The Royal Town Planning Institute (RTPI) has recently released its formal comments for consideration. One of the main concerns revolves around the lack of clarity of the National Planning Policy (NPPF). The points have been summarised below:
- Clarification of the presumption in favour of sustainable development. The Government needs to define sustainable development more precisely. As drafted, the presumption risks a disruption in the smooth running of the planning system. Any change needs to be managed effectively;
- A tightening up of language. In parts, the language needs to be tightened up to avoid ambiguity and legal challenge;
- The document to have a spatial aspect, expressing a vision for development forEnglandas a whole, recognising that different parts of the country will be affected differently by policy;
- NPPF on the face of the Localism Bill. The status of and procedures for producing and reviewing the NPPF need to be embodied in statute to ensure proper public debate of issues and restore democratic accountability through Parliament; and,
- Positive planning needs to be holistic, and not reactive. The draft focuses on providing a basis for determining planning applications rather than genuine place shaping.
In essence, the RTPI comments call for clarity on a number of matters. No doubt one of the main concerns will be the appeal process, where in the absence of clear guidance, will undoubtedly mean a much higher number of appeals. This in turn may lead to a much higher dependence on case law to determine applications. We wait for the next stage in the process.