Planning is in crisis: central government simply doesn't understand what planning is about, it has arbitrarily blamed the planning system for the shortage of housing, and local authorities are in the firing line. "One thing we all agree on," one developer representative said to me in the wings during a tea-break, "is that the National Planning Policy Framework isn't working. But councils haven't helped themselves, because they've tried to defend what they had before NPPF, but without providing proper evidence."
I fear that the High Peak Local Plan is a case in point: the outgoing (2005) Plan was well-argued, but in trying to adapt it to NPPF since 2012 I suspect the Borough Council has been thrown into turmoil. The best way I can demonstrate this is with a sketch of some of the questions I've put to them across the table at the Public Examination, along with their replies. I've used some poetic licence in the sketch, but some parts are verbatim.
Q: When you have policies for housing numbers that are precisely quantified, and many other policies that merely 'encourage' or 'seek to enhance' certain things, such as green spaces and energy efficient buildings, how can you assess whether progress is being made, or if progress on one policy is being made at the expense of another?
A: Well, it's difficult. Some policies are more quantifiable than others.
Q: Considering that you're promoting an upgraded Trans-Pennine road on the A628 route which will generate new traffic to fill up the new capacity, is generating additional traffic a strategic objective of the Plan?
Q: The proposed new housing in High Peak will generate 40-50,000 more car trips every day by 2031 – how have you established whether these road traffic impacts will become intolerable for the communities where those car trips will take place?
A: We haven't.
Q: The Viability Assessment deals with the remediation costs associated with developing brownfield sites, but shouldn't this follow through to an implementation plan that says, "This site is important for regeneration, these are the obstacles to viability, so this is how we're going to make this site viable"?
Q: Affordable housing need represents a huge proportion of your total housing need, but central government is not currently providing the means to deliver affordable housing, so your policy to provide affordable housing is not implementable. What are you going to do about it?
From Andrew Wood, Planning Officer, on site at the High Peak Local Plan Examination.