The NPPF includes policies on sustainable development, business and economic development, transport, communications infrastructure, minerals, housing, design, green belt, climate change, flooding and coastal change, natural and local environment, waste management and heritage.
We set out some of the Group's recommendations below.
- The emphasis of the NPPF is on sustainable delivery of homes, infrastructure and work places and producing a planning system that pro-actively encourages growth. It includes a series of core planning principles.
- The draft relies on the traditional "Brundtland" definition of sustainable development but also sets out what sustainable development means for the planning system in particular, including economic, social and environmental considerations. There is a presumption in favour of sustainable development. LPAs should promptly approve applications which accord with up to date plans.
- However, the NPPF also encourages the grant of permission where planning policies are out of date or a plan is silent or unclear on a particular development unless there would be significant harm to the objectives, principles and policies in the NPPF. Applications should never be refused simply because a plan is in preparation - acceptable development should be approved. No test of prematurity is recommended.
- The Group suggest that there should be a single Local Plan for each area - with additional development plan documents or supplementary guidance necessary only exceptionally. The Local Plan would set out strategic priorities, preferably for a 15 year period. It would include a key diagram with broad locations for development, a proposals map for land use designations, identification of areas where changes of use may be limited and land requiring protection and a strategy for environmental enhancement. A significant evidence base would still be required and the plans tested for soundness. Neighbourhood plans must be in conformity with the strategic priorities of the Local Plan.
- LPAs would be encouraged to put in place Local Plans as soon as possible, although it is suggested that they could seek a certificate of conformity with the NPPF for existing plans while preparing new or reviewing existing plans. The change to a single Local Plan system raises the question of the need for further legislation.
- In the absence of an up to date Local Plan which is consistent with the NPPF, it is recommended that applications should be determined in accordance with the NPPF, including its presumption in favour of sustainable development.
- Viability is seen by the Group as an important consideration. Infrastructure plans and, preferably, any Community Infrastructure Levy should be assessed at the same time as the Local Plan. The total burden on development as a result of planning obligations should not affect deliverability.
- The town centre first policy and protection of their viability and vitality, alongside the sequential approach, remain fundamental. However, where town centre and edge of centre sites cannot be identified, the Plan should set policies for meeting the requirements in other accessible locations. The threshold for an impact assessment for retail and leisure development outside of town centres which does not accord with the Local Plan should be set locally.
- Local Plans should include a rolling supply of deliverable sites to provide five years of housing, but with an additional allowance of 20% to ensure choice and competition. The Plan should identify the LPA's approach to housing density.
- Policies should set out how affordable housing needs will be met on site or through commuted payments - LPAs are encouraged to recognise the advantages of commuted payments to improve and make effective use of existing stock.
- Green Belt boundaries should be considered when a Local Plan is prepared or reviewed. LPAs may safeguard land for longer term development stretching beyond the Plan period. Local transport infrastructure which demonstrates a requirement for a Green Belt location is not inappropriate development in the Green Belt.
- LPAs are encouraged to adopt national standards and Building Regulations rather than developing alternative or additional standards. Permission should not be refused for well designed buildings with exceptional levels of sustainability on grounds of incompatibility with existing townscape, unless material harm would be caused to a heritage asset protected by national designation or its setting which is not outweighed by the benefits of the development. Significant weight should be given to the wider environmental, social and economic benefits of renewable or low carbon energy projects.
- The sequential test and exception test are broadly retained in respect of flood risk, although the guidance is significantly pared down.
- Biodiversity is also considered important when determining planning applications - significant harm must, in order of preference, be avoided, mitigated against or compensated for.
- Applicants should describe the significance of heritage assets affected and LPAs should favour the conservation of designated heritage assets. Any loss requires clear and convincing justification.