Policy S1: Presumption in favour of sustainable development

GBC Policy

Policy S1: Presumption in favour of sustainable development

When considering development proposals we will take a positive approach that reflects the presumption in favour of sustainable development contained in the National Planning Policy Framework. We will work proactively with applicants jointly to find solutions that mean that proposals can be approved wherever possible, and to secure development that improves the economic, social and environmental conditions in the area.

Planning applications that accord with the policies in this Local Plan (and, where relevant, with policies in adopted neighbourhood plans) will be approved without delay, unless material considerations indicate otherwise.

Where there are no policies relevant to the application or relevant policies are out of date at the time of making the decision, then the Council will grant permission unless material considerations indicate otherwise, taking into account whether:

  • Any adverse impacts of granting permission would significantly and demonstrably outweigh the benefits, when assessed against the policies in the National Planning Policy Framework taken as a whole; or
  • Specific policies in that Framework indicate that development should be restricted.

GGG Response

Summary

We OBJECT to this policy.

While this wording is based on the National Planning Policy Framework (NPPF) – which is binding - this policy fails to recognise that development in rural areas, with inadequate transport and other infrastructure, cannot cope with the proposed scale of development. It is unsustainable. This should represent an absolute constraint on development.

Detailed response

This policy suggests that “We will work proactively with applicants jointly to find solutions that mean that proposals can be approved wherever possible, and to secure development that improves the economic, social and environmental conditions in the area". This does not appear to accord with the requirements of NPPF 10 which notes that "plans and decisions need to take local circumstances into account so that they respond to the different opportunities for achieving sustainable development in different areas".

Furthermore NPPF 14 notes that specific policies within the framework may require development to be restricted, and in this context, decision taking should not imply that development proposals should be approved in all circumstances.

NPPF 17 notes further that there are 12 planning principles which should be applied to underpin both plan-making and decision-taking and so these should be taken into account in the framing and the administering of the Local Plan. These include 

  • "empowering local people to shape their surroundings" 
  • "take account of the different roles and character of different areas, promoting the vitality of our urban areas, protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving communities within it" [note in this context that Guildford is in the Metropolitan Green Belt surrounding London and, therefore, that all users of the Green Belt within London are stake holders for the purposes of this assessment]
  • "support the transition to a low carbon future" [hardly promoted by increasing commuter dwellings] 
  • "contribute to conserving and enhancing the natural environment and reducing pollution" 
  • "encourage the effective use of land by reusing land that has been previously developed (brownfield land) provided it is not of high environmental value" 
  • "conserve heritage assets in a manner appropriate to their significance" 
  • "actively manage patterns of growth to make the fullest possible use of public transport walking and cycling and focus significant development on locations which can be made sustainable"

Of the 12 core principles set out in NPPF 17, Policy S1 seems to be disregarding at least 7 of these. These core principles must be taken into account in order to meet the requirement to comply with NPPF 17.

There is grave concern about the statement in the policy that “Planning applications that accord with the policies in this Local Plan (and, where relevant, with policies in adopted neighbourhood plans) will be approved without delay, unless material considerations indicate otherwise.” This is too flexible and too permissive and open to subsequent abuse. Policies should be structured as part of local plan so that they will be enforceable for the duration of the plan. Furthermore, the presumption in favour of all applications, as stated in this policy, fails to recognise the requirement for constraints which should be agreed and implemented as part of the Local Plan process. The proximity of the SPA, for example, should preclude development (which is a major factor for a large proportion of the borough); most development in the AONB should be severely restricted (which is another major factor); and Green Belt should act as a substantial constraint on development. The Birds and Habitats Directive is a further major issue.

Astonishingly, there are no Monitoring Indicators to ensure the achievement of this core requirement set out in paragraph 14 of the NPPF.

In the context of assessing sustainability it is worth quoting from the response of David Roberts who Is a retired civil servant who was, from 2005-08, in charge of the British Government's international policy on Sustainable Development (SD).

“The NPPF states that the presumption in favour of sustainable development “should be seen as a golden thread running through both plan-making and decision-taking[1]."  Standing at the head of the draft plan, Policy S1 ought to set a clear framework.  Instead, no definition of “sustainable development” is given[2].   The policy also fails to set out any principles for applying sustainable development in practice to local planning decisions, which often have serious long-term impacts.  

The promise “to secure development that secures the economic, social and environmental conditions in the area” omits to recognise that economic growth, social justice and environmental protection often conflict.  It does not say how each element is to be weighted or conflicts resolved.  As a practical guide to the tough choices Councillors will face, it is useless.  Under this policy, any development will qualify as “sustainable”, in breach of the NPPF’s most important guideline.   

The most gaping hole in Policy S1 is the Green Belt.  As an inter-generational covenant (enshrined in primary legislation) to protect green areas in perpetuity, the Green Belt is a living example of sustainable development in practice.  It is the envy of the world.  Policy S1 should commit to uphold Green Belt boundaries and protections, setting at least one clear boundary to planning decisions.  The plan’s contempt for Green Belt constraints is amply demonstrated in later policies.

The commitment to approve planning applications “wherever possible” and “without delay” reveals this draft plan’s pro-development bias.  Countervailing references to sustainability are so vague that the NPPF presumption in favour of sustainable development becomes a presumption in favour of any development at all.  

This policy also ignores, as if they are inconvenient constraints, most of the 12 Core Planning Principles set out in NPPF paragraph 17[3].   In my view this is a non-policy.”


 

Note 1:  NPPF paragraph 14.

Note 2:  The most widely accepted definition is the 1987 United Nations one from the Brundtland Report: “Development that meets the needs of the present without compromising the ability of future generations to meet their own needs.”

Note 3:  Including: “empowering local people to shape their surroundings… Take account of the different roles and character of different areas…protecting the Green Belts around them… recognizing the intrinsic character and beauty of the countryside and supporting thriving communities within it… Support the transition to a low carbon future… Contribute to conserving and enhancing the natural environment and reducing pollution… Encourage the effective use of land by reusing land that has previously been developed (brownfield land)… Conserve heritage assets… Actively manage patterns of growth to make the fullest use of public transport and cycling and focus significant development on locations which can be made sustainable.”

 


2017 Guildford Local Plan

Guildford’s NEW local Plan has just opened for consultation. PLEASE RESPOND before 24th July 2017.  GGG has published its responses to Local Plan Policies here 


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