BSCF's comments on proposed changes to the National Planning Policy Framework

Mark Prisk Esq MP
House of Commons
20 April 2016


am writing to you on behalf of the Bishop's Stortford Civic Federation about proposed changes to the National Planning Policy Framework (NPPF).

I would be very grateful if you could raise our concerns in writing, as soon as possible, with Greg Clark, Secretary of State for Communities and Local Government.

Across England there is already plenty of land with planning permission: enough for at least 650,000 new houses with much more in the pipeline. New proposals, such as the ‘Housing Delivery Test’, could force local authorities to release even more greenfield sites for development unnecessarily. Instead, we should make developers build out land for which they already have planning permission.

As you will know, Bishop's Stortford has provided some 40% of all the new dwellings built in East Herts over the last 20 years. Planning permission was granted over a year ago for development at Bishop's Stortford North, a greenfield site which will provide over 2500 more new homes, but on which work has not yet started, and we can see no good reason for granting planning permission for housing on other greenfield sites in the area while this huge permission remains unexercised. While East Herts cannot display a five year supply of land for housing, that calculation relies on house building rates which are designed to keep house prices up, and nearly all of the land supply which does exist is in Bishop's Stortford. Land supply here is well in excess of locally generated need and if lack of supply is a problem, it is one for the rest of the district.

We want to see a policy that both prioritises the re-use of suitable brownfield sites in urban areas, and restricts development on competing greenfield sites. Neither the NPPF as it stands, nor the changes proposed, are strong enough to make this happen. In that context you will also know that a planning application has recently been lodged to build nearly 700 dwellings on the former Bishop's Stortford station goods yard.

We are particularly concerned that, nationally, over 225,000 houses are being proposed on Green Belt land, despite Government commitments to protect it. This is nearly a three-fold increase from when the NPPF was introduced in 2012. We should abandon proposals to relax Green Belt policy and instead make clearer that unnecessary or major losses of Green Belt should be avoided.

Here too we have a particular concern in Bishop's Stortford about the proposal in the draft District Plan for the development of up to 1000 dwellings on the so called Bishop's Stortford South site which is within the Green Belt. Development of part of this site has already been refused planning permission once on appeal because of its valuable Green Belt attributes. The Government’s planning guidance has confirmed that meeting an objectively assessed housing target is not an exceptional circumstance that would justify removing Green Belt protection, and so there is no planning case for removing this site from the Green Belt. Yet we know that developers have drawn up plans to build there although they have another planning permission already available for them to use on the opposite side of town.

We believe that Green Belt protection needs to be strengthened and that housing targets should be based on a realistic assessment of what developers and local authorities are likely to be able to deliver, rather than aspirational building rates that have never been achieved even in the most buoyant economic times with massive public investment.

Please let me know Greg Clark’s response.

Yours faithfully