Whaley Bridge Amenity Society

Registered Charity No. 500862

National Planning Policy Framework — Consultation Response

Introduction:

Whaley Bridge is a small town in the High Peak of Derbyshire. Its population is about 7,000. The Local Planning Authority is High Peak Borough Council. For a small area of the town lying within the Peak District National Park, planning is administered by the Peak Park National Planning Authority from its administrative centre in Bakewell.

Whaley Bridge Amenity Society (the ‘Society’) was formed in the late 1960s. The Objects of the Society are:

Upon the reorganisation of local government in 1974, High Peak Borough Council was created and Derbyshire County Council’s responsibilities with regard to planning, and other services, were amended. Since then, our Society has played a prominent role within the communities of High Peak in responding to public consultation by both High Peak Borough Council and Derbyshire County Council, including:

Our Society comments on planning applications within the Parish of Whaley Bridge that are relevant to our Objects, sometimes supporting an application, sometimes opposing it, sometimes seeking to secure conditions on a consent to ameliorate the ‘harm’ consequent upon the proposed development.

Our Society has participated in many Planning Appeals over the last four decades. It has played a leading role in the development of, and maintenance of the integrity of, the Public Rights of Way network. It helped to secure the ‘listing’ of several of the two dozen Listed Buildings within the Parish. It led the campaign for the creation of the Whaley Bridge Conservation Area and helped to identify the relevant area. It has participated in the two subsequent Whaley Bridge Conservation Area Character Assessments.

National Planning Policy Framework (NPPF) Consultation Response:

There should be a simplified national (ie across England) planning policy framework, but one through which communities are enabled to take a stronger lead in securing the long term public interest in the development and use of land. It should not be simply, nor primarily, a tool for economic growth.

The current presumption against inappropriate development inside the Green Belt should be retained. Indeed, greater protection should be considered for Green Belt areas, National Park areas and other specially designated areas. We welcome, in principle, Local Green Space designations.

The ‘brownfield first’ policy should be retained so that previously developed land, where it exists, is normally used to meet development needs before ‘greenfield’ sites.

There should be effective integration of transport planning and land use planning; otherwise, development will fail to be ‘sustainable’. ‘Sustainable development’ should be redefined so that the environmental (and climate change) consequences of all development are given greater weight; indeed, all development should be environmentally sustainable. Development should be ‘plan-led’. A planning application that is not in conformity with the Local Development Plan should normally be rejected unless there is strong evidence that the local community has been specifically consulted and on balance is supportive.

There is a long-standing need for more housing provision, and in particular for more affordable housing provision for those unable to access fit-for-purpose market housing of a decent standard. It is unclear that S106 agreements, New Homes Bonus and Community Infrastructure Levy (CIL) arrangements will be able to address these needs, and to fund necessary associated infrastructure improvements, in any significant way. Robust and up-to-date Housing Needs Assessments should be in place, and should be a core component of each Local Development Plan.

Whilst the NPPF appears at first sight to retain the spirit of Planning Policy Statement 5 (PPS5) by protecting the nation’s heritage assets, and this is welcomed, there is concern that it should not be weaker in any detailed respect, nor in its interpretation.

It is recommended that provision is made for ‘transitional’ arrangements for Local Planning Authorities, whose successor Local Development Plan has not received Secreatary of State approval at the time that the NPPF comes into force.

It is noted that paragraph 75 states that the 'long term' (undefined) protection of employment land or floor space should be avoided.  In an area (such as Whaley Bridge) where land suitable for employment is in short supply this would be imprudent and would contradict the general thrust of the NPPF, which encourages economic development. (See particularly paragraph 81.)

Prepared by: Cllr. John A T Pritchard (Chairman: Whaley Bridge Amenity Society)

14th October 2011

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