B&DBC

DRAFT

Newnham Parish Council comments on:

National Planning Policy Framework (NPPF)

General Comments

Whilst we support strongly the objectives of sustainable development, we are concerned that the current draft does not adequately recognise the difficulties inherent in trying to balance between the needs of society, the economy and the environment, in a way which meets the needs of the current generation without jeopardising the needs of future generations.

The practical application of the principles of sustainable development means that trade-offs have to be made in order to ensure that an appropriate and acceptable balance is achieved between the three, often conflicting, areas. For many of the societal and environmental aspects it is difficult or even impossible to develop financial values which can be compared to the economic aspects, including contribution to Gross Domestic Product and therefore judgement has to be applied and consensus reached between the different stakeholders in order to decide whether a particular development is acceptably sustainable.

Although the document: introduces a strong presumption in favour of sustainable development, the bulk of the document indicates that the prime objective of the authors is the achievement of sustained economic growth and not the much broader sustainable development.

As with many planning documents, the issue of scale is not adequately addressed. All developments need to take account of the neighbourhood and be of an 'appropriate' scale in the local context, for example a development of an estate of 10 houses could be totally inappropriate in a small village, whereas a development of 1,000+ on a regeneration site within a town or city could be totally appropriate. Ultimately what is sustainable for the local community should be supported by that community, the NPPF should clearly state this is the case, so there can be no interpretation by planning officers, planning inspectors or indeed the Minister. Also, the term Local Community needs to be defined.

Serious concerns about the document:

1. Perpetuates the powers of planning officers and inspectors (and Whitehall), and that

maintains or adds to Big Government;

2. Increases the requirement for a rolling 5-year housing land supply to six years (5+20%);

3. Seeks to reduce or minimise planning obligations of developers;

4. Fails to address (merely gives the vaguest nod to the issue) the lack of sustainability in water availability and river contamination from sewage effluent;

5. Fails to address the crucial importance of transport and other key infrastructure being in place before development can begin;

6. Contains some very unsustainable statements e.g. §42;

7. Claims to support ‘key sustainable development principle’, but scarcely gives any acknowledgement to the needs of wildlife or to landscape, on the contrary, stresses ‘the default answer to development proposals is 'yes'' (§19, 2^nd bullet point).

If introduced in its current form the document would be a charter for the large house building companies and would be highly likely to result in irreversible and unacceptable damage to many parts of the countryside. We urge the Minister to order a redraft which achieves the required balance between society, the economy and the environment and also provides Local Communities and Local Planning Authorities (LPAs) the protection to ensure that developments at the community level are appropriate in terms of nature and scale and are such that the intrinsic character of the local area is maintained over the coming decades. The revised document should also include a presumption favouring previously developed (brownfield sites) and should be scrutinised by appropriate legal specialists to ensure that it does not lead to unintended consequences.

Comments by sector of NPPF:

While it is arguable that 'development means growth', the emphasis today should be on smart growth wherever possible. What Britain needs is better means of improving the national economy without threatening further damage to irreplaceable resources such as open space, farm land, forestry, water supplies and quality, mineral deposits. We need more emphasis on investment in people (training) and investment in plant and equipment to enable our existing population to be more productive despite the demographic shift towards an older population.