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.
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