Apologies for posting this after the date for submitting evidence has (just) past but the panel appointed by the Planning and Housing Minister to investigate ways of improving the system of local plan preparation and approval of local plans is now considering the evidence.
My views were,"The Panel has been set up due to existing problems in the timely approval of development plans. However, in the pre-occupation with speeding up (and possibly simplifying) the process there is a danger that the system will continue to operate under the conspiracy of silence and avoid the challenge implied by the test of soundness which is compliance with s39(2) of the 2004 Act. There are no development plans that are actually “contributing to the achievement of sustainable development” or following the para 14 of the NPPF/Framework where development in accordance with the plan would necessarily benefit from the ‘presumption in favour of sustainable development.
Development plans are current being produced by local government planners faced with interpretations of the Framework by inspectors and Secretaries of State that have prioritised economic development at the expense of any proper consideration of the social and environmental limbs of sustainability. The contributions being made by private sector planners through representations during the plan preparation and at the examination are being made in the interest of clients seeking to advance the prospects of development giving rise to profits to landowners and builders under existing models that are adding to the problematic scale of unsustainable development that will need to be re-visited and fixed before 2050.
In the context of a s78 appeal (Ref Appeal Decision APP/N2345/A/12/2169598) an inspector expressed surprise at the lack of help being given to him by the professional experts. The examiner of the Vale of White Horse Local Plan is being faced with the proposition from the LPA that the EU and UK carbon budgets (under the Climate Change Act and para 94 of the NPPF) are unrealistic, and the need to reduce carbon emissions by about 60% during the plan period should not be an impediment to the 40% planned growth in housing, jobs and associated infrastructure. The Sustainability Assessment has identified the ‘negative impacts’ that almost all the proposed development will have on carbon emissions with no ‘major positive’ impact to start the transition to a low carbon economy. The response from the Inspector was a question as to whether this conundrum had been raised before any othe inquiry/examination?
So when recommendations are being formulated as to how the development plan system might be made more efficient and effective, the Panel should take into account that the new system should deal with the question of how sustainability can be dealt with in development planning an honest way (and in accordance with the first two paragraphs of Greg Clark’s Foreword to the NPPF) that planned development does not make the situation worse for future generations.
I hope that this is interesting if no longer a post that readers can use to join in the debate.