The Society wish to submit comments in support of those submitted by Civic Voice to the changes proposed to the NPPF. However, prior to presenting these comments, we wish to state that town and country planning is an important means of facilitating and implementing new development, but it is constrained in its powers and subject to more strategic, governmental and political powers and decisions and actions. Additionally planning cannot, of course, control the market because house builders and other landowners control the land. Furthermore, those parties hold the power to release land for building, and the house builders normally control the range and type of housing to be built.

It is not considered, therefore, that planning alone can successfully fulfil the demands being made on it and implicit in the changes now being proposed, which, as demonstrated, are beyond its ambit. In this respect, planning will not be able to provide adequate numbers of affordable and market housing to satisfy the needs currently existing for these and the following reasons, and particularly as a result of previous Government decisions, including:

a. the sale of Council affordable housing stock through the 'Right to Buy' mechanism,
b. the sale of Housing Association affordable housing stock which is understood to be imminent,
c. the failure to replace rented housing stock in adequate numbers,
d. the abandonment of Regional Planning with the ability to address cross boundary housing issues, and replacement with a poorly conceived substitute, the Duty to Cooperate,
e. the down-grading of the Section 106 approach to affordable housing provision,
f. the continual tinkering with the development planning system resulting in delay and adjustment in programmes for adoption of Local Plan documents, and
g. the cut backs in resourcing and staffing in planning departments.

Lichfield Civic Society supports the contents of the response to the changes proposed to national policy as submitted by Civic Voice.

The only minor variation, which arises because of particular local issues, is that the inclusion of encouragement and support for new settlements should be more fully and explicitly referred to in the amended national policy when finalised. It is accepted that any such proposals would need to emerge through the development plan process and have been subject to community involvement. It is considered that such settlements, when properly planned over the medium and long term, would contribute significantly to sustainable development and would relieve pressure for release of Green Belt for large scale housing allocations to meet objectively assessed need for housing.

John Thompson,
Chairman,
Lichfield Civic Society.
8th February, 2016