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Responding to the NPPF Consultaion

24 September 2024

Teynham Parish Council has responded to the proposed reforms to the National Planning Policy Framework (NPPF) and other changes to the planning system.

 

24th September 2024

Dear NPPF Planning Policy Consultation Team,

Please find below our feedback on the proposed updates to the National Planning Policy Framework (NPPF) and related planning changes:

1. Simplification of the NPPF Framework

The current NPPF framework has become overly complex, hindering efficient and informed decision-making. We recommend simplifying the document by grouping its content into key thematic categories, such as:

  • Needs — Focus on genuine community and national needs.
  • Protections — Ensure comprehensive impact assessments with clear mitigation strategies.
  • People — Prioritise the well-being and interests of local communities in all planning decisions.
  • Resources — Safeguard limited and critical assets for future generations, such as water, farmland, and energy.

2. Consistent Numbering System

To enhance clarity and avoid confusion, we suggest adopting a consistent numbering system for NPPF regulations. This system should allow for updates (additions or deletions) without altering the overall structure, ensuring that future iterations remain easy to navigate.

3. Application Determination Process

We propose that planning applications, once submitted, should be reviewed as presented, allowing only minor changes within a 14-day window. The current practice of permitting multiple rounds of revisions and public consultations causes delays and inefficiency. Each substantial new application should be subject to a new planning fee to discourage unnecessary cycles.

4. Protection of Key Resources

Future generations rely on the protection of essential resources. The NPPF should emphasise safeguarding the following:

  • Water — (supply and storage)
  • Farmland — Grades 1 and 2 (vital for national food security)
  • Insects and Pollinators — (e.g., bees, crucial for biodiversity and food production)
  • Energy Resources — (including renewable energy options)

5. Expanding the Scope of Statutory Consultees

Additional stakeholders should be included in the statutory consultation process to ensure comprehensive feedback. These should include:

  • Water Supply Companies
  • Wastewater Companies

6. Centralised Information Sharing

We propose the creation of a single national website to share best practices and planning knowledge. This resource should be regularly updated and streamlined for ease of use, similar to the NHS’s website. Outdated or redundant information on government and local council websites should be promptly removed to ensure accuracy.

7. Heritage Protection

We disagree with the proposed introduction of fees for Listed Building Consent applications. This policy is likely to lead to an increase in unauthorised alterations, resulting in significant damage to our limited and irreplaceable historic assets.

8. Transport and Vision-Led Approaches

We have serious concerns regarding the proposed revisions to paragraphs 114 and 115. The term "vision-led approach" lacks a clear definition, making it difficult to assess its impact. Furthermore, the phrase "in all tested scenarios" could allow developers to present overly optimistic future projections of reduced traffic and trip generation. This could undermine the integrity of spatial planning by replacing evidence-based decisions with speculative outcomes. Rational planning should not be compromised by vague aspirations.

9. Agricultural Land and Solar Farms

Solar farms should not be developed on agricultural land, particularly Grade 1 and 2 farmland, which is essential for food security. We recommend exploring innovative solutions, such as integrating solar installations with existing infrastructure, to meet energy needs without jeopardising agricultural productivity.

We appreciate the opportunity to provide feedback and urge the government to consider these recommendations to ensure a more sustainable, transparent, and community-focused planning framework.

Yours sincerely,

Teynham Parish Council