NPPF Changes Consultation 2015

Supporting New Settlements, Development on Brownfield Land and Small Sites and Delivery of Housing Agreed in Local Plans

Question 6.

Do you consider that national planning policy should provide greater policy support for new settlements in meeting development needs? If not, why not?

  • One of the major problems with existing policy is that the Objectively Assessed Need for housing is based on existing levels of housing in an area. This means that authorities which already have a high level of housing are expected to build larger numbers of extra homes even if they are surrounded by Green Belt and their infrastructure is already beyond maximum levels of capacity. 
  • The NPPF and NPPG allow local authorities to take such constraints into account but residents are told by local authorities that the Planning Inspectorate will not accept that. The NPPF needs to be modified to make it absolutely clear that such areas can safely choose not to build beyond their capacity. 
  • Because of the existing concentration of population in the congested south of England, more support should be given to decentralisation of the population and employment opportunities for that population. We support the Government’s devolution agenda.
  • It is important that sustainable locations are selected which should take into account biodiversity, flooding, landscape and specifically Green Belt designations as important constraints, as well as access to public transport and highway connections.

Question 7.

Do you consider that it would be beneficial to strengthen policy on the development of brownfield land for housing? If not, why not and are there any unintended impacts that we should take into account?

  • Strengthen brownfield policy as proposed, making brownfield sites in towns and cities the priority for new houses and allowing local councils to refuse proposals on competing green field sites.
  • Care must be taken that brownfield sites in the Green Belt are not used where it would harm openness. Sites in the green belt that have been used for renewable energy projects or sports grounds including golf courses for example must always be returned to their original state when the use is discontinued. Allowed developments in the green belt must not become stepping stones to housing development. This should be made explicit in the NPPF
  • In principle we strongly support the use of urban brown field land for development subject to environmental considerations and sustainable locations.
  • We have concerns about the development of small sites in rural locations, particularly in the Green Belt, if they harm the character and openness of the countryside and are in unsustainable locations.
  • Brownfield land is currently being recycled. It is not a static area and so it is unhelpful to require 90% of brownfield land suitable for housing to have planning permission by 2022 (paragraph 21).

Question 8.

Do you consider that it would be beneficial to strengthen policy on development of small sites for housing? If not, why not? How could the change impact on the calculation of local planning authorities’ 5 year land supply?

  • We are against a specific positive local policy in rural areas. Rural communities should have the ability to decide whether small sites on the edge of settlements are developed for starter homes or other types of affordable housing, depending on the needs of the area. Speculative development proposals (that is, those not included within a local or neighbourhood plan) that would lead to significant growth of a village should be resisted.
  • We object to proposals for development immediately adjacent to settlement boundaries providing they are ‘sustainable’, (Paragraph 24), assuming this means beyond the existing settlement.  We are aware that sustainability is increasingly meaning ‘viable’. A ring of small developments around existing settlements could harm the character of the settlement as well as the surrounding countryside. We object particularly strongly where the land has environmental designations such as AONB or is in the Green Belt. 
  • Generally we consider that the contribution of ‘windfalls’ to the housing stock has been underestimated. We would like to see a more realistic figure used in the 5 year land supply calculations based on recent windfall trends.

Question 9.

Do you agree with the Government proposals to define a small site as a site of less than 10 units? If not, what other definition do you consider is appropriate and why?

  • Our experience in Guildford is that with defining a small site to be one of less than 10 units is that developers will divide up large areas of land and/or apply to build small numbers of executive homes on large areas of green field sites. A small site should be defined by the area to be developed rather than the number of units and care should be taken to avoid any possibility of advantage from dividing up sites.
  • In our opinion a small site should be less than 10 units in urban areas; less than 5 dwellings would be a more acceptable limit outside existing settlements, particularly in the Green Belt.
  • We support a requirement that local authorities provide clear policies by which to assess small site developments. However, we are strongly against a predisposition to granting planning permission on the edge of settlements.
  • However, should this be confirmed as policy, councils must have the powers to refuse applications where there are good reasons to prevent the development. 

Question 10.

Do you consider that national planning policy should set out that local planning authorities should put in place a specific positive local policy for assessing applications for development on small sites not allocated in the Local Plan?

  • No, such developments should follow the rules of the local plan and not be made into exceptions. Otherwise developers will be able to develop against the plan by simply picking off areas in many small parcels instead of one large parcel.
  • We support a positive bias if the site is in an urban area and there are the criteria with which a development has to comply. However, there should always be, even where there is a positive bias, the ability to refuse an application.
  • We are against a specific positive local policy in rural areas.


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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