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British Property Federation welcomes National Trust contribution to planning framework debate

(Please scroll down for BPF’s point-by-point commentary on National Trust demands)

The British Property Federation has today welcomed calls from the National Trust, made today as part of a 10-point list of demands, that the draft National Planning Policy Framework should adopt a more explicit requirement to develop brownfield land before greenfield sites.

However, the industry body is concerned that the National Trust does not seem to regard local businesses as having a legitimate voice in neighbourhood planning. The BPF also believes that neighbourhoods should not be allowed to completely disregard the local need for new homes.

Commenting on the National Trust’s “10 asks of the NPPF”, published today, BPF chief executive Liz Peace said: “It is welcome that the National Trust have made some positive suggestions for ways in which the draft NPPF can be improved, and there are certainly ideas here that the property industry can support.

“We strongly agree that the new planning system should promote sustainable development that balances the needs of people, environment and businesses; we agree that town centres should be supported and we agree that it is right, where practical, to develop brownfield land first.

“However, the Trusts’ insistence that businesses cannot be considered part of their communities is both inequitable and economically naive. 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.

“We are also concerned at the suggestion that neighbourhoods should be able to thwart evidence based plans, developed by elected local authorities, to provide much-needed homes. This would exacerbate our housing shortage and deprive families and young people of somewhere to live, something that should be a basic human right.”

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.

ENDS

For broadcast/print interviews with BPF chief executive Liz Peace please contact Patrick Clift, media and public affairs manager, on 07834 439 505 or at pclift@bpf.org.uk.

National Trust press release reproduced below:

National Trust press release

Wednesday 28 September 2011

EMBARGOED UNTIL 00.01am Thursday 29 September 2011

National Trust sets out vision for a planning framework fit for purpose

Following assurances from the Prime Minister that the planning system should continue serve the public interest by balancing social and environmental benefits with those of the economy, today the National Trust sets out its positive vision including the top line requirements for a planning system which can deliver that balance.

The draft National Planning Policy Framework (NPPF), published by the Coalition Government in July, threatened to put short-term economic gain ahead of all other considerations, including the impact on local communities and local green spaces.

Dame Fiona Reynolds, Director-General of the National Trust, said: “We  warmly  welcomed the Prime Minister’s intervention; our task now is to  play a full part in the consultation process until we are satisfied that the final planning regulation reflects his assurances, providing a neutral framework which decision makers can use to achieve balance.

“We support the simplification and streamlining of the planning system and agree that it needs to provide land for new housing, jobs and infrastructure as well as protecting the environment.  We are also keen to see greater engagement by local people in the decisions that affect their future.

“What we question is the present draft NPPF, which does not deliver these goals. It needs significant change to properly reflect the ambition of balance. 

Consultation on the draft NPPF closes on 17 October. Visit www.planningforpeople.org.uk to find out more, and add your voice to our petition.

*National Trust ten asks:

The planning system should not be used as a blunt tool to ‘proactively drive development’. Its guiding principle has been to act in the public interest, balancing the needs of people and the environment with those of the economy. The NPPF should be rewritten throughout to make it a balanced document.

Planning should promote genuinely, robustly defined, sustainable development. In particular, the presumption in favour of sustainable development should only apply when plans or proposals can be shown to deliver multiple positive outcomes for people and the environment as well as economic growth.

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.

The NPPF should act in everyone’s interests to safeguard the things people value. There should be no weakening of the protection for the designated natural and historic environment. The countryside has value for its own sake. Development of the best and most versatile agricultural land should be strongly resisted on grounds of food security and landscape protection.

The NPPF should adopt an explicit ‘brownfield first’ approach. It should be clear that developers should seek to use previously developed land before green field sites are used. There should be exemptions for brownfield sites of the highest public interest, including for nature and heritage.

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. Confidently delivering a five year housing land supply will be a big step forward. Requiring more than this will put greater pressure on green fields, whether protected or not. The NPPF should promote the provision of affordable housing.

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. Local authorities should have the ability to refuse development proposals where they would cause harm.

Localism should be real: communities should be given genuine power to shape their area for the better. It should be clear that neighbourhoods can opt for less development as well as more than in the local plan, and that local authorities who wish to set high standards for development are free to do so through the use of supplementary guidance.

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.

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.

The National Trust exists to promote the preservation of special places for the benefit of the nation. This doesn't just mean the places we own or have covenants over. It goes wider to mean any special places which are under threat. We support the legal and policy safeguards that protect such places, and would be very concerned if those safeguards were diluted or removed.  We have a duty to oppose such measures and to bring the issue to the attention of our members and supporters. Find out more at: http://www.nationaltrust.org.uk.

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