The IHBC has submitted its response to the consultation on England’s ‘National Planning Policy Framework: proposed reforms and other changes to the planning system.
Roy Lewis, IHBC Policy Secretary said: ‘The consultation draft of the NPPF is significantly different to recent iterations. Some of the changes, such as distinct policies for plan-making and decision-making, the replacement of the ‘tilted balance’ with more nuanced policies, and the re-introduction of the purposes of the planning system are welcome,’ said.
‘However, we are extremely concerned about some of the proposed changes in terminology. The deletion of ‘great weight’ from conservation policy and its replacement with ‘substantial weight’ together with the introduction of ‘substantial weight’ for a raft of public benefits would seem to nullify the ‘special regard’ required by statutory duties in relation to listed buildings and conservation areas. Whilst the abandonment of the unhelpful term ‘less than substantial harm’ is welcome, the unnecessary difficulty of distinguishing ‘substantial harm’ from ‘harm’ remains.’
‘Finally, we are disappointed that the policies remain predicated on avoiding harm and on controlling development in high growth areas and do not put greater emphasis on the enhancement of historic places or the encouragement of appropriate development where local economies are stagnant.’
‘Responding to the consultation IHBC also makes the observation on the several policies to increase housing density (densification) that ‘Local character and distinctiveness is very important and densification can be at odds with the traditional character and distinctive grain of historic areas. The reuse of existing buildings can help increase density but other forms of development can damage historic character and loose urban green space. Increased density can overwhelm infrastructure, education and social services. High-quality design and expert advice is necessary with schemes to increase density to ensure new developments are compatible with the historic environment.’
‘The IHBC points out that many of the policies in the NPPF require investment in local authority resources if they are to be successfully achieved. It is important to ensure there are enough Local Authority staff with appropriate training and skills both to deal with the heritage proposals as well as with the other decision making and plan making requirements.’
The Consultations Panel
The IHBC constantly monitors Government Departments and other national and regional organisations for relevant proposed changes to legislation, policy and guidance. The Consultations Panel formulates responses to these documents on behalf of the IHBC.
See the IHBC Response HERE
For current relevant consultations that the IHBC is aware of and for past consultation responses.
NB: The IHBC may not necessarily comment on all these consultations, but we are glad to hear opinions on them from both members and non-members.
