Issues with the NPPF

Suggested changes to the NPPF:

Leeds North West MP Greg Mulholland has published a cross-party manifesto with our support, setting out planning reforms the next government must look at to give communities a greater say in the development in their neighbourhoods.

See the Government response to the Report from the CLG Enquiry

As one of our members stated recently:

“Good practice in community engagement is being stifled by tight timescales for deciding applications. Good practice in challenging poor development schemes is being suppressed in the interests of avoiding appeals. Good practice in producing affordable homes is being put at risk by developers threatening to appeal on viability grounds, and the LPA feeling obliged to avoid appeals unless absolutely sure of the outcome.”

The following are the main areas where change to the planning system would be helpful now or early in the life of the new government:

1. The calculation methods used for determination of housing needs are based on long term economic forecasts of dubious accuracy but Local Plans must be based on them, they should be based on historic trends and include a range of figures (minimum based on pure historic trends and maximum based on projected economic growth).

2.  The calculation of the five year housing land supply should be based on the minimum figure of housing need and should include all permissions not just those which developers chose not to land bank.

The five year land supply target does encourage house building but the current calculation methodology has the appearance of allowing inappropriate land grabbing by developers. The inclusion of permissions in the calculation would ensure that sufficient land was allocated but would then encourage building on those sites. Allocation of land for housing is essentially a one-way process; once included in a development plan, there is no going back – only under-provision can be corrected later, by making further allocations if the projection turned out to be too low. If there was over-provision, either because the projection was too high, or because land came forward more quickly than expected, no corrective action is possible.

3.  An increased emphasis on affordable housing, evidence shows that many developers prefer to build executive homes and that they actively attempt to reduce the number of affordable homes included in developments. The main need is for affordable homes for individuals and young families and for older people to downsize to. The policy should encourage councils to prioritise affordable homes and bungalows for elderly people who want to downsize but still want a garden for themselves and their grandchildren. For a discussion on the weaknesses in housing policy see: http://covop.org/weaknesses-in-housing-policy/

4.  The role of planning inspectors should be reviewed to ensure independence and to reduce their quasi-judicial status.

5.  The constitution of planning committees and role of LPA planning officers should be clarified (should be supporting the planning authority and the electorate not promoting developers).

6.  The elimination of “costs” in planning appeals – if developers chose to field numerous barristers, they should pay for them win or lose.

7.  Prioritisation of brownfield developments over green spaces.

8.  Importance of infrastructure planning and funding early in the life of developments.

9.  The need to allow time for local plans to be agreed (perhaps a moratorium on new applications for anything other than brownfield sites until plans are in place).

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