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National
Planning Policy Framework
Consultation Questions
1 "The Framework has the right approach to establishing
and defining the presumption in favour of sustainable development."
Strongly disagree
Paragraph 9: The National HMO Lobby considers that there is a tension
within the National Planning Policy Framework's concept of 'sustainable
development', between its understanding of 'sustainability' and
its understanding of 'development'. 'Development' seems to be understood
essentially in terms of 'economic growth' (see paragraph 13). 'Sustainability'
however is understood in essentially social terms: paragraph 9 refers
to "people … enjoying a better quality of life, both
now and in the future." Meanwhile, paragraph 1 makes clear
that one of planning's roles is to "support strong, vibrant
and healthy communities"; and paragraph 5 emphasises that it
is for "local people … to reflect the needs and priorities
of their communities." In other words, both the end and the
means of planning is strong communities, which is also apparent
in the government's goal of a Big Society, and its route thereto
through vehicles such as the Localism Bill. The Lobby therefore
is concerned that the Framework quite fails to prioritise 'community'
in general, and its foundation in 'housing' in particular.
Paragraph 10: This paragraph prioritises economic growth, planning
for prosperity (bullet-point 1). However, if 'sustainability'
is understood as it is in the Framework, then economic growth is
not an end in itself, but a means to an end, "a better quality
of life" for local communities. The priority should properly
be given to planning for people (bullet-point 2),
"supporting strong, vibrant and healthy communities."
Unfortunately, this questionable initial prioritisation underlies
the whole structure of the Framework.
Paragraph 13: The section is titled sustainable development,
but paragraph 13 interprets this solely as "economic growth."
Paragraph 14 identifies the economic version of development as
a "golden thread" running through the whole planning system.
But if strong communities are both the means and the end of planning,
then surely 'communities' should be the golden thread?
Paragraph 18 is welcome in re-asserting the priority of communities,
"development is expected … to respond to the needs of
communities."
Paragraph 19: The Lobby considers that the paragraph on Core
Planning Principles is seriously deficient. Not one of
the ten principles acknowledges the importance of communities: environment,
heritage, greenspace, resources, transport, health, and so on, all
are cited - but no reference is made to the key role of strong communities.
2 "The Framework has clarified the tests of soundness,
and introduces a useful additional test to ensure local plans are
positively prepared to meet objectively assessed need and infrastructure
requirements." Neither agree nor disagree
Paragraph 25: The Lobby welcomes the emphasis on the engagement
of local communities in plan-making.
Paragraph 28: The Lobby welcomes the priority given here to housing,
which is the bedrock of communities. But the Assessments advocated
should be concerned not only with demand (Market Assessment) and
supply (Land Assessment), but also with the central role that mix,
or diversity, plays in sustaining strong communities.
Paragraphs 49-52: The Lobby welcomes the Framework's emphasis on
Neighbourhood Plans.
3 "In the policies on development management, the
level of detail is appropriate." Neither agree
nor disagree
Paragraph 53: The Lobby considers that the primary objective of
development management should be to support sustainability.
Paragraph 57: The Lobby welcomes the support for the involvement
of the local community in the pre-application stages of planning
applications.
Paragraph 64-66: The Lobby welcomes the Framework's emphasis on
local circumstances. (With regard to Article 4 Directions, it is
important that planning applications generated by these should incur
fees, so that they do not drain local resources.)
5 "The 'planning for business' policies will encourage
economic activity and give business the certainty and confidence
to invest." Neither agree nor disagree
Paragraph 71: The economy matters, of course, but the Lobby considers
that it is not the same as 'development' in general, and it is a
means to an end, not an end in itself. In the Framework, it should
be preceded by planning for people.
Paragraph 74 reinforces the equation of 'economic growth' with
'sustainable development.'
6 "The town centre policies will enable communities
to encourage retail, business and leisure development in the right
locations and protect the vitality and viability of town centres."
Neither agree nor disagree
Paragraph 76: The Lobby supports the promotion of town centres.
Further to bullet-point 4, residential development is necessary
for the viability of town centres; but strong communities surrounding
the town centre are also necessary for viability and vitality.
7 "The policy on planning for transport takes the
right approach." Neither agree nor disagree
Paragraphs 82-84 omit entirely the importance of transport in sustaining
strong communities and maintaining community cohesion. It is important
on the one hand to provide for free movement for all within communities,
and on the other, to protect communities from the impacts of transport
unrelated to those communities. In particular, paragraph 84 should
add a third objective concerned with transport within communities.
Paragraph 92 points up the importance of local transport, but only
in the context of new residential developments.
10 "The policies on housing will enable communities
to deliver a wide choice of high quality homes, in the right location,
to meet local demand." Neither agree nor disagree
Paragraph 107: The Lobby welcomes bullet-point 4, "creating
sustainable, inclusive and mixed communities", as an essential
objective of housing policy.
Paragraph 109, bullet-point 7, draws attention to one aspect of
the abuse of existing housing stock, empty properties, especially
significant when a major policy objective is to "increase the
supply of housing." However, in a time of acute shortage, the
Lobby is also concerned about the abuse of stock when it is used
as a second home. This happens for a number of reasons - leisure
is the most obvious reason (holiday homes), but so too is work (crashpads)
and also study (student houses). Policies should be devised to meet
these needs, not from existing housing stock, but from purpose-built
development or from the conversion of other types of redundant buildings.
Paragraph 111: Mixed housing is mentioned in the first and last
bullet-points of this paragraph. The Lobby recommends that it is
identified as a criterion in its own right.
Paragraph 111, bullet-point 3: The Lobby welcomes the policies
for affordable housing, especially the option of "financial
contributions" (or commuted sums) to help create mixed and
balanced communities. This is a vital measure where local communities
(such as Headingley in Leeds) are seeking to redress polarisation
of the neighbourhood, as the consequence of the conversion of first
homes for families into second homes for students.
However, the Lobby regrets that the reduction of the Planning Policy
Statements has led to the omission of "the national indicative
minimum site size threshold [of] 15 dwellings" (PPS3, paragraph
9) in the requirement for affordable housing. This will undermine
the provision of affordable housing, which is universally recognised
as being in short supply.
Paragraph 124-132: The Lobby finds it deeply regrettable that the
section on sustainable communities does not even
merit a Question in the Consultation. In fact, communities should
be the golden thread (paragraph 14) of the Framework - and as such,
planning for people surely deserves priority over
the other sections of the Framework.
Furthermore, given the importance ostensibly accorded to the role
of 'community', the Lobby is surprised that no attention is given
to the government's understanding of what constitutes 'community'.
Since there are many kinds of community, it should at least be made
clear that it is local communities which are meant (as opposed to
communities of interest, for instance). Again, consideration should
be given to the representation of communities: Parish and Town Councils
are accountable to their electors, but what of urban communities
without such councils? And in our cities, how are communities delineated?
Finally, not all communities have the same degree of social capital:
means should be found to ensure the equality and viability of communities.
Paragraph 125: Given the importance of mix and balance to sustain
strong communities (paragraphs 107 and 111), the Lobby considers
that one of the objectives of planning for inclusive communities
should be to avoid polarisation. On the one hand, polarisation arises
either from the exclusivity of the privileged, or from the exclusion
of the disadvantaged; on the other hand, it loses the diversity
of life-skills provided by a mixed and balanced community. For both
reasons, it should be discouraged.
12 "The policy on planning and design is appropriate
and useful." Neither agree nor disagree
Paragraph 116: The Lobby welcomes bullet-point 3 on local character,
as an objective of design policy. Neighbourhood Design Statements,
developed by the local community, provide a vehicle for doing so.
Paragraph 122: Where there is a local Neighbourhood Design Statement,
developers should be encouraged to refer to this, and to liaise
with the community which developed it.
Paragraph 123: The Lobby welcomes control of outdoor advertisements,
which can blight a neighbourhood (for instance, letting boards erected
in huge numbers in areas of HMO concentrations).
16 "This policy provides the right level of protection
for heritage assets." Neither agree nor disagree
Paragraph 179: Neighbourhood Design Statements provide an alternative
designation for neighbourhoods valued by their local communities
Dr Richard Tyler, National HMO Lobby, October 2011
National HMO Lobby
email: hmolobby@hotmail.com
website: www.hmolobby.org.uk
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