Response to the National Planning Policy Framework

Below is my response to the consultation document on planning that has been published by the Department of Local Government and Communities. As will be evident I have some serious concerns, especially about the future of villages in my ward.

Dear Sir/Madam

I am aware that the preferred method of response to the National Planning Policy Framework is in the form of a questionnaire. While I appreciate this makes opinions easier to collate, I am responding in prose so that my thoughts on this important document are fully articulated.  

I do believe there are very many aspects of the National Planning Policy Framework that are laudable and would enhance the planning process: certainly the idea of using direct democracy in order for local communities to encourage needed development is a worthy thought. However, in order to avoid a response that is bland and unhelpful, I have focussed my comments on areas where I believe the National Planning Policy Framework needs more consideration.

My letter is hereafter divided into general comments on the National Planning Policy Framework and a local view on how the document as it stands could affect the locality of Rugby where I live and sit as a Borough Councillor.

General Comments

1. Sustainable Development

Much is made throughout the document about the new ‘presumption in favour of sustainable development’. There would seem to be an inherent unfairness in a situation where there is a presumption in favour of any type or scale of development. While my position may seem naïve, I assert that in order for trust to be retained in the planning system, both sides of the development argument must view the decision as objective, fair and not pre-determined.

An objective decision must not position objectors to a proposed development in the position of needing to actively prove the development is not sustainable. It would seem to be more just that a situation remains where the onus is on the developer to persuade, by reasonable argument, the locality of the sustainability and need of their proposed planning venture.

Notably the document goes further than sustainable development in paragraph 19 when it states that: ‘Decision-takers at every level should assume that the default answer to development proposals is “yes”’. This very much undermines confidence in the view that it requires a compelling and well researched argument to convince planners of the benefit of a development to a particular locality.

I would be very much more comfortable with a situation whereby many more caveats are included in the document to assure local communities that the Planning Framework is not just, as some media outlets have suggested, a “developers charter”. Indeed, I would suggest that in the initial portion of any changes, planning officers are mandated to briefly supply their view on whether a development would have received a different decision had it been decided under the previous policies.

2. Motivations for the National Planning Policy Framework

While sustainable development is the key phrase in document, it should be noted that in paragraph 13 it is mentioned that “significant weight should be placed on the need to support economic growth through the planning system”. This would seem to place upon the planning system an additional requirement that it support economic growth with decisions construed as favourable to the economy as a whole. The policy does not describe what would constitute promotion of economic growth and who would decide. Indeed there seems to run through the document a view that development directly promotes the local or national economy.

I would prefer that the potential economic benefit of proposed development is information that Councils can have at their disposal when adjudicating on contentious decisions. However, I would stop short of advocating a planning policy where economic growth is placed at the centre of the decision. Planning policy should not used as an economic stimulus mechanism: this would not be consistent with the purpose of the planning system and is not a sustainable method for promoting growth.

In paragraph 19 the scope of the planning system is outlined. Within that paragraph it would seem that the Government is seeking to use planning policy to take up problems caused by failures in public policy but also to control market forces.  It is quite clear that the country does have a shortage of affordable housing, especially in the South East, but this is a fairly new phenomenon and seems to be a function of a failing immigration policy, erroneous use of the social housing stock and a falling ability for younger members of society to find suitable work or credit.

Paragraph 19 mentions that ‘planning policies and decisions should take into account local circumstances and market signals such as land prices, commercial rents and housing affordability’. The implication that the planning system is a tool for an aggressive price determination would seem counter to the principles of a free market Government.  Again, I would prefer that planning policy does not try to actively interfere in market forces. If it did this could lead to a postcode lottery over policy because of regional variations in price and need.

It is my view that the review of the planning system should be motivated by a desire to promote more expeditious decisions for simple planning matters. It should also help ensure greater transparency and clearer decision making for the more contentious decisions. This review does offer some solutions, but it would appear to overstep the mark into different Governmental concerns where perhaps it has no legitimate role.

 

3. Community Involvement in Planning 

As is described in paragraph 21, the document places great weight on the local plans that Councils produce. These are being used as an example of where these new framework will allow greater local autonomy over planning decisions. Indeed, Ministers have been quick to use the local plans to defend the policy from opposition.

The preamble to the description of local plans makes it quite clear that local plans should be ‘consistent with the … presumption in favour of sustainable development’. The development of local plans that sit within this remit means, and of course the reports authors would appreciate this, that all local plans will be forced to identify any site with the possibility for development.

Indeed in paragraph 24 local plans are required to ‘plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of this Framework’. This sentence gives me cause for concern because planning is, by its very nature, a defensive exercise. Without planning policy starting from a defence of the status quo it loses effectiveness and becomes nothing more than a facilitator for development. 

If a true objective of the review is to promote localism in planning policy then I contend that committees should be furnished with greater officer resources allowing a greater proportion of decisions to be “called-in”. This would provide elected Councillors, who should be appraised of local need, to examine more decisions in greater detail and apply this knowledge within the statutory planning rules.

Moreover, the current policy that only allows rejected decisions to be appealed should be re-examined.  This will become a very important area to investigate and legislate for especially if the desired push towards planning policy that is positive goes ahead.

Paragraph 48 mentions that local plans should be prepared or they would fall under the auspices of the national framework and decisions will be made with presumption in favour of “sustainable development”. The reality is that this is a false threat because even with a local plan the national framework (with presumption in favour of sustainable development) is still the guiding document. The local plan is a false beacon of hope when the details are logically followed to their natural conclusion.  

My concerns extend to the cost of the meeting measures which will be placed upon local authorities by adhering to the various statutory requirements of the framework. Many authorities have current core strategies that were developed at great cost. These will be out of date within the current framework and I would prefer to be appraised of the total potential cost before we jump blindly into this policy. Without wishing to contradict myself with a view to short-term finances, I must mention this in the context of the current squeeze on local government finance.

In terms of local inclusion, I do have a concern that there is a lot of bluster about how much involvement local communities will have via direct democracy and the local plan. I would be keen to involve people, via referenda, in the planning process and strong local plans are, of course, an excellent idea. This said, if we frame all of this against the backdrop of a presumption in favour of sustainable development and a default answer of “yes” then all of these things will have a negligible effect on answers to decisions on de novo development.

4. Simplification of the Planning System

The planning system is undeniably complicated, especially for those who do not work with it in a professional capacity. Underlying this complexity is a need to ensure a balance between development and the environment and local identity. The proposal to condense over one thousand pages of Planning Policy Guidance into one 52-page document may, at face value, seem to be a sensible situation but the reality is different. The detailed national and local planning guidance gives certainty to both developers and residents; this certainty allows the planning system to be argued around the periphery but that the general rules are well set and tested. A comprehensive planning system as currently stands allows officers and Councillors to be guided by the detail rather than vague statements of aspiration. With this entrenched planning detail there is also consistency rather than transitory policy based on prevailing economic conditions.

It could easily be argued that small planning matters, such as porches and windows, are ripe for simplification. These non-contentious issues should be made more simple and cheaper for individuals to navigate through. However, this proposal seems to be aiming at larger developments with a greater monetary value. It must be remembered that these large developments often have a quite stark effect, positive or negative, on the lives of people in the locality.  This fact places a moral requirement on government to have rigorous, tested and objective rules on what development is allowed. 

As it sits, proposing to use Local Plans to take up the slack of detailed planning guidance is flawed if all of these local plans are undermined and overtaken by the ambiguous and amorphous guidance laid down in the National Draft Planning Policy. I would suggest the ideas put forward are piloted on smaller concerns initially. If successful I am sure that other sceptics would be more convinced.   

Planning policy has evolved into its current form through encountering challenges, devising solutions and applying these to the new situation. This new review is very much a revolution in the planning system. It is very much in vogue for national politicians to promise a “revolution” in various policy areas. In reality this is rarely possible and an evolutionary approach is adopted when the problems in their ideas are pointed out.

Comments Relating to the Borough of Rugby

1.Rugby’s Planning Past

The Borough of Rugby sits to the south of the County of Warwickshire covering an area of 138 square miles. The Borough has 41 parishes and the largest centre of population is the attractive market town of Rugby with two thirds of the Borough’s 91,000 residents living in the town and the remainder residing in the rural area. The villages in the Borough range in size from 20 to 3,000 people.

The Borough’s overall population remained steady between 1971 - 2001 but between 2001 - 2006 the population increased by 3.1%. The rise in population was largely due to people migrating into the area but also as a result of people living longer. Whilst numbers of young people are in decline the number of over 50’s is beginning to increase sharply and the population of the Borough is expected to increase to well over 100,000 by 2026.

The average household size within the Borough of Rugby is 2.35 persons. However the number of households has risen faster than the population with around a quarter of Rugby’s 39,000 households occupied by a single person.

Within the Borough there are 19 Conservation Areas, 6 Grade 1 Listed Buildings, 30 Grade II* Listed Buildings and 460 Grade II Listed Buildings. Spread throughout the Borough are 26 Scheduled Monuments and 5 Registered Gardens at Bilton Grange Grade II, Coombe Abbey Grade II*, Ryton House Grade II, Newnham Paddox Grade II, and Dunchurch Lodge Grade II. There are currently 11 assets on the Heritage at Risk Register within the Borough (2009).

In recent years there have been major pockets of development within the Borough. While some of these developments have taken place on brownfield sites in the urban centre, there have also been significant developments within rural villages such as Cawston, Dunchurch and Bourton-On-Dunsmore. There is also an ongoing plan to develop a major area of land know locally as “the Mast Site” which sits in the East of the Borough.

While no aspect of Rugby Borough has been without certain amounts of developments in recent years, it is factually accurate to say that the south of the Borough has taken on a greater proportion of the development. Within this area sit many historic villages of which Dunchurch, Stretton-On-Dunsmore and Ryton-On-Dunsmore represent the largest.

2. The village of Dunchurch: An Example

The village of Dunchurch was mentioned in Domesday Book where the settlement was called Doncerce. The core of the village has been declared a conservation area because it has many buildings of historical interest. Some of the buildings date from as far back as the 15th century are timber framed and still have traditional thatch roofs.

Many famous people throughout history have stayed in Dunchurch. Most notably in 1605, the Gunpowder Plotters stayed at the Red Lion Inn (reputed to be the private residence now called 'Guy Fawkes House') in Dunchurch awaiting news of Guy Fawkes's attempt to blow up the Houses of Parliament. If he had been successful they planned to kidnap the King's daughter Elizabeth of Bohemia from nearby Coombe Abbey.

I mention Dunchurch in such detail because I live here, represent the village as a Councillor on Rugby Borough Council but also because I am convinced that the National Draft Development Planning Document would see the northernly edge of Dunchurch become conjoined to the border of urban Rugby under the proposed plans.

The area between Dunchurch and Rugby consists of mostly arable farmland that, in recent years, has been slowly developed with housing and retail sites. Property prices here remain buoyant meaning development can be lucrative. As I write there is local outcry over a proposed development on Rugby Road exiting Dunchurch towards Rugby.

It could plausibly and with some economic justification be argued that building between Dunchurch and Rugby, on the Northampton Lane, Ashlawn Road and Rugby Road represents sustainable development. This would mean that there would be a presumption in favour of building on these sites.

I have grave concerns about such a situation. This development would destroy the village identity of Dunchurch and negatively impact upon the quality of life of existing residents. Dunchurch is an historic area which adds to the diversity and colour of the Borough. While arguments could be constructed that show building heavily in this region would have positive effects on pure economic indicators, I believe that the planning system is there to ensure that Britain is not just some robotic nation obsessed with our GDP. We cherish our heritage and history, and it is for this reason that I must respond to the document in this way.

Yours faithfully,

Cllr. Howard Roberts

Dunchurch and Knightlow Ward Councillor, Rugby Borough Council