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

Delivering community needs (questions 67 to 71)

Question 67

Do you agree with the changes proposed to paragraph 100 of the existing NPPF?

Answer: no

Please explain your answer:

It is not clear what this adds to policy, emphasis is already placed on proactively and positively planning for such uses within current policy. While the importance of delivering public service infrastructure such as further education colleges, hospitals and criminal justice consideration is understood this should not be at the cost of other planning considerations, such as highways, environmental or heritage matters.

Question 68

Do you agree with the changes proposed to paragraph 99 of the existing NPPF?

Answer: yes

Please explain your answer:

Agree, the changes clarify the full range of education provision for children from early years to post 16 (to 18) education important for local communities.

Question 69

Do you agree with the changes proposed to paragraphs 114 and 115 of the existing NPPF?

Answer: no

Please explain your answer:

It is unclear what 'a vision led approach' means in principle without reading the consultation document and what 'all tested scenarios' means. Publication of guidance will be important to support implementation of this policy. Notwithstanding this, the following comments are made on each change:

Paragraph 114:

suggest linking to the national policies including 'Net Zero Strategy: Build Back Greener' and 'Decarbonising Transport'.
clarity is required to state what the 'vision' is and what the policy source is (at the national level), which can then filter through to local policies. The approach should reflect local plan and local transport plan policies to promote sustainable transport modes.
further detail and guidance will be key to understanding the expectations of development proposals including how the approach, and deliverability of mitigation measures, will be demonstrated and secured
it is acknowledged that a vision led approach could help support National Bus Strategy objectives at both the national and local level, in theory better enabling local authorities to make buses more frequent, more reliable, and bringing people to jobs, study and local services. However, funding constraints to delivery of such infrastructure will remain a challenge particularly in rural areas.

Paragraph 115:

the addition of 'in all tested scenarios' will make it more difficult for authorities to demonstrate that a development proposal will have a severe impact on the road network. This could result in the authority not having the ability to ensure that the road network can operate in an efficient and safe manner
this could also undermine an authority's position to secure improvements to the transport network and other mitigation measures to ameliorate the impact of development
the wording of the policy should be strengthened to state that for a scenario to be deemed acceptable, the required associated infrastructure and other mitigation measures must be deliverable, quantifiable and within the control of the developer

Question 70

How could national planning policy better support local authorities in (a) promoting healthy communities and (b) tackling childhood obesity?

Please explain your answer:

Delivery of healthier communities is centred on good design and locating development in areas that have or can be designed to support use of sustainable transport links/active travel. Creating places where people are happy to be outside their homes and spend time in the wider environment requires a move away from volume house builders replicating designs/maximising numbers of homes to designing places for people with attractive public realm and open spaces.

(a) National planning policy could better support local authorities in promoting healthy communities by introducing health impact assessments for certain types of developments into design requirements.

It is recognised that the planning process has major benefits to improving the health of the nation. Momentum continues to grow across England, with the Office of Health Inequalities and Disparities (OHID), NHS and academics calling out for better integration of health and well-being into planning policy, as it supports the creation of 'healthy environments' which in turn facilitates healthy lifestyles and behaviours.

The Health Impact Assessment (HIA) process is seen as a tool to identify the health impacts of a plan or planning application and to develop recommendations to maximise the positive impacts and minimise the negative impacts, while maintaining a focus on addressing health inequalities. By bringing such health considerations to the fore, HIAs can add value to the planning process. However, the use of HIA does need to be proportionate to the scale of development and defining the trigger parameters will need further consideration should its inclusion be considered.

(b) It is difficult in practice to refuse hot food takeaways near schools through the planning system, as it is difficult to demonstrate the health impact of such a use. If the desired outcome is to restrict such uses close to schools, then introducing policy at national level would ensure consistency in its application and not leave local authorities open to challenge.

However, this is perhaps an overly simple solution to a more complex problem. The measures outlined in response to (a) would form part of a wider set of measures (including those outside of the planning system) that could be more effective