Saltford Parish Council (SPC) resolved its response to the Government’s consultation on a revised National Planning Policy Framework at its 3 September 2024 meeting. In its response, SPC agreed to seek a stewardship approach to land use planning.
SPC’s full response to the NPPF consultation, and an accompanying executive summary of the stewardship approach sought by SPC, can be found as follows:
- Saltford Parish Council response to proposed reforms of the NPPF
- Executive summary – SPC’s response to proposed reforms of the NPPF
The Government’s consultation titled ‘Proposed reforms to the National Planning Policy Framework and other changes to the planning system’ (for submission to the Ministry of Housing, Communities and Local Government by 24 September 2024), consults on revisions to the NPPF. The NPPF forms the Government’s planning policies for Local Planning Authorities (LPAs) including B&NES Council. The NPPF revisions will have an impact on house building targets in the B&NES area.
SPC resolved to answer specific sections of the NPPF consultation that related to matters central to SPC’s interests and concerns, including Green Belt matters. During consideration of the NPPF consultation at the SPC meeting, Cllr Phil Harding, Chair of SPC’s Planning Committee, provided a concise overview of some of the key points he recommended the Council make as part of SPC’s response. This included the focus of SPC’s response on Planning Practical Guidance with views on ‘Food Security’ and ‘Support Ecological Recovery’; ‘Grey Belt and Previously Developed Lane (PDL) in the Green Belt’; and ‘Valuing landscapes and protecting the health and well being of communities’. SPC’s full response to the NPPF consultation (as linked above) was resolved by the Council, as was an executive summary of the response for publication and circulation (also linked above, and copied below).
Further to SPC’s response to the Government’s NPPF consultation, it was resolved that SPC’s response to the NPPF consultation and accompanying executive summary would be sent to the Member of Parliament for North East Somerset and Hanham, Dan Norris M.P. It was also agreed that representatives of SPC would seek to meet with Dan Norris M.P. to request his support of the key points made by Saltford Parish Council in its response to the NPPF consultation.
The Council also resolved that SPC would share its response with the Member of Parliament for Bath Wera Hobhouse M.P., Keynsham Town Council, CPRE Avon and Bristol, B&NES Council’s Head of Planning, B&NES Council Saltford Ward Councillors, B&NES Council’s Leader of the Council, and the B&NES Council Cabinet Member for Built Environment, Housing and Sustainable Development.
B&NES Council is the ‘Local Planning Authority’ for Saltford. On 4 September B&NES Council published a press release titled ‘Cabinet to consider increased housing figure targets’. This stated that a detailed report will go before B&NES Cabinet that includes that the new government target would see a significant uplift in the housing numbers that B&NES needs to plan for as part of its Local Plan (as steered by the revised NPPF consultation), going from the current 717 houses per annum to 1,466 per annum. The press release also refers to B&NES Council’s own intention to respond to the NPPF consultation.
SPC’s comprehensive response to the NPPF consultation should be considered alongside the significant activity taken by SPC, particularly since January 2023, to protect Saltford’s Green Belt. A summary of actions taken by SPC to achieve designated landscape protection for areas of Saltford’s Green Belt can be found on SPC’s ‘Protecting Saltford’s Green Belt‘ page. This page also includes SPC’s strong objection to proposals for 1,300 residences on Saltford’s Green Belt, as in B&NES Council’s Options Consultation which took place in early 2024.
‘Planning Matters’, including matters relating to the B&NES Council Local Plan and SPC’s actions to protect its Green Belt, is a standing item on SPC’s agendas. More information about SPC’s meetings can be found on our ‘Meetings – Agendas and Minutes‘ page.
Executive Summary of SPC’s response to the NPPF consultation:
This is a summary of the main points made in SPC’s response to the Government’s consultation on an updated National Planning Policy Framework (NPPF) that was resolved on 3rd September 2024 for submission to the Ministry of Housing, Communities and Local Government. Explanations of these and additional points are contained in the full SPC response.
LAND STEWARDSHIP
- This updating of the NPPF has the potential to provide a much-needed opportunity for the Government to move land-use planning to more of a “land stewardship approach” so that planning the provision of land for new housing will improve, not reduce, the nation’s future food security and strongly support ecological recovery without a negative outcome for the open green spaces that are so important to the health and well-being of local communities.
- Either adding a specific new paragraph or a (new) sixth purpose to the list of Green Belt purposes “to protect agricultural land and/or eco-systems that help underpin the UK’s food security” would show the Government’s commitment to not only provide sufficient houses but simultaneously improve future food security, not reduce it, whilst enabling nature’s recovery from the ecological emergency.
FLEXIBILITY IS ESSENTIAL FOR SUSTAINABLE DEVELOPMENT
- The proposed “one-size fits all” baseline approach of 0.8% growth of existing housing stock per annum for every LPA does not fit with sustainable development principles and taking a longer-term holistic approach to the nation’s needs and aspirations would be preferable.
- To allow for LPA areas that specifically support or have potential to improve food security and ecological recovery, a flexible baseline approach with lower and higher amounts than the proposed 0.8%, for example, might be more appropriate with additional infrastructure incentives for those areas that can meet a higher baseline to assist in meeting national housebuilding targets.
- Flexibility is particularly important for communities that have historically absorbed significant volumes of development that have reduced recreational and open green space for residents, and created traffic and other transport problems that can severely reduce the quality of life for the existing community.
GREY BELT & PREVIOUSLY DEVELOPED LAND (PDL) IN THE GREEN BELT – AVOIDING LAND ABUSE
- Allowing Green Belt development to help meet the Housing Delivery Test could enable decisions to be unduly influenced by a number of factors including vested interests, corruption, and short-termism.
- Land-use planning should be part of a long-term process so that it delivers sustainable development on a more permanent basis and that takes account of environmental priorities which, as is widely acknowledged, underpin all other sustainable development goals, i.e. economic and social outcomes.
- The introduction in the NPPF of a new Grey Belt definition for previously developed land in the Green Belt needs safeguards to avoid providing incentives to allow the degradation of existing Green Belt Land such as “developed at least 15 years previously to the date of application”.
- Grey Belt definitions should not enable unauthorised or informal developments including ‘change of use’ activities made in the short-term, to become gateways to Green Belt development that would otherwise be inappropriate.
- For the avoidance of doubt, it is essential that the updated NPPF itself makes it clear that it is only grey belt land in the Green Belt that could be released to meet commercial and other needs, not Green Belt land that has not been previously developed.
VALUING LANDSCAPES & PROTECTING THE HEALTH & WELL-BEING OF COMMUNITIES
- The proposed sequential test and that protections will be maintained for “existing environmental designations” is welcomed. However, the local community should, through its elected representatives on Town or Parish Councils, have the opportunity to identify and designate for protection locally important and sensitive landscapes.
- A local community knows and understands the strengths and weaknesses of its local area and the value placed on its local landscape more than anyone including the LPA. The (updated) NPPF should place a requirement on the LPA to give due consideration of landscape designation requests submitted by local communities in its land-use planning decisions and plan-making processes.
- To add yet further developments in degraded areas that have historically absorbed significant volumes of development can exacerbate problems already created, whereas a new Garden City/Town approach can avoid ongoing damage to existing communities and ensure town planning is done correctly and holistically, rather than the current piecemeal incremental approach of adding new developments to existing communities already under extreme pressures.
- New developments – including new Garden Cities/Towns – must come with public green spaces such as sufficiently large public parks to protect the health and well-being of new and existing communities.
- The overriding objective should be “building new homes in the right places in well-designed developments”.
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B&NES Council press release 4 September 2024: ‘Cabinet to consider increased housing figure targets‘
New mandatory housing targets set out by the Government are to be discussed by Bath & North East Somerset councillors when cabinet meets on September 12.
A detailed report before cabinet says the new government target would see a significant uplift in the housing numbers that B&NES needs to plan for going from the current 717 houses per annum to 1,466 per annum. The purpose of this increase is to address historic shortfalls in housing delivery and meeting housing needs.
These new targets would require a reset of the Council’s Local Plan, including a review of the Green Belt and a stronger focus on housing affordability to meet needs of those on lower incomes. In addition, the report says the new targets would need a commitment to regional/strategic planning to ensure that sustainable communities are designed with the right infrastructure to thrive.
The council’s recently adopted Economic Strategy acknowledges that addressing the lack of affordable housing in Bath & North East Somerset is a key priority to improve people’s lives and the report welcomes the Government’s focus on this important issue.
Councillor Matt McCabe, Cabinet Member for Built Environment, Housing and Sustainable Development, said: “Here in B&NES, we are committed to delivering the right homes in the right places, and homes that are genuinely affordable. We also have an aspiration to be building hundreds of council homes every year. So, I welcome any changes that help us deliver on our priorities. However, the current NPPF consultation proposes a more than doubling of our current housing targets, when compared to the figures included in our new, emerging Local Plan. We had been intending to put a Draft Plan out for consultation at the beginning of 2025, with Draft Plan submission to the Planning Inspectorate next June.
“We need now to carefully consider the impact of the draft NPPF on this programme. We will therefore be seeking more clarity from central government on their methodology for arriving at their new figure, as well as on their levels of commitment to providing more support for affordable housing delivery. Crucially, our residents would expect any additional housing to be supported by much-needed infrastructure – including sustainable transport, health, education and community facilities- and we will be making these points clearly in our response to the consultation.”
In July the Government announced that all councils in England were to be given new, mandatory housing targets and is currently consulting on a revised National Planning Policy Framework (NPPF) and other changes to the planning system.
Bath & North East Somerset Council needs to respond to the consultation and cabinet is being recommended to note the government’s proposed changes to the NPPF and to agree the key elements of the council’s response to the consultation on the revised NPPF and other changes to the planning system.
Cabinet is recommended to delegate authority to the Executive Director for Sustainable Communities, in consultation with the Cabinet Member for Built Environment, Housing and Sustainable Development, to agree and submit the council’s response to the government’s consultation on the revised NPPF and other changes to the planning system.
It is also being asked to agree a reset of the Local Plan and agree its preparation should progress towards submission in advance of the Government’s new deadline of December 2026.
The Local Plan is an important statutory document used for decision-making on development and the use of land, and when adopted will form the basis for determining planning applications until 2042.
Thousands of responses have been received in a consultation held earlier this year on the Local Plan Options Document – the first stage in the development of a new Local Plan which was due to be consulted on early next year. The outcome of this consultation stage will help to inform the reset of the Local Plan that the council are required to undertake.
Cabinet is being asked to delegate authority to the Executive Director for Sustainable Communities, in consultation with the Cabinet Member for Built Environment, Housing and Sustainable Development, to agree and publish a revised Local Development Scheme setting out the revised programme for Local Plan preparation.
And it is recommended the council continues to co-operate with neighbouring authorities and the West of England Combined Authority (WECA) to ensure that strategic planning delivers the affordable housing we need, as well as the supporting infrastructure.
You can find out more about the Local Plan on the council’s website.
The report going before cabinet on 12 September can be viewed on the council website . You can watch the Cabinet meeting live at 6.30pm on the same web page, or watch later on the council’s YouTube channel