National Planning Policy Framework

Written evidence from Surrey County Council

 

Summary of main points

· The draft NPPF appears to place far greater emphasis on the benefits of economic growth compared with the environmental and social aspects of sustainable development. Local views that are equally concerned with environmental and social issues and the impact of more growth may not be given voice in planning decisions.

· If more weight is to be given to the achievement of economic objectives, then the presumption in favour of sustainable development risks new development that is not necessarily in the right place or of an appropriate scale for the location being permitted where there is no up to date local plan.

· The proposed duty to cooperate needs to be strengthened further to provide a sufficient basis for strategic planning, including both plan-making and delivery aspects and more guidance is required.

· As part of the duty to cooperate, the NPPF should introduce a requirement for a strategic infrastructure assessment to ensure that strategic planning issues are properly addressed and to help co-ordinate investment and address some of the challenges for delivering sustainable development in two-tier areas.

Introduction

1 A prime objective of the County Council is to support the sustainable growth of Surrey’s economy, which is one of the strongest in the South East and nationally, but it is important that economic growth should not be at the expense of social and environmental considerations.

2. Surrey experiences considerable demand for housing and economic development, However, because the county includes Areas of Outstanding Natural Beauty and some 73% is designated Green Belt, regional planning policies over the last 20 years have recognised these constraints and taken a strategic view of housing provision by directing more housing to growth areas in the South East such as the Thames Gateway, Milton Keynes and Ashford. Nonetheless, the county has taken substantial growth over the past few decades and for most of those years achieved its annual housing requirement. Similarly, within Surrey itself there are some districts and boroughs where there is more capacity in their built up areas to take a greater share of growth to meet needs.

3. Much of this growth has been through small-scale and incremental development and consequently it has been difficult to secure sufficient developer contributions to deal with the cumulative impact on local and strategic infrastructure. Congestion on the road network and pressure on school places arising from new development are key current concerns for many of our communities.

4. We welcome the Government’s objective to condense existing national planning policy guidance into a simpler and clearer National Planning Policy Framework to help make the planning system more accessible. Given the above, we consider that such policy guidance must provide an adequate framework within which councils can draw up local plans that give sufficient weight to environmental and social considerations in promoting economic growth and enable strategic issues to be fully addressed and the timely delivery of infrastructure to support development. However, we have a number of concerns that the draft NPPF does not provide such a framework for the reasons set out below in response to some of the Committee’s questions.

Response to Committee Questions

Does the NPPF give sufficient guidance to local planning authorities, the Planning Inspectorate and others, including investors and developers, while at the same time giving local communities sufficient power over planning decisions?

5. The draft NPPF states that local planning authorities should cater for housing demand and the scale of housing supply necessary to meet this demand and also refers to ensuring that Local Plans meet the full requirements for market and affordable housing in their housing market area. The demand for new housing in Surrey significantly exceeds the annual housing requirement set out in the South East Plan. We believe that any future housing requirements should be set on the basis of need rather than demand and are concerned as to whether the proposed duty to cooperate will be able to deal with housing requirements that cannot be accommodated in an area where there is a lack of physical capacity or to do so would have adverse impacts that would significantly and demonstrably outweigh the benefits.

6. The draft NPPF places a clear emphasis on economic growth and appears to give this far more weight than environmental and social issues. Therefore, local views that are equally concerned with environmental and social issues and the impact of more growth may not be given voice in planning decisions. This seems inconsistent with the localism agenda and giving local communities greater control over the planning of their areas.

7. We consider there is a need for further guidance on the duty to cooperate. See comments below.

Is the definition of ‘sustainable development’ contained in the document appropriate; and is the presumption in favour of sustainable development a balanced and workable approach?

8. The definition of sustainable development set out in the NPPF at paragraph 9 based on the 1987 Brundtland Report is a widely accepted definition, but this is over 20 years old. More recently, Defra’s "Securing the Future Delivery of the UK’s Sustainable Development Strategy" (2005) has set out how the goal of sustainable development should be pursued. The NPPF, however, although referring to economic, social and environmental roles as components of sustainable development that planning should pursue in an integrated way, is clear that significant weight should be placed on the need to support economic growth. Indeed, taken as a whole, the NPPF appears to place far greater emphasis on the benefits of economic growth compared with the environmental and social aspects of sustainable development with more references made to the economic dimension.

9. The majority of local authorities do not have an up to date local plan in place (in Surrey 5 out of the 11 districts have adopted core strategies) and the NPPF indicates that in such areas planning applications should be determined in accord with the NPPF, including its presumption in favour of sustainable development. This risks insufficient weight being given to environmental and social issues in assessing development proposals, where grounds for refusal would have to be on the basis of there being adverse impacts that "significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole", and new development that is not necessarily in the right place or of an appropriate scale for the location being permitted. We consider it particularly important that new development should not give rise to undue pressure placed on existing infrastructure without the ability to secure appropriate mitigation.

Does the NPPF, together with the ‘duty to cooperate’, provide a sufficient basis for larger-than-local strategic planning?

10. While we acknowledge that the proposed duty to cooperate in the Localism Bill has been strengthened since the Commons Committee Stage, we do not think it provides a sufficient basis for strategic planning, including both plan-making and delivery aspects. There are particular challenges in two tier shire areas where county councils provide much of the infrastructure and services to support new development. While we are working closely with our borough and district council partners to develop infrastructure and delivery plans and CIL charging schedules that will help deliver their plans for growth there is no obligation for the districts as CIL charging and collecting bodies to spend the receipts on the infrastructure and the priorities identified to support growth. This presents a challenge if larger-than-local strategic planning and infrastructure issues are to be addressed.

11. We would like to see county councils designated as charging authorities as well as district councils and, as part of the duty to cooperate, for the NPPF to introduce a requirement for a strategic infrastructure assessment or framework that looks across all infrastructure and service needs to support development. County councils are well placed to lead on the preparation of such assessments, which would ensure that strategic planning issues are properly addressed and help co-ordinate investment and address some of the challenges for delivering sustainable development in two-tier areas.

Surrey County Council

September 2011