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NPPF consultation: forget the unwieldy title, this matters and you can influence it

Elementary Admin
By Elementary Admin &
30th April 2018
The beauty of Walland Marsh (pic Richard Watkins, flickr)

National Planning Policy Framework… it’s an ugly brute of a name.
Even its shortcut, the NPPF, takes some tongue-twisting getting used to. But it is an important beast and plays a bigger part in our lives than many might think.
To put it at its simplest, the NPPF (we’ll stick with that for now) is the government’s planning rulebook.
It helps determine the principles of countryside protection, the delivery of affordable housing, the provision of infrastructure, the places from where we draw our minerals and aggregates – and very much more.
And right now the NPPF is being consulted upon, because it is going to change. And how it changes will affect us all.
A key driver of the proposed change is what is commonly referred to in the media as ‘the housing crisis’.
CPRE is the first to highlight the fact that too many people are excluded from the housing ladder, while homelessness is an undeniable problem in this country.
However, we don’t believe that the proposed changes, or reforms, to the NPPF will do enough to tackle those issues. Indeed, we suspect that while communities’ needs go unmet, the only people who will really benefit are housebuilders.
It’s a problem caused by the government’s misunderstanding of housing issues and its subsequent weakening of planning rules in a bid to encourage developers.
The ‘crisis’ is of course one of affordability and won’t be addressed by simply building more houses, which is the government’s current approach. Rather, it is a case of the type of homes we build, for whom we build them and where.
‘The right homes in the right places’ has long been a CPRE mantra, and we believe it is possible to build the homes England needs without swathes of our countryside being sacrificed.
We advocate ‘sustainable development’ (the last bit of jargon – honest!) that:

  • Supports local democracy by adhering to neighbourhood and local plans
  • Ensures realistic and high-quality development based on genuine need, not market demand
  • Delivers more affordable homes by closing legal loopholes that put developer profits first
  • Adopts a true ‘brownfield first’ approach to development
  • Protects our countryside for current and future generations

Many organisations, communities and individuals with many agendas are contributing to the NPPF consultation, and it is vital that CPRE and those who agree with our outlook also make their views known.
The future of the countryside you hold dearest could depend on the changes made to the NPPF, so we urge you to join us in fighting for the best possible outcome, for the countryside, for wildlife – and for people.
We’re asking you to write to your MP, asking them to put communities at the heart for the planning system in the revised NPPF.
You can do that here
Alternatively, given that some MPs do not respond to formatted messages, you might choose to write to them individually.
It is difficult to overstate the importance of this consultation. For those of us who love the countryside – indeed those of us who love this country, its people and its traditions – the new-look NPPF will have an impact way beyond anything its cumbersome name might suggest.

Monday, April 30, 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