The Dacorum Local Development Plan and the "NPPF" - the Government's National Planning Policy Framework

Dacorum Borough Councillor, Liz Uttley, has been looking at the Dacorum Local Development Plan. She writes,

"To be "sound" (and get accepted), a Local Plan like the one being consulted by Dacorum must follow the rules set out in something called the National Planning Policy Framework (NPPF). What's that?

One of the ways the Government tells local councils to do what they're told is by issuing National Policy Frameworks of various types. This is "advice" that the councils must take into account when setting their own policies. They have little scope to vary very much and cannot set any poliy which cuts across the "advice" they were given. In this case we are looking at Planning Policy.

In this posting we are looking at the second 'Topic Paper' document in the NPPF, entitled 'Site Selection'.

This document begins by pointing out some of the rules that our Local Plan is supposed to follow, and then discusses the site selection process.

We'll get our heads round the NPPF and come back to Site Selection in the next post!

So, the rules in the NPPF; we've picked out some beauties:

SUSTAINABLE LOCATIONS

'significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes'

In Plain English…this means "you have to build near existing transport links, or where not using the car is a credible option" (which doesn't mean that people will definitely choose to do so.)

THINK BIG

'Recognition that larger numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions of existing villages and towns, provided they are well located and designed and supported by the necessary infrastructure and facilities.'

In Plain English…this means "you have to think BIG in towns/villages, unless you can find somewhere - that doesn't use greenbelt - to start from scratch."

You may agree with us that this Draft Local Plan currently does rather too much of the first one, and cannot take advantage of the second…

Or how about:

'strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:

1. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or
2. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.'

In Plain English…this means "you have to use the Government figures unless you have rare AREAS or ASSETS (that means the Chiltern AONB) - OR - (convenient "judgement" clause) you are willing to risk a LOT to make an overall case.

' policies should avoid homes being built at low densities and ensure that developments make optimal use of the potential of each site. With this, policies should include the use of minimum density standards for town centres and other locations that are well served by public transport.'

' Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified,'

' policies should consider identifying suitable areas for renewable and low carbon energy sources, and identify opportunities for development to draw its energy supply from decentralised, renewable or low carbon energy supply systems')

From page 20 the description of how sites were chosen begins, with

page 35 offering some insight into why certain sites were rejected (eg Land Adjacent to the Red Lion Public House, Hemel Hempstead).

page 42 discussing key points raised by residents in the Issues and Options consultation 2017 (eg Concerns over the extent to which infrastructure assessments have fed into the Plan. Of particular importance is the need for schools and healthcare facilities.)

Page 49 is the beginning of a useful Q&A Regarding site selection (eg Why are there no residential allocations proposed outside of the six main settlements of Hemel Hempstead, Berkhamsted, Tring, Kings Langley, Bovingdon and Markyate?)

Do you think that the Emerging Local Plan follows these rules? In thinking about responding to the consultation have a think about whether you think these questions have been satisfactorily answered.

Don't rush in to responding to this consultation yet, now is the time for gentle perusal and discussion! We have until February to respond so there's no major rush yet!"