Notes of SDAONB NPPF Consulation Meeting 2 MAY 2018 – Click here.
Dear Dr Wollaston,
by way of introduction
I have for the last 3 years been a member of the Salcombe Neighbourhood Development Plan Steering Group.
We are now at reg 14 stage having completed our community consultation on our draft plan which I am happy to report has been well received and enjoys healthy majority support.
As you will know our Parish is entirely within an AONB and 96% of our respondents asked for the plan to include AONB policies and guidance, it is well appreciated by our community that the AONB designation underpins our very important local tourism industry, which of course is a major employer.
We have responded to the Governments Consultation on the proposed changes to the NPPF both as a group and individually.
Overwhelmingly there is disquiet that the new proposals diminish the protection afforded to AONB’s.
In today’s pressurised environment for development we consider this to be the wrong direction of travel, if change is needed it would be to strengthen the protections afforded.
The NAAONB’s is making it’s representations as is our local AONB partnership and I am content to be guided by them as to any necessary changes.
Suffice it to say that the current position is superior to that which is proposed.
There is sufficient provision in the current legislation to allow for housing and commercial development against strict local need criteria. This is essential as AONB’s are seen by developers as very lucrative opportunities and unfortunately financially induced Local Authorities do not help.
We seek your support in either maintaining the status quo or ensuring that the advice submitted by AONB’s and their NA is followed to achieve improved protection.
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On 9 May 2018, at 21:23, South Hams Society <firstname.lastname@example.org wrote:
The objectives of the South Hams Society are to stimulate interest and care for the beauty, history and character of the South Hams, to encourage high standards of planning and architecture that respect the character of the South Hams, to secure the protection and improvement of the landscape, features of historic interest and public amenity and to promote the conservation of the South Hams as a living, working environment. It sees itself as pursuing these objectives not only for its own membership but also for the very many people who visit the area to enjoy its attractions.
In recent years the Society has been very much exercised by inappropriate development in the South Devon AONB, where large national developers aggressively seek permission to build houses. It is claimed that the development will provide much-needed housing for local people but the resulting dwellings are all too often advertised in the national press, priced high for the reason that they are in or close to a fashionable resort and/or in the AONB. The planning framework needs to focus more sharply on providing good quality small-scale housing for people on low incomes, while protecting the environment from developers catering for wealthy people with no local work or connection.
Chapter 5, Para 60
It is requested that this very broad-brush paragraph be deleted. If it is retained, it will be used by lawyers to force through development which other parts of the NPPF seek to restrict. The need for genuinely affordable housing is surely undisputed and doesn’t need to be asserted in this way.
Chapter 15, Para 170
Paragraphs 115 and 116 of the 2012 NPPF have, together with its footnote 9, been the subject of many appeals and legal challenges. Their meaning is now quite well agreed, and it seems perverse to re-open the debate for no very apparent reason. We believe the wording should remain unchanged. If this is not possible, the words ‘which have the highest status of protection in relation to landscape and natural beauty’, in relation to AONBs, should be reinserted.
Such is the battle to get major developments approved that design seems often to be forgotten, with disastrous results, particularly in the case of housing estates in an AONB. Notwithstanding the provisions of the third test for major development, a fourth should be added: ‘design, in relation to the objective for which the area is designated.’
Conservation of wildlife and cultural heritage are important criteria in the assessment of AONBs, so it is essential that they be stated to be important considerations in decision-making in AONBs as well as in National Parks and The Broads.
It is assumed that the definition of major development is intended to apply to the use of the phrase in paragraph 170. We believe that for this purpose it would be better to judge each case on its merits and circumstances. In whatever planning context the phrase ‘major development’ is being used, there needs to be a means of controlling incremental development, where several applications are submitted, each just below the threshold for major development but together forming what is in reality a single development above the threshold.