The Battersea Society: Planning Committee submission The Battersea Society website 

Planning Committee Submission

Added on: 12 June 2018 at 18:42:20

Response to the draft revised National Planning Policy Framework

May 2018 

The response below does not cover all the questions listed in the consultation document but focuses on those of greatest relevance to the planning issues the Battersea Society faces in its local area.

Chapter 1: Introduction

Q1:Do you have any comments on the text of Chapter 1?

The introduction unfortunately sets the tone for the drafting of much of the document which at times is obscure and often convoluted in stating the policy proposed. While some sections are more directive and clear, many are vague, hedged with qualifications or require cross referencing to other documents. In some sections simple clear diagrams would have helped, for example to exemplify the suggested plan and decision making structures.

Chapter 2: Achieving sustainable development

Q2: Do you agree with the changes to the sustainable development objectives and the presumption in favour of sustainable development?

No, not as an underlying objective for all planning decisions. This is because the whole tone of the revised NPPF is now too much in favour of numbers driven new development especially housing. There is inadequate guidance at national strategic level for promoting high quality local environments, creative solutions for neighbourhoods and communities, or protecting and conserving historic architectural areas.

Q3: Do you agree that the core principles section should be deleted, given its content has been retained and moved to other appropriate parts of the Framework?

No. It was more helpful to have the core principles listed as previously. These provided  a more directive policy reference for local planning authorities and for members and interest groups in responding planning applications. The previous document set out the more detailed elements of each core principle in a more accessible form than the revised version.

Chapter 3: Plan-making

Q5: Do you agree with the further changes proposed to the tests of soundness, and to the other changes of policy in this chapter that have not already been consulted on?

Not altogether as the test of conformity with national policy is increasingly difficult, given the supremacy of housing development now proposed for the national framework.

Q6: Do you have any other comments on the text of chapter 3?

We consider that the local planning framework has been weakened by the legal requirement focusing on the setting of strategic principles with only only a permissive requirement to produce more detailed plans as deemed necessary locally. On the face of it this sounds a pragmatic approach given the pressure on local authorities finances. However in the longer term it could be seriously detrimental to the longer term quality of the environment. In particular in metropolitan areas where brown field and/or run down sites are subject to total redevelopment site specific policies can be crucial in terms meeting strategic objectives,  local place making and in creating a high quality day to day living environment. A formal local framework for such sites is a very helpful guide and a pre-requisite of achieving sustainable principles. We consider that in such areas preparation then regular review of local plans should be a legal requirement, together with supplementary planning guidance related to specific local issues.

Chapter 4: Decision-making

Q7: The revised draft Framework expects all viability assessments to be made publicly available. Are there any circumstances where this would be problematic?

We welcome the this requirement. In the past it has been difficult for local interest groups to access information submitted on viability.

Q9: What would be the benefits of going further and mandating the use of review mechanisms to capture increases in the value of a large or multi-phased development?

We have been pressing for this in the Vauxhall Nine Elms Opportunity Area as it is a more  equitable means of ensuring that low thresholds for viability can be adjusted if market conditions indicate that developer returns are higher than forecast at plan approval stage and hence the number of affordable units can be increased in later stages of developments.

Q10: Do you have any comments on the text of Chapter 4?

Pre-application discussions: We consider that it should be the norm for local planning authorities to formally write to developers confirming the outcome of pre application discussions including the guidance on the application offered to them by planning officers. This should be posted online with other documents if an application is submitted. Some planning authorities already do this but if it was universal local interest groups and members would always be aware of any general encouragement given to particular aspects of controversial proposals , and also whether alleged approved local priorities are being stretched to meet developers demands.

Chapter 5: Delivering a wide choice of high quality homes

Q11: What are your views on the most appropriate combination of policy requirements to ensure that a suitable proportion of land for homes comes forward as small or medium sized sites?

The target of 20% of sites being less than half a hectare is unrealistic in densely developed urban areas such as central London where redevelopment off larger sites is extensive

Q14: Do you have any other comments on the text of Chapter 5?

The whole chapter is poorly drafted and argued. This is meant to be the key to the new vision yet in itself needs to be read and re-read to grasp what exactly is being proposed.

The provision of new housing is too dependent on private market demands as opposed to the needs of those on low incomes. The definition of affordable housing at 80% of market rents means that housing pressures will rise in central London and more and more essential workers will be forced to undertake long journeys to work in central boroughs, including those who work early late and night shifts on low wages.


Even with this definition, the target of 10% for affordable homes is a pitiful figure for metropolitan areas with high needs and property prices. Existing borough plans aim for significantly higher figures than this and even they are frequently well below the London Plan target of 35%.

para 71 and 72 are particularly obscure in their discussion of windfall and exception sites. More guidance should be given of the longer policy for such sites.  Are Al units retained for entry-level buyers on resale?

We consider there is a lack of creative thinking on different ways to deliver what is actually affordable housing. For example there is no discussion the role of prefabrication of units might play in rapidly increasing the supply of housing, or

The quality of housing once delivered is not touched on in spite of high profile cases of poor or failing building standards recently. Again a suggested process diagram suggesting ways of greater cooperation between planners, building inspectors and developers would offer more credibility to this section.

We support the suggestion that there should be tighter monitoring and potential penalties for slow development of sites. once planning approval has been given.

Chapter 6: Building a strong, competitive economy

Q15: Do you agree with the policy changes on supporting business growth and productivity, including the approach to accommodating local business and community needs in rural areas?

We strongly support paragraph 83 which provides (with para 84 for rural areas)  clear straightforward guidance not commonly found elsewhere the document. Nevertheless it will be important that local authorities are encouraged to adopt these types of policies in a formal local plan including site specific guidelines for business and industrial sites. This is needed to avoid loss of local employment (and particularly service industry) sites in central urban areas which are too readily being displaced by new high rise residential developments.

Chapter 8: Promoting healthy and safe communities

Q20:Do you have any other comments on the text of Chapter 8?

This chapter should refer to the need for large scale urban developments to have integrated  open spaces of a form which are usable. While the provision of open space in new high density developments may meet policy standards if it too fragmented it fails to provide areas for longer periods of sitting or playing etc and may also have high maintenance costs after initial planting.

This section (as well as the chapter on the natural environment) should emphasis the need to monitor and take action to improve and maintain high air in urban and other areas with high pedestrian footfall.

Chapter 9: Promoting sustainable transport

Q21:Do you agree with the changes to the transport chapter that point to the way that all aspects of transport should be considered, both in planning for transport and assessing transport impacts?

Q23:Do you have any other comments on the text of Chapter 9?

To just say that all transport issues and impacts always have to be taken into account means very little. The important assessment in areas of high growth is not just the transport impact of a particular application but also of all other sites with approval in the development pipeline. In London the pace and scale of new developments in some areas needs a holistic approach, assessing the cumulative impact of all the approvals on public transport facilities and traffic congestion. Unfortunately there has been a failure by the strategic authority – TfL – to develop realistic models of traffic generation and demand on local public transport routes for different sectors of London. Thus traffic gets slower, buses trains etc get more overloaded, air pollution increases and safety is jeopardised due to overcrowding at stations. It is important therefore that the role of strategic transport authorities is emphasised and explained in the NPPF, and the need for integrated modelling of transport needs and impact undertaken at that level. Such analysis can then provide a framework within which local planning authorities can assess applications for major developments.

Chapter 12 Achieving Well Designed Places

Q.28:  Do you have any comments on the changes of policy in Chapter 12 that have not already been consulted on?

We endorse paragraph 124 but plans should set out a vision for a whole area, with appropriate computer visualisation, rather than applications providing images of an individual building with surrounding buildings shown in light outline.  Simulations of the entire area are needed, showing the cumulative effect as it will look when all other consented and planned buildings are in place

Paragraph 125 lacks clarity.  As in so much of this document there is a proposal in the first half of the paragraph and then a drawing back in the second half.  Those who are drafting should go through and take out ‘However … ‘ whenever they are tempted to qualify what might be sound advice as what follows effectively tells local authorities and, more importantly developers, to ignore this advice if they wish. 

Paragraph 131 is another example where an excellent start stating that:  the quality and character of places can suffer when advertisements are poorly sited and designed. … is then undercut by the final sentence:  Advertisements should be subject to control only in the interests of amenity and public safety.…Does amenity include the quality and character of places?  We hope so.

It is refreshing to read paragraph 126 which is clear and straightforward..

Q.29  Do you have any other comments on the text of Chapter 12

Good design can be a matter of individual opinion and it is essential that the Local Planning Authority has the advice of disinterested professionals to aid their assessment of complex schemes.  In paragraph 127 no mention is made of Design Review Panels – an absolute essential in terms of providing sound advice to both the developer and the local authority.  While consultation with the lay community is essential, this must be augmented by such advice which provides essential input to planning officers, councillors and the community. 

Both the report of the Design Review Panel and the minutes of pre-application discussions with officers and councillors of the LAP should be made public when the application itself is in the public domain.

We mourn the fact the CABE now have to charge and consider their services should more often be used by L Pa's and by the GLA.  The Bishop Review contributed much to setting down principles of good design and guidance to Design Review Panels but we fear this work was rarely implemented and is now forgotten.

Chapter 15: Conserving and enhancing the natural environment

Q 34;Do you agree with the approach to clarifying and strengthening protection for areas of particular environmental importance in the context of the 25 Year Environment Plan and national infrastructure requirements, including the level of protection for ancient woodland and aged or veteran trees?

Yes it is important however that this is given equal priority for implementation as other elements of the framework and protection is not compromised by pressures to deliver on housing and other development regardless of environmental impact and disbenefits for local communities.

Q35:Do you have any other comments on the text of Chapter 15?

We generally welcome the policy priorities set out in this chapter but feel an added emphasis that open spaces and especially tree populations in urban areas must not be forgotten in the assessment of the impact of proposals on local environments.

Chapter 16:  Conserving and enhancing the historic environment

Q.36  Do you have any comments on the text of Chapter 16

No mention is made of the need for the preparation and publication of Conservation Area Appraisals and Management Strategies – absolutely essential in guiding planners and residents in what should and should not be allowed in conservation areas.

Overall this is another example of unclear drafting which combines pious exhortation with hasty retraction or the offering of ways in which an applicant can get round these guidelines.

While it is not within the scope of this consultation, it should be noted that pressure on council budgets is having an adverse impact on the ability of LPAs to provide sufficient conservation staff within planning departments.