The Brighton Society has responded in detail to the Draft National Planning Policy Framework circulated by the Government and its conclusions are summarised below:-
- Remove the presumption in favour of development. This will address the majority of our reservations.
- Remove the misleading expression ‘sustainable development’ Just call it development. Or come up with another description for the definition set out in paragraph 9.
- Set out a reasonable and realistic timetable within which Local Authorities can prepare and finalise their Local Plans in conjunction with their local community before ANY of the policies contained in the NPPF become mandatory.
- Provide a failsafe mechanism if deficiencies in the Local Plan lead to patently detrimental consequences to the local environment and the wishes of the local community.
- Give the local community a greater say in the formulation of Local Plans free from development targets – because that is what they are.
- Ensure that there are procedures and safeguards so that local communities are given the time and facilities to make a real contribution to planning policies in their local areas.
- Issue guidance to local authorities on how to resolve the problem of finding accommodation for travellers.
- Remove the requirement for a 20% additional allowance for development.
- Specifically encourage the use of brownfield sites for new housing development.
- Confirm that equal weight will be given in the NPPF to the categories of planning for prosperity, planning for people, and planning for places (para 10) but acknowledge in para 11 that there will be many circumstances, particularly within existing built environments, where planning for spaces will outweigh the others because of a need to protect the existing environment.
- Create a presumption against development which would detrimentally affect the historic environment in our villages, towns, cities and countryside.
- Create protection for open spaces used by the public within built up areas.
- Recognise the value of open countryside and include policies to preserve, enhance and protect the character of the countryside from inappropriate development.
- Encourage local authorities to review the boundaries of Green Belt land where these run along main roads to ensure a buffer of open space along those roads.
- Encourage local authorities to put in place strong policies to control the proliferation and detrimental environmental effects of advertisements and signage.
- Incentives should be created for Housing Associations to allow them to expand their ability to provide more affordable housing, and to make a greater contribution towards the aim of increasing the number of new dwellings built annually.
- Create a monitoring system on a national basis to keep track of the amount of housing developments approved, built and completed, and issue updated guidance on a regular basis to local authorities so that they can see how their own allocations, planning applications, approvals and built provision are affected by the national picture.
- Provide national guidelines for future development to address the imbalance between the increasingly depopulated north and the increasingly overpopulated south and issue guidance to local authorities where this is likely to affect the provision within their local plans.
- Make VAT zero-rated where existing buildings are converted and/or refurbished to new uses.
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