since in some circumstances economic and Housing need may have to take precedence. Homes and jobs must go somewhere, and there is not enough brownfield land on which to build everything we need.
3) Clause 130 of the Localism Bill, (Applications for planning permission: local finance considerations) should be removed. Financial payments should not be a material consideration in planning decisions.
BPF comment: We understand that the Government maintains that this is a re-statement of their existing policy.
4) The NPPF should see no diminution of protection for designated countryside and heritage; and planning should continue to protect the wider countryside ‘for its own sake’.
BPF comment: We entirely agree that there should be no diminution of the protection of designated countryside and heritage, and that development of the best agricultural land should be strongly resisted. The NPPF already states this in strong terms, but we would have no problem if these policies were to be re-phrased so as to make the document clearer.
5) The NPPF should adopt an explicit ‘brownfield first’ approach.
BPF comment: In seeking to prioritise the use, where practical, of “land with the least environmental or amenity value” we believe that the NPPF has an implicit ‘brownfield first’ approach. However we believe that it would be helpful if this were made more explicit. We believe the National Trust is right not to have sought to reintroduce artificial targets for the use of brownfield land.
6) The NPPF should provide a five year supply of land for housing, but the requirement to identify an additional 20 per cent of land should be dropped.
BPF comment: We believe the National Trust’s position comes from a mis-reading of the NPPF. On our interpretation, the draft seeks an additional 20 per cent simply to provide a buffer in achieving the five-year supply which may not always be able to utilise all of the sites that have been identified. This seems like prudent planning, not an increase in housing numbers by the back door.
7) The default ‘YES’, and requirement to grant permission where a local plan is out-of-date, indeterminate or silent, is irresponsible and must be removed.
BPF comment: This misreads the draft NPPF, which states that where there is no local plan an application must meet the test of “sustainable development” as defined in the NPPF. It could not therefore in normal circumstances be badly designed, be built in an inaccessible location, be built in the Green Belt or on other protected land, be built in an area of high flood risk, increase the risk of coastal damage, fail to minimise greenhouse gas emissions, fail to maximise the use of renewable energy, threaten valued landscapes, fail to minimise impacts on biodiversity, pose unacceptable risks from pollution, generate noise that would impact on health or quality of life, threaten areas of tranquillity, create unacceptable light pollution or threaten treasured heritage assets.
We agree however that careful thought must be given to transitional arrangements, and that local authorities should be helped to put sound local plans in place.
8) Localism should be real: communities should be given genuine power to shape their area for the better.
BPF comment: We welcome neighbourhood planning and believe it will, combined with the strong plan-led system at local authority level, give communities greater power than ever to shape their areas. However, allowing neighbourhoods to accept less development than has been agreed in the local plan is wrong. The local plan identifies real-life needs and so to disregard it would deprive people, particularly the young, of jobs and homes.
9) It is fundamentally wrong that neighbourhood plans should be led and funded by business. It should be a core principle of the reforms that any plans, whether at neighbourhood or local authority level, should be genuinely community led.
BPF comment: Businesses are an integral part of the communities in which they trade and it absolutely right that they get a fair say. The Localism Bill allows for the creation of business-led neighbourhood forums in predominately commercial areas, such as business parks or high streets. Any proposals put forward by business neighbourhoods will be voted on by residents and businesses in spate referendums. Where disagreements occur democratically-elected councillors will decide.
10) There should be a limited third party right of appeal, in circumstances where consent is granted for development that is inconsistent with the local plan. This should be guaranteed by the Localism Bill.
BPF comment: We do not support third party rights of appeal.