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4.0 AUDIT OF THE GPDO AGAINST GOVERNMENT POLICY

4.1 Introduction

In order to provide a starting point and give some shape to a potentially limitless task, this audit is conducted against land-related policy on sustainable development. The rationale is that the UK and Scottish governments' policy aims are today predicated on a commitment to sustainable development. Accordingly, this chapter first summarises the documents charting the evolution of general government policy on sustainable development. It then collates land-related policy aims from sectoral policy documents such as White Papers, and identifies the corresponding national planning policy documents. It then reviews the alignment of the GPDO with policy aims.

We have interpreted the spirit of the client's brief (s3.2) as seeking a 'big picture' audit against the general thrust of policy, rather than a blow-by-blow account of each Class of the GPDO against every paragraph of planning policy statements. Accordingly, the audit is carried out at the highest practicable level, viz. the sectoral policy aims, rather than corresponding policies in the national planning guidance. It is therefore not an audit of the GPDO against national planning guidance.

4.2 General government policy on sustainable development

The governmental pursuit of sustainable development was originally set out in the white paper This Common Inheritance ( HM Government 1990), and has since been re-presented in three successive UK sustainable development strategies ( Sustainable Development, the UK Strategy, H M Government 1994; A Better Quality of Life, H M Government 1999; Securing the Future, H M Government 2005).

The current framework in Scotland is expressed in three documents:

• Meeting the Needs. Priorities, Actions and Targets for Sustainable Development (Scottish Executive 2002);
• A Partnership for a Better Scotland (Scottish Labour Party and Scottish Liberal Democrats 2003);
• and most recently One Future - Different Paths. The UK's Shared Framework for Sustainable Development (H M Government et al 2005), which as its name implies is concerned with setting out what is common to the agendas of the kingdom's constituent nations.

One Future - Different Paths reiterates the sustainable development aims of the 1999 UK strategy:

• social progress which recognises the needs of everyone;
• effective protection of the environment;
• prudent use of natural resources; and
• maintenance of high and stable levels of economic growth and employment.

However, the 2005 version of the UK strategy, Securing the Future, remarks that different agencies have selectively pursued whichever of these aims seemed most relevant to them, and that a restatement of overarching purpose is therefore needed. It accordingly provides one:

The goal of sustainable development is to enable all people throughout the world to satisfy their basic needs and enjoy a better quality of life, without compromising the quality of life of future generations. For the UK Government and the Devolved Administrations, that goal will be pursued in an integrated way through a sustainable, innovative and productive economy that delivers high levels of employment; and a just society that promotes social inclusion, sustainable communities and personal wellbeing. This will be done in ways that protect and enhance the physical and natural environment, and use resources and energy as efficiently as possible.
http://www.sustainable-development.gov.uk/publications/pdf/strategy/Chap%201.pdf

At the Scottish launch of One Future - Different Paths on 7 ^th March 2005 , the First Minister cited sustainable economic growth as a major continuing priority, 'but not economic growth at any cost', referring to the need to live within environmental limits. It is noteworthy that he mentioned four times in his short address the theme of environmental justice, a theme which was stressed again in the subsequent announcement on the Executive's sustainable development website of a separate Scottish strategy.

This separate Scottish strategy, Choosing Our Future: Scotland's Sustainable Development Strategy (Scottish Executive 2005) was published in December 2005. It focuses on six areas:

• Sustainable consumption and production - achieving more with less, reducing environmental impacts, improving business competitiveness and breaking the link between economic growth and environmental damage.
• Climate change and energy - making changes to how we generate and use energy and other activities which release greenhouse gases and drive climate change
• Natural resource protection and environmental enhancement - protecting and enhancing the environment to ensure a decent environment for everyone
• Sustainable communities - creating communities which embody the principles of sustainable development at the local level
• Learning to live differently - developing awareness, understanding and engagement and seeking to help and encourage people and organizations to make more sustainable choices
• Delivery - targets and indicators, accountability and governance
  [ http://www.scotland.gov.uk/Publications/2005/12/1493902/39032]

With regard specifically to spatial planning policy, the Executive's current key statements are Scottish Planning Policy ( SPP) 1 The Planning System (Scottish Executive Development Department 2002) and its white paper Modernising the Planning System (Scottish Executive 2005). These respectively set out its current and future visions for the goals and operation of the spatial planning regime.

SPP1 sets out in s4 the purpose of the planning system as:

• 'to set the land use framework for promoting sustainable economic development;
• to encourage and support regeneration; and
• to maintain and enhance the quality of the natural heritage and built environment.'

Ss6-21 then stake out the Executive's emphases for the planning system's role in contributing to its wider objectives: sustainable development (which focuses on environmentally sustainable development), economic competitiveness, social justice, environmental quality, design, and integrated transport. The strong emphasis on design (echoed in PPS1 in England, ODPM 2005, ss33-39), marks its restoration to full status as a material consideration: 'The architectural design, siting and setting of development in its surroundings are valid concerns of the planning system' ( SPP1, s17). This follows through clear statements to this effect in A Policy on Architecture for Scotland ( SE 2001, p12).

Modernising the Planning System is of course the context for this research, and focuses on the reconciliation of improving efficiency with improving inclusion. Under the headings of 'fit for purpose', 'more efficient', 'more inclusive' and 'sustainable', it sets out an agenda to reinforce the primacy of the plan; to achieve greater public involvement in planning decisions, and move it to earlier in the decision making process; to make the system more efficient, speeding up the preparation of plans and decisions on applications; to create a hierarchy to deal more appropriately with development proposals of differing scales; to increase confidence in the system e.g. by more up-to-date plans and better enforcement; and to apply Strategic Environmental Assessment to plan preparation.

Part of the Modernising the Planning System agenda has now been taken forward in the Planning etc. (Scotland) Bill introduced to the Scottish Parliament in December 2005 (see http://www.scottish.parliament.uk/business/bills/51-planning/index.htm). The Bill proposes to insert a new Part 3D into the Planning Act requiring planning authorities to exercise Development Plan powers 'with the objective of contributing to sustainable development'. It does not however define sustainable development, for which one must therefore revert to the policy statements outlined above.

4.3 Sectoral policy aims

Sectoral policy aims with potential relevance to land use and development are scattered through a plethora of documents such as White Papers, and corresponding planning policies are set out in the national planning series. Table 1 presents a summary of key references in tabular form.

The table was constructed by first scanning sectoral policy documents. The policy aims are listed in the first column, and the sectoral documents in the third column. The corresponding national planning guidance is listed in the fourth column. To save repetition, the third and fourth columns omit references to Modernising the Planning System and SPP1 respectively.

An attempt was made to group the policy aims in the first column into natural clusters, but this proved unsatisfactory because of the multi-directional links between them. Instead, the second column gives a rough indication of the primary alignment of each policy aim with the four sustainable development goals from the 1999 UK strategy and reiterated in One Future - Different Paths (Scottish Executive 2005). These have been chosen for their clarity over the integrated expression of sustainable development in Securing Our Future (H M Government et al 2005) and the longer list of goals in Choosing Our Future (Scottish Executive, 2005) .

As explained in the introduction to this chapter, what follows is not an exhaustive audit of the GPDO against planning policy, but rather an attempt to test its overall alignment with the thrust of high-level government policy directions.

Table 1 Land use-related government policy aims and key references to them

4.4 Alignment of the GPDO with policy aims

This section first reviews alignment under the four generic sustainable development goals, then considers in more detail a number of specific policy sectors which emerge as meriting special mention.

Social progress which recognises the needs of everyone

The GPDO has no obvious distributive effect on the major policy aims of social inclusion and regeneration, except that PDR could exert a progressive effect relative to income, by lowering the cost of minor development of dwellings and business premises. Also, PDR are disapplied in all cases where an Environmental Impact Assessment is required (except where the EIA requirements would be met under another consent procedure). However, the GPDO has a specific effect on human rights, because it defines the balance between the right of an individual to alter their property for the purpose of enjoying it, against a neighbour's right not to lose enjoyment of their property as a result. PDR run counter to the government's intention to increase public involvement in planning decisions because they pre-empt them, avoiding the associated neighbour notification and consultation. In some respects, PDR thereby also run counter to the government's pursuit of environmental justice, insofar as the opportunity to have a say is an element of that.

Effective protection of the environment

Generally speaking, PDR apply only to development of such a scale or nature that it poses little threat which is not covered by the regimes of environmental protection and health and safety. The GPDO builds in a number of safeguards against PD which is hazardous. PDR are automatically withdrawn for most proposals requiring environmental impact assessment ( EIA) ( GPDO Part 2, ss8-10). The GPDO also restricts PDR and/or requires prior notification where there are specific hazards (gas pipe laying and building demolition: Table 2). However, HSE have expressed concerns about general lack of effectiveness of the prior notification procedure for permitted development within a hazardous development consultation zone.

PDR pose a potential threat to the conservation of the built heritage and amenity (including streetscape and thus vital and viable town centres) and to the promotion of good design. This is because they allow without scrutiny development which could lower local amenity, could damage the built or natural heritage, or cumulatively could threaten local distinctiveness. That threat is mitigated by limitations in protected areas and the general power of rescinding rights under Articles 4 or 7. Comments on the alignment with policy on the natural heritage are made below in the subsection Natural Heritage.

Prudent use of natural resources

The government's aim of reducing flood risk is potentially opposed by some PD such as repairs to ways, extensions and hard surfacing, which can produce one-off effects such as impeding access to watercourses for maintenance or interfering with drainage, or cumulatively speed up the runoff of surface water.

Further comments on this goal are made below under specific sectors, especially the subsection Minerals.

Maintaining high and stable levels of economic growth and employment

PDR as a whole aid economic competitiveness and growth by removing the need to apply for planning permission for much minor business development, such as equipment installation and minor factory extensions, although the review of PD in England is sceptical ( Review of PDR, ODPM 2003, para 2.17). It argues that e.g. floorspace limits are set so low for industrial and warehouse PD that the scale of development allowed is too small to contribute much to economic prosperity. Those enterprises which benefit from the widest PDR are farming and forestry, transport undertakings (especially airports - see below), and undertakings for the supply of electricity, gas, water and sewerage. All these relaxations must add up to a considerable lifting of a burden that would otherwise be a drag on the day-to-day operation of the nation's economy.

The contribution of PDR to the pursuit of Best Value might seem to go hand-in-hand with that to economic competitiveness. Best Value seeks not only efficient but also effective i.e. high quality outcomes, and whilst PDR generally permit without scrutiny development which could lower quality in the form of local amenity or identity, prior notification has been introduced nationally for specified Classes of permitted development in order to screen for potential impact on siting, design and appearance, supplemented by local powers under Article 4 to remove specified classes of permitted development.

Table 2 PD Classes in which prior notification is required

The following paragraphs comment on the relationship of the GPDO with specific policy sectors. One or two other sectors are woven through these, notably transport, under both airport development and greenhouse gas emissions.

Farming and forestry

Since these primary industries are massively supported by government through a plethora of instruments, it is of particular interest to review how the GPDO reflects changing policy on them. The postwar settlement excluded most farm and forestry operations from the definition of development and granted PD status to operational buildings, tracks and engineering works. This continues to be the case generally under the GPDO today, even though prior notification of farm and forestry buildings was introduced in the GPDO to allow the planning authority to modify siting, design or external appearance (Table 2). There are no size limits on forestry buildings and the limits in Class 18 permit very large farm buildings indeed. This generosity works in favour of the intensification and mechanisation of forestry and farming, in line with government policy. But this same generosity is also seen by environmentalists as a failure of the GPDO to catch up with change in these industries and with the public response to it (see below under conservation).

An important strand of the change in farm policy is promotion of farm diversification. This is part of a wider policy to promote rural diversification, using the reform of the Common Agricultural Policy to enable the diversion of support to other rural activities. In keeping with this there has been a recent shift of planning policy, away from historical caution towards non-farming development in the countryside, towards a positively welcoming stance ( SPP15 and PAN73). There are as yet no corresponding amendments to the GPDO favouring either farm or wider rural diversification. One way of doing this might be to extend the permitted development privileges enjoyed by farming and forestry to other industries in rural areas.

Farming and forestry and associated drainage operations all being PD under the Order, there is potential for them to aggravate flood risk, either downstream by speeding runoff into the nearest watercourse, or locally by reducing or intercepting drainage. Either way, this runs counter to government's aim to reduce flood risk, a very sensitive topic in recent years. One way of addressing this might be to introduce limitations or other restrictions to the existing relevant permitted development classes. Another would be remove existing PDR.

Natural heritage conservation

The planning regime impacts on natural heritage conservation chiefly through determining the location of development, and particularly through the defence of protected areas designated at international, national or local levels. It can also play an enhancing role through design guidance and briefs and through conditions and planning agreements. The GPDO contributes significantly to the protection of protected areas by restricting or rescinding PDR in them (Table 3). There is an inconsistency in presentation, in that only parts of Classes 67 and 68 explicitly rescind PDR where the development would adversely affect a European site, even though the Habitats Regulations rescind them for all Classes of development (Table 3 footnote). This suggests a need to clarify unambiguously that PDR are so rescinded in such circumstances, and raises the wider issue of the relationship between the GPDO and subsequent related legislation.

The GPDO serves conservation less well outside protected areas, in what is commonly referred to as 'the wider countryside'. The PDR for farm and forestry development described above create a large discrepancy in the wider countryside between what is PD for farming and forestry purposes and what is PD for all other purposes. The Order's only concessions to closing this gap are locational restrictions ( e.g. not within 25m of a road or, in the case of noisome operations, 400m of an occupied building not related to farming), and the requirement for prior notification of farm and forestry buildings (Table 3). Research reveals that there is concern among the environment lobby, Scottish Natural Heritage and planning authorities about the negative effects of PD on the natural heritage. Focuses of concern are farm and forestry buildings and tracks (Classes 18 and 22), land drainage and works to watercourses (Classes 18A and 20), and statutory undertakings (Classes 38-40), which variously affect hydrology, ecology, scenery, access and wildness ( Review of Permitted Development Regulations Affecting Natural Heritage Interests In Scotland, SNH 2002). One way of addressing this issue might be to extend restrictions on PDR within certain designated areas. Another would be to re-visit the universal restrictions and limitations within specific Classes of permitted development.

The impact of Class 20 works to watercourses bears on policy for good ecological status of water bodies, although the Class seems likely to be rendered nugatory by the new Water Environment (Controlled Activities) Regulations 2005. PDR for domestic peat-cutting (Class 21) are seen by some as a threat to peat-based habitats, but the mainstream view is that the chief threat is from commercial peat-cutting, which is not PD.

PDR could potentially affect the operation of Green Belt policy, through the impacts discussed above affecting the ability of Green Belt land to supply a landscape setting and a recreational asset. However, most of the impacts discussed above concern countryside further from major settlements. There could also be indirect impacts in particular instances, for example via the PDR granted to operational airport buildings (Part 14) when the airport lies within Green Belt, as is the case in Edinburgh, or to development associated with mines or waste facilities on Green Belt land. Overall, though, such factors will have little impact on Green Belt amenity relative to factors like the state of farm policy, difficulties of farming in the urban fringe, development hope value, and the state of positive access and amenity programmes like Greenspace Scotland ( Review of Green Belt Policy in Scotland, Scottish Executive Social Research 2004).

Table 3 Restriction of PDR in designated areas

Airport development

Part 14 grants prior permission for operational buildings and other structures at or related to airports. Class 44 in particular allows aircraft hangars, freight handling depots or passenger terminals, although prior consultation of the planning authority is required if the building exceeds 4m in height or 200m ³ in volume, i.e. for all but the smallest ones. This is the largest type of development granted prior permission by the GPDO - some buildings are likely to be larger even than farm or forestry buildings. It differs from the latter in being located on an intensively developed site, of which the main impact is anyway aircraft movement rather than buildings. On the other hand, it also has much larger knock-on effects, since an increase in passenger or freight handling capacity will generate proportional transport increases both in the air and on the ground. In a broader way, airports act as focal points of regional economic growth, and thereby affect transport and settlement patterns and the integration of land use and transport.

Thus in theory airport PDR are the peak of deregulation under the Order, strongly support government policy for economic competitiveness and growth, and are out of line with restrictions over most other business development under the Order. In practice, however, it must be noted that: as with other statutory undertakers there is the opportunity to put in place protocols for prior consultation on PD, the prior consultation limit is in this case set very low, airport development planning takes place in the public eye (viz. the West Edinburgh Planning Framework, SEDD et al 2003), and the EIA regulations will pick up all works over more than 1ha ( Environmental Impact Assessment (Scotland) Regulations 1999, Schedule 2.10(e)).

Energy and greenhouse gas emissions

The GPDO makes no reference to energy consumption, still less to greenhouse gas emissions, and is to that extent out of step with a major theme of contemporary government policy and a specific driver of much planning policy since This Common Inheritance 1990. There are three spheres in which the GPDO might affect emissions, especially of the main greenhouse gas, CO₂: transport, the energy consumption of buildings, and energy generation.

Small developments granted prior permission under the Order, such as parking on business sites, could add to the total of transport movements and therefore of CO₂ emissions. More specifically, airport PDR permit expansion of capacity, which is directly associated with extra aircraft movements and extra ground movements, and could indirectly affect local and regional transport emissions via economic growth, settlement pattern and land use-transport integration (see above under airport development). Air transport is the fastest growing contributor to emissions, and the GPDO can be seen as part of a pattern of relative deregulation of the industry, alongside e.g. the reluctance to tax air fuel at a level comparable with other transport fuels.

The energy efficiency of buildings is regulated under the Building Regulations. PDR under the GPDO allow minor accretions to the nation's building stock which cumulatively may add to CO₂ emissions. The impact in practice will however be determined by whether they are screened under the Building Regulations, and whether approved design is then upheld or undermined by build quality.

Government policy supports a shift in energy profile towards renewable sources, chiefly in the generation of electricity. Generating stations exceeding 50 MW in capacity fall under s36 of the Electricity Act 1989, but smaller ones fall under the planning Acts. Class 40 (electricity undertakings) is the relevant item of the Order. It applies only to statutory undertakers, and only to development on their operational land, i.e. existing sites. It does not apply to development by independent electricity generators. For the most part, such installations will be small-scale renewables technology, such as small wind turbines, biomass and micro-hydro plant. These will usually be intended primarily for the generator's own consumption, but they can be connected to the grid to sell on surplus electricity (Scottish Renewables Forum, 2005, Briefing: Microgeneration and Extending the General Permitted Development Order). Extension of permitted development to small-scale renewable generation would be in line with government energy policy (although environmentalists have voiced concerns about the hydrological and ecological impact of micro-hydro in the Highlands).

Telecommunications

Telecommunications provide the clearest instance of the GPDO being modified to keep up with evolving technology and the public response to it. Classes 67 and 68 have been amended to take on board concerns about visual impacts on both built and natural environments, and about the impact of radiation on health. Since revision in 2001 the limitations are now stricter than those in England and Wales, but are claimed by the Executive to implement its policy 'to enable the telecommunications industry to expand and diversify, but…sensitively' (National Planning Policy Guideline ( NPPG) 19 Radio Telecommunications, para 2). They could be argued to work against the rollout of the Executive's initiative to extend the information superhighway to rural areas and to foster the development of rural enterprises using telecommunications [ http://www.broadbandforscotland.co.uk/news.asp].

Waste management

Government's aim is to move waste management up the waste hierarchy from tipping through reclaiming value in some way, to minimisation. Several Classes of PD, which are not about waste facilities, nevertheless have potential implications for waste management. Class 18(3)(c) prevents the use of farmland for uncontrolled waste tipping, by forbidding the import of waste to a farm other than for work on a building or to create a hard surface. However, this could be interpreted to leave a loophole for the import of waste usable in the formation of tracks and hard standings, in combination with the PDR granted to tracks for farming (Class 18(1)(b)) and for forestry (Class 22(1)(b)), and generally to the repair of private ways (Class 27). In this regard, an early claimed side-effect of the 1996 Landfill Tax was the diversion of inert waste to form unnecessary landscaping of ways, golf courses and so on, in order to avoid paying the tax at a licensed tip. Class 30(b) grants local authorities PDR to put up refuse bins. This is neutral with respect to waste policy, since it could either enable or undermine recycling, depending on the authority's waste collection policy. Class 63 permits the tipping at a mine of waste derived from work on that site, which again is neutral with respect to waste policy.

The absence of PDR specifically for waste management facilities could, from one standpoint, be seen to support the government's policy for orderly and sustainable waste management, in that all such development is subject to scrutiny. The opposite view is that the resulting burden of having to apply for sundry minor works, associated e.g. with the management of existing waste facilities, is an unnecessary cost and a disincentive to modernising waste management. The waste management industry is evolving fast in response to ever tighter standards for landfilling and landraising, and to targets for recycling and diverting biodegradable waste from landfilling or raising. New types of facility are required, especially for recycling, which are less demanding as to location and for which it may be reasonable to consider some PDR. There is also potential for new kinds of developments which cross Class boundaries: for example, is an anaerobic digester for farm waste a farm building (which may be PD under Class 18), a waste facility (which is not), an energy generation plant (potentially PD under Class 40), or all of the above?

Minerals

Mineral winning, like waste management, is a closely regulated activity. The potential for unregulated commercial exploitation on farmland is prevented by Class 18(3)(b), which permits farmers to win minerals for farming purposes only on the same holding, and not to export it; Class 21 does the same for peat. The main Classes for minerals are however 53-66. These enable mine operators to pursue their daily business on site unburdened by having to seek planning permission for exploratory drilling, erecting or moving plant, making ways etc., although prior notification of the planning authority may be required (Table 2). These relaxations pose no threat to the environment, given that these days planning authorities require detailed operating plans, set demanding conditions, and usually seek a planning agreement and a restoration bond, and that the EIA regulations cover all operations exceeding 1000m ² or 0.5ha ( Environmental Impact Assessment (Scotland) Regulations 1999, Schedule 2 s2). Class 58 and parts of other classes are rendered nugatory for the foreseeable future by the closure of the last deep coal mine in Scotland.

Statutory undertakers

One of the peculiarities of the GPDO is that it grants PDR by two criteria: type of development and type of developer, the latter by distinguishing between statutory undertakers and others. The GPDO grants to statutory undertakers more generous PDR than to other developers. This favouritism by type of developer creates inconsistencies with respect to the type of development: for example, Network Rail, as a statutory undertaker, enjoys PDR for telecommunication masts which general telecommunications companies do not. Is the justification that statutory undertakers are quasi-public bodies, whose ultimate bottom line is the public interest, and who can therefore be relied upon to behave themselves; whereas non-undertakers, whose bottom line is the shareholders' profit, cannot?

There are two objections to this reasoning. First, one could argue that telecommunications companies provide an equally necessary service to the public. Second, the privatisation of public services casts doubt on the assumption that statutory undertakers behave in the public interest (even supposing it can be defined). Even where the undertaker remains in public ownership, it is increasingly run along business lines because government requires it to be so, as well illustrated by Scottish Water. The differentiation of PDR between statutory undertakers and others in fact means that the separation of operation from regulation, which privatising public services requires, is incomplete.

The GPDO contrasts in this respect with the EIA regime, which does not distinguish between statutory undertakers and other developers. It is beyond the remit of this study to consider why, but two reasons spring to mind. First, the EIA regime is driven by a European Directive, whereas the GPDO is home-grown. Second, the EIA regime is much more recent in origin, and reflects the shift of public and professional views about the weight to be given to environmental concerns.

Conclusions

Does the GPDO speak the language of contemporary government land use-related policies? The considerations which the GPDO does take into account can be inferred from reasons it gives or implies for limiting PDR: amenity ( e.g. odours), siting, design, external appearance, and specific hazards (Table 2). The GPDO was not conceived to contribute to some of today's policy aims ( ODPM 2003, s2.15; Prior and Raemaekers 2006). It predates the contemporary vision of spatial planning propounded in government planning guidance and RTPI's A New Vision of Planning. Thus, in the absence of a systematic mechanism whereby the GPDO could track policy developments, it will reflect them only through piecemeal amendments, and even those amendments are bound to run behind the policy agenda, which itself will run behind the development of new technologies, such as micro-renewable energy generation.

But even if the GPDO lacks explicit references to elements of the contemporary policy agenda, does this in practice reflect a threat to their implementation? In our view, the analysis above indicates that it broadly does not. By its nature, the GPDO is concerned with relatively trivial developments; and current general and specific limitations on PDR greatly restrict the threat these pose to the achievement of policy aims, even through cumulative development.

Yet this audit does highlight the discrepancy between the relatively generous PDR granted to farming, forestry, and to statutory undertakers on the one hand and those granted to other businesses on the other hand. Farming, forestry, and statutory undertakings are all businesses which government wishes to expand, but so are many others, including telecommunications, and we are not aware of any government policy that the former should be given a structural business advantage. By the same token, we are not aware of any intention in government policy that quasi-public developers should be subject to lighter-touch environmental regulation than are others.

Whilst there is scope to address some of these policy conflicts by amendment to existing permitted development Classes, and introduce new permitted development for microgeneration and minor development ancillary waste management activities, there is a general need to tighten up the prior notification requirements for permitted developments which may, because of their location in relation to airports and hazardous industries, raise issues of health and safety.

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