Agenda item

Consultation on the draft revised National Planning Policy Framework

Decision:

Resolved that the Council’s response to the draft National Planning Policy Framework, as set out at Appendix A to these minutes, be approved and submitted to the Ministry Housing, Communities and Local Government by 10 May 2018.

Minutes:

(Link to Council Priorities: P4)

 

The Government had published its draft revisions to the National Planning Policy Framework (NPPF) for consultation.  In this regard, the Portfolio Holder for Planning Services considered a report that set out the Council’s draft response.

 

Whilst the draft revisions built upon and sought to implement into national policy the details of other recent publications / consultations, the Portfolio Holder noted that the key thrust of the draft revisions was to underpin the delivery of the Government’s ambition to increase the supply and delivery of new homes and resolve the national housing crisis.  Critically, the changes to be introduced by the draft revised NPPF sought to ensure that more land was brought forward for development, the use of the land was optimised (primarily for new homes) and that permissions were turned into homes as quickly as possible.

 

The key changes proposed as part of the draft NPPF included:

 

·         a new document structure of 17 topic-based chapters reflecting the Government’s priorities – with a focus upon resolving the housing crisis;

·         clarification on the presumption in favour of Sustainable Development and amendments to the tests of soundness for Local Plans;

·         a new standard methodology for the calculation of local housing need;

·         a wider definition of affordable housing and a focus on affordable home ownership products;

·         promotion of the role of small sites and their exclusion from affordable housing contributions;

·         introduction of the Housing Delivery Test;

·         greater emphasis on effective and optimal use of land, particularly brownfield land;

·         promotion of minimum density policies, upward extensions, conversions and reallocation of sites to deliver housing;

·         requirements to set out a clear local design vision and expectations;

·         continued strong protection for the Green Belt and clarification of the exceptional circumstances in which releases or development may occur;

·         strengthened protection for ancient woodland and other irreplaceable habitats; and

·         new plan-led approach to viability, seeking standardisation and transparency.

 

The Portfolio Holder noted that whilst the proposed changes to the draft NPPF remained the subject of public consultation, the Government had stated that they would be publishing the final version of the new NPPF during Summer 2018.

 

It was acknowledged that a presentation in respect of the draft NPPF had been given at the recent Local Plan Working Group Meeting.

 

During consideration of the Council’s response and taking account of the comments made by Councillors Mrs. S.R. Kapadia and Mrs. R.J.M. Lyon, who were also present at the meeting, the Portfolio Holder requested that the following revisions be made prior to its submission to the Government:

 

Chapter 2: Achieving sustainable development

 

·         Q2 – Sustainability Objectives – the first sentence be amended to read “The Council supports the objectives of sustainable development as set out in Paragraph 7 of the draft NPPF.”;

 

·         Q2 – Sustainability Objectives – the beginning of the second sentence be amended to read “The Council also supports the proposed …”;

 

·         Q2 – Meeting Housing Need – the Planning Policy Manager reword the first paragraph to make it more robust;

 

·         Q2 – Housing Delivery Test – the second sentence be amended to read “The presumption in favour of sustainable development will unfairly penalise local authorities in areas, such as Elmbridge, where the identified need figure is significantly higher (and continues to rise through the standard methodology) than previous targets and where the availability of deliverable land is limited.”;

 

·         Q2 – Housing Delivery – the last sentence be amended to read “The Council has been working hard to respond positively to the housing crisis and is progressing its Local Plan accordingly; however, these positive actions will not be recognised in the mechanisms such as the Housing Delivery Test.”;

 

·         Q3 – the words “The Council does not agree” be inserted at the beginning of the paragraph;

 

·         Q3 – the first sentence be amended to read “The ‘core principles’ section in the existing NPPF is an important and useful reference point for both plan-makers and decision-takers and should be retained.”;

 

·         Q3 – the Planning Policy Manager reword the second sentence;

 

Chapter 3: Plan-making

 

·         Q5 – the first sentence of the second paragraph be amended to read “With this in mind, the Council maintains a strong objection to developing a Local Plan and future spatial / growth strategy based purely on an overly simplified process of establishing a housing target as prescribed in the Standardised Methodology.”

 

·         Q5 – the beginning of the second sentence of the second paragraph be amended to read “The Council therefore wishes to raise strong objection as to the …”;

 

·         Q5 – the first sentence of the third paragraph be amended to read “The Council is striving to achieve a Local Plan that positively contributes towards the resolution of the national housing crisis and the need to address affordability issues.”

 

·         Q5 – the second sentence of the third paragraph be amended to read “This however needs to be balanced against pressures of achieving the overarching concept of sustainable development.”;

 

·         Q5 – the third sentence of the third paragraph begin with the words “Taking account …”;

 

·         Q5 – the word “consist” in the third sentence of the fourth paragraph be amended to read “consistent”;

 

·         Q5 – the first sentence of the fifth paragraph be amended to read “The draft revisions do not appear to lend themselves to such a situation occurring.”;

 

·         Q6 – the Planning Policy Manager rewrite the second paragraph to re-emphasise the point regarding the retention of the core principles;

 

·         Q8 – whilst not wanting to detract from the content of the second paragraph, the Planning Policy Manager rewrite the text to make it more succinct and sharp.

 

·         Q8 – the second sentence of the third paragraph be amended to read “Consequently, improved market conditions should trigger viability testing for increased developer contributions.”;

 

Chapter 5

 

·         Q12 – the second sentence of the second paragraph be amended to read “In addition, the suggestion that New Homes Bonus could be linked to the HDT is counterproductive.”;

 

·         Q12 – the third paragraph be amended to read “It is accepted that it is good practice to produce an annual action plan to identify barriers to housing delivery and suggested actions to remove these barriers.”

 

·         Q13 – the second sentence of the second paragraph be amended to read “The Council objects to this proposal as it weakens the protection of Green Belt land.”;

 

·         Q14 – Affordable housing provision on small sites – the fifth paragraph in bold be amended to read “Unless outweighed by local circumstances, provision of affordable housing should not be sought for development on sites of less than 10 units …”;

 

·         Q14 – The Standardised Methodology – the Planning Policy Manager expand the second paragraph to reflect the consequences of having no standardised methodology for providing a breakdown of the housing numbers;

 

·         Q14 – Housing Land Supply Tests – the Planning Policy Manager include a reference to land banking in the second paragraph;

 

·         Q14 – Housing Land Supply Tests – the Planning Policy Manager include some context as to how a condition, as referred to in Paragraph 78 of the draft NPPF, would be enforced;

 

Chapter 6: Building a strong, competitive economy

 

·         Q16 – the beginning of the first sentence of the first paragraph be amended to read “The Council expects a greater focus …”;

 

·         Q16 – the Planning Policy Manager include some wording in the first paragraph in respect of the removal of the policy regarding Permitted Development rights for conversions of offices / retail premises;

 

Chapter 9: Promoting sustainable transport

 

·         Q21 – the beginning of the third sentence of the first paragraph be amended to read “However, there should be clear guidance on when …”;

 

·         Q21 – the Planning Policy Manager include some wording in the first paragraph in respect of public transport and specifically the congestion / capacity on the train network;

 

·         Q21 – the word “acknowledge” in the second sentence of the third paragraph be amended to read “acknowledged”;

 

Chapter 11: Making effective use of land

 

·         Q26 – the Planning Policy Manager revise the paragraph to moderate the robustness of the comments;

 

·         Q27 – the word “effect” in the second sentence of the first paragraph be amended to read “effective”;

 

Chapter 13: Protecting the Green Belt

 

·         Q30 – the second sentence of the second paragraph be amended to read “However, such development would be incremental and unplanned growth in the Green Belt, contrary to the fundamental aim of Green Belt policy and indeed the purposes it serves as well as other policy considerations and constraints.”;

 

·         Q30 – the words “For example” be added to the beginning of the third sentence of the second paragraph;

 

·         Q30 – the Planning Policy Manager include some wording in the second paragraph in respect of Paragraph 144 (f) of the draft NPPF;

 

·         Q30 – the words “… and as such Local Planning Authority’s should be able to prescribed Development Management and Supplementary Planning Document policies.” be added to the end of the second sentence of the third paragraph;

 

·         Q31 – the last sentence of the third paragraph be deleted; and

 

Glossary

 

·         Q43 – the Planning Policy Manager include a reference within the Glossary to reinstate the Historic Environment definition.

 

The Portfolio Holder for Planning Services thanked the officers for all the work undertaken in preparing the Council’s response to the consultation particularly given the timing and length of the consultation period.  It was acknowledged that if the consultation period had been longer, the Council’s draft response would also have been considered by the Planning Committee, if timescales had allowed.

 

Subject to the above together with a number of typographical and grammatical amendments, the Portfolio Holder

 

Resolved that the Council’s response to the draft National Planning Policy Framework, as set out at Appendix A to these minutes, be approved and submitted to the Ministry Housing, Communities and Local Government by 10 May 2018.

Supporting documents: