This post was first published by The Croydon Citizen on 24/09/2018.
Croydon’s new planning guidelines: great leap forward or stumble to uncertainty? (part 2)
Following on from my article last week on the implications for the Croydon Local Plan with the implementation of the government’s revised National Planning Policy Framework (NPPF) guidelines, here are a number of further issues for Croydon’s planners to take into consideration. New text from the NPPF is shown below in italics.
Section 11 ‘making effective use of land’ makes it clear that ‘Planning policies and decisions should promote an effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions. Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land’ (paragraph 117).
Planning authorities are now expected to regularly review ‘both the land allocated for development in plans, and of land availability‘ (paragraph 120). No doubt this will be subject to at least an annual report to the council’s cabinet or planning committee.
Given the council’s obsession with meeting housing targets, this government addition in paragraph 122 may be helpful: ‘d) the desirability of maintaining an area’s prevailing character and setting (including residential gardens), or of promoting regeneration and change; and e) the importance of securing well-designed, attractive and healthy places‘.
Many people consider that Croydon council has agreed too many applications which are not ‘good design’. The new plan sets out the government approach to stimulate good design. Paragraphs 124-6 in section 12 ‘Achieving well-designed places’ are important and the current Croydon consultation on design needs to be assessed against them.
There is also a strengthening of requirements on planning authorities which ‘should ensure that they have access to, and make appropriate use of, tools and processes for assessing and improving the design of development. These include workshops to engage the local community, design advice and review arrangements, and assessment frameworks such as Building for Life…‘ (paragraph 129).
The government has retained its 2012 sentence ‘permission should be refused for development of poor design that fails to take the opportunities available for improving the character and quality of an area and the way it functions’ – but has added ‘taking into account any local design standards or style guides in plans or supplementary planning documents. Conversely, where the design of a development accords with clear expectations in plan policies, design should not be used by the decision-maker as a valid reason to object to development. Local planning authorities should also seek to ensure that the quality of approved development is not materially diminished between permission and completion, as a result of changes being made to the permitted scheme (for example through changes to approved details such as the materials used)‘.
Green Belt and the environment
Section 13 ‘protecting Green Belt land’ retains the 2012 guidelines about the purpose of the Green Belt. The new text in paragraph 137 makes it clear that planning authorities must look at all options ‘(b)efore concluding that exceptional circumstances exist to justify changes to Green Belt boundaries’. Paragraph 138 adds that in releasing the Green Belt for development, authorities must consider whether it ‘is well served by public transport‘.
Section 14 ‘meeting the challenge of climate change, flooding and coastal change’ has few amendments on 2012.
Section 15 ‘conserving and enhancing the natural environment’. Paragraph 170 stresses how important it is to improve air and water quality; ‘maintaining and enhancing networks of habitats and green infrastructure‘ and planning ‘for the enactment of natural capital at a catchment or landscape scale across local authority boundaries‘. (Paragraph 171)
In relation to habitat, biodiversity plans are now expected to ‘safeguard… wildlife-rich habitats and wider ecological networks’; and ‘identify and pursue opportunities for securing measurable net gains forbiodiversity’ (paragraph 174).
‘A new development needs to be appropriate for its location’
Paragraph 180 appears to be a key one because of additional wording on the previous formulation: ‘planning policies and decisions should also ensure that a new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on health, living conditions and the natural environment, as well as the potential sensitivity of the site or thewider area to impacts that could arise from the development…‘.
Section 16 ‘conserving and enhancing the historic environment’ strengthens the government’s view on the importance of heritage assets, adding the new wording ‘so that they can be enjoyed for their contribution to the quality of life of existing and future generations‘.
It strengths the requirements on planning authorities to ensure the maintenance of evidence. ‘Local planning authorities should maintain or have access to a historic environment record. This should contain up-to-date evidence about the historic environment in their area and be used to: a) assess the significance of heritage assets and the contribution they make to their environment; and b) predict the likelihood that currently unidentified heritage assets, particularly sites of historic and archaeological interest, will be discovered in the future.’ Further they ‘should make information about the historic environment, gathered as part of policy-making or development management, publicly accessible’ (paragraph 188).
‘Developers need to record and advance understanding of any heritage assets to be lost’
An important new text is added in paragraph 199: ‘local planning authorities should require developers to record and advance understanding of the significance of any heritage assets to be lost (wholly or in part) in a manner proportionate to their importance and the impact, and to make this evidence (and any archive generated) publicly accessible. However, the ability to record evidence of our past should not be a factor in deciding whether such loss should be permitted’.
The accompanying footnote (no. 64) states: ‘copies of evidence should be deposited with the relevant historic environment record, and any archives with a local museum or other public depository’.
The final section is no. 17: ‘facilitating the sustainable use of minerals’, and there are two annexes: (1) ‘implementation’ and (2), ‘glossary’.