A revised version of the National Planning Policy Framework has been published this month (July) – see here. The new incarnation follows this year’s consultation, which focused primarily on incorporating design codes and building-beautiful recommendations. The full government consultation response can be found here, while the original comments made by CPRE to the consultation are here. The changes are largely incremental and as anticipated though are to be formally applied from the date of publication (Tuesday, July 20) for both Local Plans not yet at examination and planning decisions. For immediate practical purposes, all paragraph numbers from paragraph 53 onwards have now changed – here is a tracked versionillustrating the differences between the February 2019 version of the NPPF and this latest edition.
Swale Borough Council has agreed to extend its current Local Plan consultation until Friday, April 30. The decision was made at a meeting of full council on Wednesday, February 24, and all residents in the borough will receive letters telling them about the state of the Plan. However, councillors did not agree to have the outcome of the consultation reported back to them before submitting the Plan for examination. This was contrary to what CPRE Kent had suggested. An amendment supporting such a report was rejected by 24 votes to 18 – a disappointing outcome, we believe.
After last week’s full council vote, the Swale Local Plan is now out for consultation. Residents and other interested parties have until Tuesday, March 23, to submit their comments. CPRE Kent and others have cautioned against going to this formal stage of consultation without undertaking the Draft Issues and Options consultation that had previously been promised. It remains an overriding concern that this decision may inadvertently delay the Plan, either by hostile third-party challenge or through failure of the legal and procedural test at the Local Plan examination. The latter happened recently with the Tonbridge and Malling and Sevenoaks Local Plans. Of course, a delayed Plan means a greater risk of speculative applications in the meantime. These fears are compounded by the lack of the necessary evidence base to inform this consultation, most notably the absence of the required Sustainability Appraisal. It is extremely concerning that a decision to go to consultation has been made before this important work has been finalised. We would urge Swale Borough Council to ensure the required six weeks is available to consider this evidence once it is completed. More generally, CPRE Kent will be considering the detail of Swale’s Plan and supporting evidence over the coming weeks. Our early concerns, however, include:
The lack of meaningful consultation undertaken so far. This is particularly the case for the development now being proposed at Teynham and Lynsted
The lack of traffic modelling. This is a significant evidential requirement that goes to the heart of the soundness of the Plan and runs across many separate issues. The need and importance of such evidence is clearly set out in planning guidance
The uncertainty as to what infrastructure is required to deliver the Plan. Most notably, this includes whether a bypass at Teynham is required and the extent of improvement at junctions 5 and 7 of the M2
The chosen distribution of development leading to a worsening of air quality in the borough’s Air Quality Management Areas (AQMAs)
The coalescence of the two contrasting parish settlements of rural Lynsted and more urbanised Teynham.
This list is not exhaustive and represents our initial views only. We would, however, strongly encourage all of you who care for the future of Swale to consider carefully the proposals and make your opinions known. The consultation document can be found here
John Wotton, CPRE Kent chairman, has given a statement regarding the government’s proposed – and highly contentious – changes to the country’s planning system. Mr Wotton said: “The policies in the Planning for the Future White Paper published in August, combined with the measures in a separate consultation paper, Changes to the Current Planning System, are wide-ranging and, in my view, potentially disastrous for the countryside, especially in Kent and other parts of the South East, where the pressure for unsustainable development is already intense. “Increased housing targets will be set by central government, under a complex formula, with a view to building at least 300,000 homes per year and will be binding on local planning authorities, whose ability to review and refuse planning will be reduced. “A new system of zoning will designate all land as either growth, renewal or so-called ‘protected’ zones. The opportunities for the public to participate in the plan-making and place-making processes will be curtailed. “I believe that opposing these changes is a fundamental necessity for protecting the Kent countryside, which we all love.”
Consultation on the second major tranche of proposed changes to the planning regime closed yesterday (Thursday, October 29). Despite the government’s stated aims of ‘levelling up’ the country and prioritising brownfield redevelopment, we see little within the proposals that would actually achieve that. Along with so many others in the wider CPRE network, we raised our concerns over the proposals, which would see a significant increase in the amount of rural land that would have to be allocated for housing, and would mean people would see a dramatic reduction in their ability to have a say about how their communities develop.
It was heartening to see so many MPs echo CPRE’s concerns in a parliamentary debate on Thursday, October 8. We hope our concerns will be heeded and we can maintain a planning system that has communities, nature and the climate at its heart.
CPRE Kent has submitted its response to the government’s Changes to the Current Planning System consultation (click here). The process could have an ultimately devastating impact on much of Kent, with almost all the county’s district authorities facing housebuilding hikes of up to 125 per cent. If the consultation figures are accepted as part of planning policy, Kent will need to build an extra 2,835 homes a year on top of current targets, which are already frighteningly high.
We have already referred to the government’s Changes to the Current Planning System consultation (click here) and the drastic effect it could have on Kent, with almost all the county’s district authorities facing annual housebuilding hikes of up to 125 per cent. If the consultation figures, based on what has already been described as “another rogue algorithm”, are accepted as part of planning policy, Kent will need to build an extra 2,835 homes a year on top of current targets, which are already eye-wateringly high. Now CPRE has produced its response to the consultation and you can read it here. At almost 9,700 words, you might not want to tackle it in one sitting, but it is an important document and one we hope will cause the government to reconsider what are potentially highly damaging proposals to our countryside and indeed our way of life.
Time is almost up! You have until 11.59pm tomorrow (Wednesday, August 12) to take part in Highways England’s consultation on further design revisions to the proposed Lower Thames Crossing. CPRE Kent has made a response running to more than 5,000 words and, while you might not wish to go to quite such lengths, it would be useful to make your voice heard. There are many issues with the project – not least regarding air pollution and climate change – but did you also know the following? The A2 was widened both ways at great expense to four lanes. With the proposed refinements, the A2 coastbound would reduce from four lanes to two just east of the Gravesend East junction and also London-bound from four lanes to two before the Thong Lane bridge. It’s not easy to find the detail in the consultation document, but it’s there! These pinch points would cause serious congestion – and should be reconsidered in the light of the recent decision permitting the operation of Manston airport, which will result in large vehicles carrying air-freight containers along the A2. Any congestion on the A2 will result in vehicles rat-running at speed through the narrow lanes of surrounding areas such as Meopham, Sole Street and Cobham. This, we suggest, would appear contrary to the LTC Project Objective to “improve safety”. There is very much more that can be said about a scheme likely to bring little benefit to Kent, but you can learn more here
You can join the Highways England consultationhere
There was a healthy turn-out to a meeting from people keen to see copies of the latest Lower Thames Crossing design consultation. The event, organised by the Gravesham committee of CPRE Kent and Meopham residents, gave all the chance to ask questions about the revised design proposals. It had been set up in view of Highways England’s belief that the documents being displayed only in Rochester Library was sufficient south of the river. None of the many visitors at the meeting, held at Meopham Cricket Pavilion on Friday, July 31, realised that the junction of the tunnel access road and A2 would result in the A2 being reduced to two lanes in each direction at this point. This pinch point is likely to cause huge congestion on the A2 and as a result greatly increase traffic on local roads such as the A227.
The next phase of consultation on the proposed Lower Thames Crossing begins this month. Highways England is launching the four-week consultation on proposed design refinements to the planned road on Tuesday, July 14. It comes after 2018’s statutory consultation in 2018 and the supplementary consultation, which was completed this year. From July 14, we will all be able to comment on the proposed refinements, which include:
Minor refinements to elements of the highways design
Updated paths for walkers, cyclists and horse riders
Proposals for redirecting and upgrading utilities
More detailed landscaping proposals
Further developed ecological mitigation measures
The consultation is a digital-first event, meaning that from July 14 to Wednesday, August 12, all materials, including an online feedback form, will be accessible here You can also order printed copies of the consultation materials by emailing email@example.com The digital-first approach reflects social-distancing restrictions imposed by the government in response to the Covid-19 pandemic. Highways England says it is, though, setting up additional measures to ensure the public can engage in the consultation. These include:
Leaflets distributed to 135,000 properties within two kilometres of the route, giving residents notice of the consultation
From now, people can register their interest in the consultation and order hard copies of the consultation packs to arrive from the July 14 launch
Extensive media and social-media campaigns to raise awareness of the consultation
Highways England says that during the consultation period, July 14-August 12, it will provide:
Freephone consultation and call-back service for people to find out more and give their feedback on the proposals
Online public information exhibition, including videos, displays and documents library
Webinars to explain the key changes open to all members of the public
Updated and newly-interactive website
Alex Hills, CPRE Kent’s Gravesham district chairman, said: “This could be the last consultation before a planning application is put in, so it is important that as many people as possible take part in this very short consultation. “CPRE Kent is calling on people and organisations to order hard copies of the consultation for those who are not comfortable doing everything online.”
For more on the Lower Thames Crossing, see here and here
Public consultation on the proposed Lower Thames Crossing has been extended until Thursday, April 2. A spokesman for Highways England said: “As a result of cancelling our last public information event and our remaining three mobile information centres, we recognise that some people may have not yet had the opportunity to speak to the team at an event. “We are also conscious that the attentions of people and organisations will have been focused elsewhere over the past few days. Therefore we have taken the decision to extend the consultation until 23.59 on Thursday 2 April. “This is to give people additional time to complete their consultation response and to enable organisations to complete their governance processes, which may have been disrupted. “Until that time people can continue to share their views online here, (www.lowerthamescrossing.co.uk/consultation-2020) by submitting a paper response form to Freepost LTC CONSULTATION or by emailing firstname.lastname@example.org” Highways England is also opening a phone service for those who had planned to go to the remaining consultation events. Sessions will run from 2pm-8pm on Monday, March 23, and Wednesday, March 25; call 020 3787 4300. CPRE Kent has already put together a substantive response to the consultation, which had been due to end on Wednesday, March 25.
To read more from Highways England on the project and the consultation extension, clickhere
The beauty of Walland Marsh (pic Richard Watkins, flickr)
National Planning Policy Framework… it’s an ugly brute of a name.
Even its shortcut, the NPPF, takes some tongue-twisting getting used to. But it is an important beast and plays a bigger part in our lives than many might think.
To put it at its simplest, the NPPF (we’ll stick with that for now) is the government’s planning rulebook.
It helps determine the principles of countryside protection, the delivery of affordable housing, the provision of infrastructure, the places from where we draw our minerals and aggregates – and very much more.
And right now the NPPF is being consulted upon, because it is going to change. And how it changes will affect us all.
A key driver of the proposed change is what is commonly referred to in the media as ‘the housing crisis’.
CPRE is the first to highlight the fact that too many people are excluded from the housing ladder, while homelessness is an undeniable problem in this country.
However, we don’t believe that the proposed changes, or reforms, to the NPPF will do enough to tackle those issues. Indeed, we suspect that while communities’ needs go unmet, the only people who will really benefit are housebuilders.
It’s a problem caused by the government’s misunderstanding of housing issues and its subsequent weakening of planning rules in a bid to encourage developers.
The ‘crisis’ is of course one of affordability and won’t be addressed by simply building more houses, which is the government’s current approach. Rather, it is a case of the type of homes we build, for whom we build them and where.
‘The right homes in the right places’ has long been a CPRE mantra, and we believe it is possible to build the homes England needs without swathes of our countryside being sacrificed.
We advocate ‘sustainable development’ (the last bit of jargon – honest!) that:
Supports local democracy by adhering to neighbourhood and local plans
Ensures realistic and high-quality development based on genuine need, not market demand
Delivers more affordable homes by closing legal loopholes that put developer profits first
Adopts a true ‘brownfield first’ approach to development
Protects our countryside for current and future generations
Many organisations, communities and individuals with many agendas are contributing to the NPPF consultation, and it is vital that CPRE and those who agree with our outlook also make their views known.
The future of the countryside you hold dearest could depend on the changes made to the NPPF, so we urge you to join us in fighting for the best possible outcome, for the countryside, for wildlife – and for people.
We’re asking you to write to your MP, asking them to put communities at the heart for the planning system in the revised NPPF.
You can do that here
Alternatively, given that some MPs do not respond to formatted messages, you might choose to write to them individually.
It is difficult to overstate the importance of this consultation. For those of us who love the countryside – indeed those of us who love this country, its people and its traditions – the new-look NPPF will have an impact way beyond anything its cumbersome name might suggest.
We very much welcome the announcement today of a consultation on changes to financial support for solar PV, which will re-direct support from the feed-in tariffs away from large (more than 5MW) solar generation installations and towards smaller arrays.
The Solar industry has done a great deal to drive down the costs and drive up the efficiency of solar PV generation, and this has helped drive the proliferation of large scale solar PV facilities being sited on productive agricultural land. We believe that there is much more to be done in making the built environment more attractive to solar power generation and if these changes help achieve that, then so much to the good.