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Digest of comments received following consultation on Draft Revised NPPG3 of March 2002
GENERAL COMMENTS
AC: Welcome the production of new guidance. Change of title is welcomed. Consideration should be given to an alternative title "Planning for Sustainable Housing" to give a greater profile to this key priority of the Executive. Issues of "guiding development to the right places" should be considered before design issues. In terms of the development process location comes before site design.
ACC: Much of the content is to be welcomed particularly in the drive towards achieving more sustainable solutions which place more emphasis on creating quality residential environments and less on issues of quantity.
AHSS: Previous NPPGs have included a paragraph in the introductory sections clearly stating the main stakeholders. This omission suggests that the document is only applicable to LAs. Broadly welcome the thrust of the draft.
C7: Broadly approve of NPPG3 as it is drafted, and consider it to be a much better document than its English counterpart.
CALA: Support comments made by Homes for Scotland.
CEC: The revisions are broadly welcomed. They provide an opportunity to update, revise and improve the clarity of guidance to the benefit of all parties. The NPPG attempts to give greater weight to qualitative matters over the current emphasis on quantitative provision and to link housing land supply to a long term housing strategy. The direction the new guidance is moving in is supported
CFLA: Hope that the introduction of new measures will not lead to increased delay in the administration of the planning process, particularly in dealing with applications for planning permission. Ultimately, the need to make the assessment of planning proposals more transparent and consistent must be properly balanced against the requirement for speedier decision-making for development control purposes.
CNES: The guidance contained in the draft documents is informative and well laid out with useful cross references recognising that the planning system has role to play in promoting attractive, sustainable forms of development which contribute to social justice objectives. It is felt that it is designed principally to address the issues surrounding mainland areas and omits to address the issues facing areas such as the Western Isles where the pattern of development is significantly different.
CLACK: Requirement of LAs to provide sustainable forms of development through the plan-led system is welcomed. Helpful that the guidance gives the main considerations and elements for the processes involved. It is agreed an inclusive process of consultation and involvement is desirable and required. However, in practice has encountered difficulties in seeking consensus in outcomes and it is likely this pattern may continue, particularly with the development industry, despite the best of intentions and substantive efforts made by authorities to seek agreement on housing and housing land supply issues. The sequence of considerations given and policy fields provided in the new guidance is welcome and agreed.
DCC: Suggests that a more appropriate title given the focus of the document would be Planning for New Housing.
EAC: It should be noted that the draft PAN is similar to, and repetitive of, the Draft NPPG and consideration should possibly be given by the SE to assimilating the two into a single document.
FC: Revision of NPPG is welcomed.
FIFE: Lack of guidance related to infrastructure responsibilities. Clearer guidance should be given on the role of various agencies.
Support is not given for the omission of the importance of addressing local considerations when considering the housing land requirement as found in current NPPG.
FMB: Broadly support the aims.
GCVSPT: The approach is welcomed. The most important element is that relating to the delivery of housing land.
HC: The draft is welcomed in drawing together existing good practice and in supporting the Council's current approach to planning for housing. It is, however, relatively weak in terms of providing guidance on effective delivery.
HCC: Consider that much of the content is acceptable. The introductory summary calls for the system to be consistent with national policies. An important national policy is community involvement in planning. There are several references to community involvement sited in NPPG 1, Getting Involved in Planning and the current SE consultation Renewing Local Democracy: the Next Steps. However, in contrast to these documents, involvement of local communities is so lightly touched upon in drafts NPPG 3, PAN 38 and RIA that we wonder whether the new policy has been given consideration. All three drafts need to be revised to give full force to the policy of local community involvement in planning. Suggest the reconsideration of paragraphs 3,7,11,12,18,19,24,26,27-30 and 32 of NPPG 3. The phrase "in partnership with local communities" might more often be used. Community involvement should come in precise ways and not the vague references found in the drafts. It seems that declared government policy on community involvement is being sidelined and that planning is being left to organisations which will often be outside the communities themselves. Yet it is the local communities which will have to live with the consequences of the decisions.
The three drafts are light on openness and transparency. Suggest the concept of commercial confidentiality might be revised, curtailed or even removed. Community councils should have the right to information about housing, without charge and within a short time span. Community right of appeal (third party right of appeal) should be permitted.
HGBG: Community involvement in planning is an important government policy, which should be built into all aspects of the three draft documents. It features insufficiently in the three and we trust that this oversight will be rectified. Agree with HCC on need for greater openness and transparency.
IC: The issues creating concern for Inverclyde Council have been covered in the response from Glasgow and Clyde Valley Structure Plan Joint Committee.
JA: Unclear why the Local Considerations section, which is accorded justifiable weight in the current NPPG 3, has been removed. This draft NPPG 3 reads like a housing developer driven document. Housing needs to be provided but these local considerations also need to be taken into account.
M&M: Support comments made by Scottish Homes.
MC: It would be helpful if elements or sections that constitute national planning policy could be clearly highlighted. This would also be assisted greatly if the NPPG and PAN were to be strongly edited so that they concentrate solely on national planning policy issues. The inordinate length of NPPGs is an issue that is consistently raised and should be dealt with.
The draft guidance is long on 'encouragement' and short on 'guidance' in areas where particular difficulties are experienced (landscaping, affordable housing and SUDS).
MT: In general terms find much to commend in the draft.
RH: Support comments lodged by Homes for Scotland.
RICS: The revised NPPG will be a useful tool in promoting the development of sensitively located, well designed, sustainable housing and is therefore welcomed. However, irrespective of the guidance itself, the key to its success will be in the actual delivery of housing. Delivery of housing needs to be improved and in this respect, links with the general planning system are extremely important. Administration of the planning system itself is in urgent need of attention. The system needs to be more efficient, with less time being spent at Local Inquiries; planning applications being speeded up; and development plans being kept up to date. Up to date development plans rely heavily on the provision of accurate and up to date data. Such information is vital.
The importance of housing to the economy cannot be underestimated. Good quality, affordable housing is vital to economic prosperity. Provision of housing is dependent on an efficient planning system which reacts quickly to changing needs to ensure that the supply/demand relationship does not come under so much pressure that house prices begin to soar. In this respect, it could be argued that housing also has an important link to social justice.
RTPI: Welcome the general approach and its renaming. We believe that this is a better form of title for NPPGs (ref. our negative comments on the draft NPPG 2 "Economic Development"). The revised NPPG is a considerable improvement on the 1996 version with regard to its expression of policy context and the addressing of three clear themes (quality residential environments, development in the right places and delivering housing land).
Commend the Executive for seeking to address the difficult issues in planning for housing - design, land supply, and affordable housing but we are concerned that it has not fully succeeded in all of these. While the NPPG places a welcome, strong new emphasis on quality residential environments, the addressing of this theme first does not alter the dominance of the 'predict and provide' ("numbers game") approach of the third section. Despite the attempt to increase flexibility in land supply by extending the requirement for an effective forward supply in development plans to seven years, the proposed methodology will do little to reduce the lengthy debates between developers and planning authorities and the incidence of planning by appeal.
The general tone of the NPPG continues to exacerbate the relationship between planning authorities and developers, rather than on promoting planning as a positive means of delivering sustainable development.
The other change that will affect this NPPG, as a result of the review of strategic planning, will be the conversion to Scottish Planning Policies. We would expect that the Executive would have in mind the appropriate format for SPPs in finalising this NPPG. Whether there is movement directly towards an SPP format immediately or not, the NPPG should indicate more clearly where it is stating national policy, as opposed to guidance.
SAC: The draft is welcomed as a useful update, which accounts for significant changes of policy and circumstance since 1996. In particular it provides an essential link between the operation of housing legislation and town and country planning legislation.
SBC: The recognition that planning authorities have an enhanced role to play in providing improved guidance to developers is to be applauded. The SE should also recognise that this enhanced role will have significant resource and training implications for local planning authorities.
SCNS: Support the draft.
SEG: Draft appears to take a wider look at the surrounding issues of housing development and the impact they have. It is imperative that there should be greater emphasis placed on these wider issues.
Lack of integration between housing supply and employment opportunities.
SLC: The title reflects a shift of emphasis from only land issues to a range of planning issues including design, layout, sustainability and requirements of different segments of housing market areas.
SMH: Fully supportive of the measures proposed particularly with regard to the delivery of housing land.
SNH: The revision of NPPG 3 is welcome, and in particular the emphasis it places on securing new housing development in sustainable locations and in encouraging more sustainable forms of development. Strongly support the welcome drive it gives towards higher standards of design and environmental protection alongside the social and economic development objectives more normally associated with housing issues. These considerations are vitally important, if the planning system in Scotland is to facilitate new housing development that uses natural resources wisely and is likely to maximise social, economic and environmental benefits.
Concerned that the format of this NPPG represents a distinct change in style from the existing NPPG series in that it does not contain emboldened policy statements or provide a listing of actions required. In terms of the clarity and precision of national planning policy, we have found the inclusion of these sections in previous NPPGs very helpful, and would ask for them to be reinstated.
SW: NPPG 3 presents proposals that, if implemented, will assist service providers in managing investment to meet legislative requirements and, where possible, accommodate demand.
UNITE: Student, key worker and NHS accommodation currently does not fall within any of the Use Classes of the Town and Country Planning (Use Classes) (Scotland) Order 1997. As a result there is often confusion when planning applications for such a use are received by planning authorities. Recognise that without a change to Scottish planning legislation this cannot be rectified immediately.
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