RCA's 38 Days of the Housing White Paper; Day 4...

Everyday for the next 35 days we will be providing a link to our responses to the Government's Housing White Paper; here is our reply to Question 4... 


Do you agree with the proposals to amend the presumption in favour of sustainable development so that:

a)    Authorities are expected to have a clear strategy for maximising the use of suitable land in their areas?

We welcome a specific focus maximising the use of suitable land through a clear strategy for each planning authority area.  This may work better than a national presumption, however, it is currently unclear as to how they would relate.  The best use should be made of available land and we agree that local authorities should have a clear strategy for maximising the efficient use of such land.

However, there needs to be clarification as to what “clear”, “suitable” and “maximising” mean.  Whilst it is fully appreciated that the best use ought to be made of available land, this should not be at the cost of the creation of quality development nor a sense of place.

The Paper identifies “particular priorities that should be pursued” as part of this strategy including utilising brownfield and public sector land, creating new communities and also supporting small and medium sized sites.

b)    It makes clear that identified development needs should be accommodated unless there are strong reasons for not doing so set out in the NPPF?

The term “identified need” requires clarification as this could lead to confusion.

In terms of accommodating needs, the wording should be amended to read “unless…specific policies in this Framework provide a strong reason for development to be restricted” rather than “indicate”. This supports the government's objective of boosting significantly the supply of housing and is consistent with achieving genuine sustainable development.

c)    The list of policies which the Government regards as providing reasons to restrict development is limited to those set out currently in footnote 9 of the National Planning Policy Framework (so there are no long presented as examples), with the addition of Ancient Woodland and aged or veteran trees?

This would provide clarity in interpretation of the Framework.  This in turn will render decision making clearer and potentially help to speed up the planning process.

d)    Its considerations are re-ordered and numbered, the opening text is simplified and specific references to local plans are removed?

We agree to this principle.  We would also request an amendment to the Framework to ensure that the definition of previously-developed land as set out in Annex 2 also refers to garden land in non-built up areas as this has now been upheld in the Court of Appeal (see also Dartford Judgement).

We are not clear as to why the reference to ‘a golden thread’ has been removed.  This serves a purpose in emphasising that the three strands of sustainable development (economic, environmental, social) should be taken into account across the wide range of planning related proposals.  

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