the draft National Planning Policy Framework
observations by St Albans Civic Society  (10 October 2011)


Planning - a complex process

Proper town planning is a complex process, a balancing exercise involving many competing interests. There is much at stake. It is important that the public trust the decisions made on its behalf, and this depends in turn on a fair process and unbiased decisions.

On the face of it, the draft sweeps this away. The default position is that all planning applications will be granted permission as quickly and simply as possible. Local plans are to be drawn up, which begs the question are Local Development Frameworks to be abolished and, if so, what happens to all the work our Council has done in the last few years? The Government intends that the planning system “ does everything it can to support sustainable economic growth” (para 13). The result is a double presumption in favour of development - “pro growth” policies of dubious intent and effect embedded in a plan-led system.

In St Albans, it is said that we have the oldest surviving 'local plan' in the country. The process of updating and replacing this document has regularly been frustrated by changes in Government policy, among other things, so we are no further forward fourteen years after commencing the update process! Where there is no plan, local authorities are told simply to “ grant permission” (para 14). This would not be fair on the residents of the City and could destroy its historic heritage. Replicated nationally, it will lead to increasing challenges and a general loss in faith in the system.

Communities need the power to say ‘no’ to prevent unacceptable development - there have been a succession of outstandingly harmful examples here in St Albans which have rightly been rejected. The power is needed to ensure that plans are delivered, without undue government interference, and quality buildings and environment created. Businesses want councils to say ‘no’ to inappropriate development that would harm their investments. On the other hand, commercial interests with the biggest purse should not be able to 'purchase' permissions by making general contributions to the CIL (Clause 130 of the 'Localism' Bill).


What is 'sustainable' development?
The word 'sustainable' is repeated throughout the document like a mantra, as a comforting cultural icon like 'Motherhood and apple-pie'. The author(s) evidently hope that 'sustainable development' will therefore be widely supported. Or perhaps it is expected that developers will use this vague and vacuous concept to smother objections to all development anywhere.

What, precisely, does 'sustainable' mean, how is it defined and, most importantly, who will judge whether a particular scheme is 'sustainable'? In lieu of precise definition, the draft document has a three woolly phrases in paragraph 10. Henceforth, all applicants will claim 'sustainability', defying planning officers and committees to reject their proposals. The number of 'beauty contests' could also increase, as developers contest the relative merits of rival schemes in front of planning inspectors and in the courts.


How serious is the consultation?
The Society questions the merits of the consultation exercise. The ministers have written "No-one should underestimate our determination to win this battle" (George Osborne and Eric Pickles joint statement in the Financial Times). This is not an appropriate sentiment for a consultation exercise. Or, if it is intended, is it simply tilting at windmills? For example, planning is not responsible for the dearth of houses. The current slump in housebuilding is the result of a lack of finance, both for home-buyers and house-builders, prevalent since the 'credit crunch'. And even if the rate of building could be increased, it would have no effect on house prices. Planning policy is at best a long-term and blunt tool with which to influence the rate of house building or development generally.


Deliberate omissions?
There is no single mention in the draft of the words 'enforce' or 'enforce­ment'. Enforcement is crucial for the preservation of the historic fabric of our conservation areas. It is also important to protect the everyday urban and rural environment that has no particular designation. Will this remain unchanged?

There is no mention of the planning acts, or to the whole system of ministerial Regulations and Circulars. A significant issue with the planning process is the procedural nightmare of box-ticking validation and preparation of meaningless supporting documents needed to meet a host of minor and petty rules and regulations. The draft is silent on these matters.

In this context, it is extraordinary that supplementary documents are to be developed and owned by external bodies. Whilst that it is true of the present arrangements that some advice is provided in this way (e.g. 'Manual for Streets') this has been the exception and should not become the norm.

Peter Trevelyan
(Vice-Chair, St Albans Civic Society)