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New planning rule book: 'a speculative developers' charter'

Elementary Admin
By Elementary Admin &
3rd August 2018

CPRE has slammed the government’s revised planning rule book, the National Planning Policy Framework (NPPF), as a “speculative developers’ charter”.
In a damning early critique, the organisation says the government has not fulfilled its promise to “build attractive and better-designed homes in areas where they are needed”.
Indeed, the document, published on Tuesday, July 24, continues to “favour the delivery of any development, rather than development that meets communities’ needs, respects the environment, and adheres to policies in the NPPF other than those which deal with housing delivery”.
CPRE’s main worry is the introduction, in November, of a ‘housing delivery test’, which sees councils further encouraged to set high housebuilding targets – the new policy has clearly been designed to enforce those targets.
The test will mean councils are penalised when housebuilders fail to deliver homes in their areas; the ‘punishment’ is the removal of local control over planning decisions.
This, of course, will leave countryside open to speculative development.
Other CPRE concerns include:

  • a failure to provide an effective brownfield-first policy
  • the continuing failure to support provision of affordable housing in rural areas
  • the discouragement of neighbourhood planning because of uncertainty over the validity of Local Plans older than two years

Matt Thomson, CPRE’s head of planning, said: “Rather than delivering ‘what communities want’, as it claims to promise, the new planning rulebook and its new ‘housing delivery test’ will result in almost all Local Plans becoming out of date within two years.
“It is a speculative developers’ charter and will lead to the death of the plan-led system.
“Without a Local Plan, councils and communities have little control over the location and type of developments that take place. Local communities’ needs are ignored and valued countryside [is] destroyed for no good reason.”
Despite its disappointment with the revised NPPF, CPRE applauds some positive moves within it. They include:

  • National Parks and AONBs reinstated as having the “highest status of protection”
  • Maintenance of Green Belt protections and an improved definition of “exceptional circumstances” for releasing land from Green Belts
  • Exclusion of National Parks, AONBs and Green Belts from the Entry Level Exceptions Sites policy
  • “Social housing” reinstated in the definition of affordable housing

Hilary Newport, director of CPRE Kent, said: “Unfortunately, the revised NPPF carries on a situation where too much of the power within our planning system lies with developers.
“The housing delivery test, for example, does nothing to restore the balance that’s needed so local planning authorities can direct the development that’s needed to the places it’s needed.”

  • For more on CPRE’s response to the revised NPPF, see here

    Friday, August 3, 2018

  • A number of important documents have yet to emerge. For example, a rigorous transport plan and a finalised air-quality assessment. The latter is critical given that allocations at Teynham will feed extra traffic into AQMAs.
  • There seems to be no coherent plan for infrastructure delivery – a key component of the plan given the allocations being proposed near the already crowded Junction 7.
  • There seems to have been little or no cooperation with neighbouring boroughs or even parish councils within Swale itself.

The removal of a second consultation might have been understandable if this final version of the plan were similar to that being talked about at the beginning of the consultation process. It is, however, radically different in the following ways:

  • There has been a major shift in the balance of housing allocations, away from the west of the borough over to the east, especially around the historic town of Faversham. This is a move that raises many concerns.
  • A new large allocation, with accompanying A2 bypass, has appeared around Teynham and Lynsted, to which we are objecting.
  • Housing allocations in the AONB around Neames Forstal that were judged “unsuitable” by the council’s own officers have now appeared as part of the housing numbers.
  • Most of the housing allocations being proposed are on greenfield sites, many of them on Grade 1 agricultural land – a point to which we are strongly objecting.

Concerns about the rush to submit the plan

The haste with which the plan is being prepared is especially worrying given the concentration of housing in Faversham. If the town is to take a large amount of new housing, it is imperative that the policies concerning the area are carefully worked out to preserve, as far as possible, the unique nature of the town. The rush to submit the plan is likely to prove detrimental.

As Swale does not have a five-year land housing supply, it is open to speculative development proposals, many of which would run counter to the ideas contained in the current plan. Some are already appearing. This is a common situation, and one that, doubtless, is a reason behind Swale’s haste.

Our overriding fear, however, is that this emphasis on haste is ultimately going to prove counterproductive. This is because it is our view that the plan, in its current form, is unlikely to pass independent examination. We are urging Swale to listen to and act upon the comments being made about the plan and to return the plan to the council with appropriate modifications before submitting it to the Secretary of State.

Essentially, this means treating the current consultation not as the final one but as the ‘lost’ second consultation.

The consultation ends on Friday 30 April and we strongly urge residents to make their opinions known if they have not already done so.

Further information