PPC responds to proposed National Planning Policy Framework

The government has overhauled its national planning policy document - last updated in 2012 - and has put out a heavy 70-page document for public consultation.

I have not been able to pick up on all the elements in the document that could give cause for concern, but I have concentrated on the fact that it does little to respond to the huge problem we have in south Devon of a lack of affordable housing and the continual development aimed at wealthy second home owners.

This is the response I sent to the consultation:

7th May 2018

I write in response to the proposed National Planning Policy Framework document.

I have several concerns about the application of this policy to South Devon.

Firstly I consider the idea of creating a single planning policy framework for the whole country to be flawed from the outset. No one policy can meet the needs of a rural area where house prices are inflated way above the national average and development is often aimed at the second home market, and at the same time be relevant to - for example - inner cities in the north of England.

Any national policy needs to give greater freedom to local authorities to determine policy in their own local area and to be less prescriptive.

The idea that a national planning policy can fix our broken housing market or create enough new, affordable homes for our young people and those on low incomes is ludicrous. While local authorities are banned from borrowing money to build social housing, the current crisis will persist.

The only answer to our shortage of affordable housing is to restart a major national programme of social housing construction and for the right to buy to be removed from such properties so that they remain available for social housing in perpetuity.

No privately owned housing developer is going to meet the social housing need when their primary goal is to answer to their shareholders.

In para 16 C you refer to "meaningful engagement between plan-makers and communities…" Across the South West this would lead to a request for much higher provision of genuinely affordable housing - which local authorities cannot currently deliver. This policy has to change.

The framework document refers to 'affordable housing'. In South Devon housing that costs 80% of the market rate is still totally out of reach to most people on an average local income. Which brings me back to my point above, that unless local authorities are allowed to borrow to invest in social housing, our housing crisis will not be resolved for the people who are most in need.

Para 64 states: Provision of affordable housing should not be sought for developments that are not on major sites, other than in designated rural areas (where policies may set out a lower threshold of 5 units or fewer). To support the re-use of brownfield land, where vacant buildings are being reused or redeveloped, any affordable housing contribution due should be reduced by a proportionate amount.

I would suggest that in a rural area such as the South Hams this should be dropped, as affordable housing provision should be sought on all developments, be they small-scale or major developments. Inclusion of this paragraph would enable developers to continue to build or develop high-end properties in rural areas that will never be affordable to local people and will only attract second-home owners.

Para 115 of the existing NPPF says: "Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty."

The key words here are 'the highest status of protection' but these key words have been omitted from the proposed version. The new Paragraph 170 says only: "Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty."

As Rebecca Bartleet, Chair of the Campaign to Protect Rural England said: "What is the purpose of National Parks and AONBs if they are not afforded the highest level of protection against inappropriate development which would harm the landscape and the scenic beauty?"

The proposals go on to say: "The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest."

Who determines what are 'exceptional circumstances' and who decides what is, or is not, in the public interest? I find this paragraph extremely concerning and would urge the Ministry to end the paragraph after 'Planning permission should be refused for major development'.

Caroline Voaden
Liberal Democrat Prospective Parliamentary Candidate for Totnes Constituency