Wiltshire Council's response to the government's National Planning Policy Framework consultation

Question 62

Do you agree with the changes proposed to paragraphs 86 b) and 87 of the existing NPPF?

Answer: yes.

Please explain your answer:

In principle changes to the NPPF to support these growth industries and their contribution to the economy is supported.

Changes to 86b) require planning policies to identify appropriate sites. However, while land may be available there remains a fundamental obstacle and challenge to demonstrate it can be brought forward alongside other much-needed housing growth because of the lack of capacity on motorway junctions, need for timely infrastructure investment and disproportionate evidence requirements expected from National Highways to demonstrate deliverability of sites. The scale of infrastructure investment required and timing for delivery can have a huge bearing on the ability to identify such proposals within plans.

Given the drive to produce plans quicker, the regional basis on which such sectors operate (especially logistics) and strategic road networks on which the logistics industry relies more needs to be done at a national level to support cross boundary working at regional/cross-regional level, and investment programme to unlock infrastructure.

Question 63

Are there other sectors you think need particular support via these changes? What are they and why?

Answer: yes.

Please explain your answer:

Greater recognition should be given to supporting commercial space near to defence establishments to facilitate the private sector in working with the emerging needs of the defence sector. This is important in the Wiltshire context and could be applicable elsewhere nationally.

Question 64

Would you support the prescription of data centres, gigafactories, and/or laboratories as types of business and commercial development which could be capable (on request) of being directed into the NSIP consenting regime?

Answer: yes.

Please explain your answer:

Agree. Such businesses can be of a significant scale or national importance, with associated significant impacts at a local level, and would be best considered at a national level and context.

Question 65

If the direction power is extended to these developments, should it be limited by scale, and what would be an appropriate scale if so?

Answer: yes.

If yes, what would be an appropriate scale?:

Yes, there should be limits to scale to allow decisions to be made locally in appropriate circumstances.

Question 66

Do you have any other suggestions relating to the proposals in this section?

Answer: yes.

Please explain your answer:

Investment in strategic transport infrastructure is critical to accommodate growth at the local level and at the regional level (for example, strategic road corridors such as the A350 and A303) which should be committed to within the national road investment strategy. The expected scale of growth is not likely to be realised without the substantial private and public funding required to deliver key transport infrastructure. The recent decision to cancel the A303 Stonehenge tunnel scheme means that significant benefits, including providing a safer, more efficient network and substantial economic growth (Gross Value Added (GVA) benefits of almost £ 40billion, Economic Impact Study 2019), will not be realised.

Government and national policy need to do more to support delivery of land for employment development. Local plans rarely have land promoted for such use, with the development industry instead favouring housing. This has the effect of preventing employment growth in towns whilst the population is growing, resulting in increased out-commuting with the associated costs to the environment and local economy. National policy should provide greater expectations regarding mixed uses on strategic sites to support delivery of employment land and safeguarding of such sites to encourage them to come forward for such uses once established through a local plan.

There is a missed opportunity for the NPPF to support the co-location of development that can make use of excess energy such as industry using roof mounted solar electricity from adjacent warehousing and housing using waste heat from data centres.

Government needs to provide resources to enable local planning authorities to specifically address the increasing constraint of electricity grid connections on the path to net zero. A start to this might be to provide guidance and funding for the provision of Local Area Energy Plans to inform 'strategic policies' that involve engagement with 'infrastructure providers' on their 'investment plans'. Furthermore, explicit reference to energy infrastructure as part of cited 'major infrastructure' within national policy is important. To help address energy provision that cuts across the boundary of plan areas or is required to meet needs within a neighbouring authority. Adjacent urban authorities will not meet their energy needs in their plan area - this needs to be managed without overwhelming adjacent rural areas that have their own land use pressures including food production.