This Society was established in the 1950s and has a special interest in the built environment and heritage. We are consultees on planning applications relating to Listed buildings and our town's three conservation areas, with representation on Birmingham's Heritage Advisory Panel, and we take a broader interest in good urban design. However, our members also care deeply about the natural environment and issues such as protection of our local Green Belt. The following comments reflect these wider interests.

General comments

·       We hope this consultation will genuinely allow the views of the public to be heard. Whatever the merits of the proposals in the NPPF, we regret that some opinions expressed by ministers during the consultation period have been aggressive and antagonistic in response to very sincere and deeply felt concerns.

·       The term "sustainable development" is the leitmotiv of the Framework. The government's stated position is that "Sustainable means ensuring that better lives for ourselves don't mean worse lives for future generations" and that "What we do today to meet our needs, must not stop future generations being able to meet their own needs". This is a very responsible attitude and we have to consider what these needs will be. Like ourselves, future generations will have emotional and intellectual as well as material needs and that is why we have a duty to protect and enhance our splendid countryside and heritage as far as possible. The NPPF has very positive things to say about designated heritage but we fear that there are too many loopholes which would allow intrusive development in the countryside.

·       We do not agree that the default answer to planning applications should be "Yes" and that "Local planning authorities should … approve all individual proposals wherever possible". This weights the planning system unfairly and undemocratically in favour of developers who may have no sympathetic knowledge of the locality, with inadequate safeguards against poor design and poor location. We support the RTPI's content that "good planning has always been about enabling the right development in the right place and the right time and, equally importantly, preventing inadequate, poorly located and untimely schemes".

·       We dislike the evident bias in the NPPF against the Planning system as it has been operating till now (akin to the regrettable allegation, heard recently, that Planners are in some way the enemies of development andenterprise). Of course there have been some delays and unfortunate decisions but the great majority of applications over the past decade have been approved (at a rate of about 90% for major commercial developments) according to the DGLG's figures. Planners interpret and apply national policy - they should not be blamed for alleged deficiencies in such policies.

·       Whilst we are relieved that the previous government's attempts to impose very high housing targets under the RSS have been dropped, we would like to see the use of brownfield sites restored as a priority over greenfield. However, we are very glad that gardens are specifically excluded from the brownfield designation.

·       Overall we welcome the aim to simplify the Planning system and make it more coherent for the general public but we are very concerned that an element of over-simplification in the terms of the NPPF will lead to more debate and uncertainty. Phrases such as "Where practical and consistent with other objectives" leave too much open to question. Throughout the NPPF there are many instances of matters which could be decided on subjective judgements and, with the presumption in favour of development, the judgements may well be those of developers rather than local opinion.

Town centres

We welcome the emphasis on promoting "the vitality and viability of town centres", though we also note the concerns expressed recently by the owners of John Lewis/Waitrose that out-of-town developments might jeopardise this.

In Sutton Coldfield we have a Supplementary Planning Document covering our town centre which was produced after a very full and well conducted public consultation and we see this as a good means of engaging the public and producing a "wish list" rather than a rigid prescription. We note the comment in the NPPF that "SPDs must not be used to add to the financial burdens on development" (our italics) and we find the phrasing rather odd. Why would any local authority deliberately set out to add to the financial burden on development, especially in the current economic climate when for instance town centre development is greatly to be desired?

Neighbourhood development rights (Item 65)

"Developments that are permitted through a neighbourhood development order will not require further planning permission from local planning authorities". We very much support involving local people in planning but we hope that local development rights will only be permitted if they are supported by a substantial number of local residents and are subject to very rigorous scrutiny. As yet we are uncertain about the mechanisms and procedures involved and the funding of the process. Where will accountability lie if something goes amiss with a neighbourhood development order? This is not to decry the involvement of the local community in planning but to ask for greater clarity as to the ways in which this will be achieved.

Planning Obligations (Item 67)

"Planning obligations should only be used where it is not possible to address unacceptable impacts through a planning condition". Does this perhaps need to be re-phrased? As it stands, it suggests that "unacceptable impacts" could be overlooked in return for a quid pro quo.

Sustainable transport modes (Items 88 and 89)

What is meant here by "sustainable transport modes"? Item 89 mentions giving priority to pedestrian and cycle movements (not greatly useful for the "large-scale movement of goods or people") and "high quality public transport facilities". We very much agree with the concept of mixed use development where facilities such as schools, libraries and sports are integrated - but should not the concept of sustainable development discourage out-of-town housebuilding if most of the residents have to travel to their employment?

Communications structures (Item 96)

We welcome the intention to restrict the spread and duplication of unnecessary communications structures.

Peat and Minerals extraction

We are glad to see the ban on new or extended peat extraction and also the emphasis on restoring and regenerating other land which has been worked for extraction as soon as possible.

Housing regeneration (Item 112)

We welcome the emphasis on regeneration and renewal of poor housing stock but we would also hope to see a push for outstanding housebuilding permissions to be actioned and for properties which have stood vacant for more than (for instance) a year to be brought back into occupation. We understand that collectively such measures could increase the housing stock by thousands. This should be a priority before giving a default "Yes" to building on greenfield sites.

Good design (Items 116 - 123)

We warmly support the criteria for good design discussed in these passages (and we are glad that a new role has been found for CABE). We would have liked to see in Item 123 a special mention of good design for adverts, signage and street furniture in conservation areas.

Open spaces (Item 129)

Existing open spaces should not be built on unless "the need for and benefits of the development clearly outweigh the loss". Again this begs the question - Who decides? With the presumption in favour of development this could be a weighted argument.

Local Green Spaces

This seems an excellent idea but a little more precise definition could be helpful. If a group of residents want to protect some open land on the outskirts of their village, would this be classed as "a centre of population" - and how big is "an extensive tract of land"? Is the concept in fact intended for urban areas only?

Green Belt land

We applaud the stated intention to protect Green Belt land as far as possible and for local authorities to plan for their beneficial use. As members of The Friends of Sutton's Green Belt Association we feel that Green Belts should be available to walkers and others who want to enjoy the countryside responsibly. We appreciate that increased public use of the Green Belt may lead to more leisure-related facilities being built and we hope these will continue to be controlled as regards design and suitability. Item 145 states without further explanation that "engineering works" will be permitted in Green Belts - what does this mean? With regard to tranquil and quiet places, these are at a premium in our small country and already there are few places in England which are out of earshot of traffic noise. Planning applications for commercial/industrial development should be carefully assessed for noise impact, the more so because this obviously cannot be demonstrated on a plan.

Renewable energy sites (Items 146 and 153)

This states that many renewable energy projects would be inappropriate but can be permitted if they contribute to wider environmental benefits of renewable energy. How is the inherent contradiction here to be resolved? Who decides which environmental concern takes priority? Item 153 states that applicants for renewable energy projects will not be required to state the need for renewable energy as such - but shouldn't they be required to show that their particular project will generate sufficient energy to make a substantial contribution which justifies intrusion into the landscape? Is the principle that "every little helps" really adequate here?

The natural environment

Item 165: "Plans should allocate land with the least environmental value where practical, having regard to … the presumption in favour of sustainable development". This again raises the question of what is "sustainable". Allowing development on a precious and irreplaceable area of land would not be sustainable. Item 166 very reasonably supports a hierarchy of sites designated for the protection of wildlife or landscape - but what is the implication for local sites (local nature reserves) that are not mentioned here? Item 167 gives the alarming impression that high-grade agricultural land may be "developed" - when for very good reasons (reducing transport emissions, encouraging local production and even considerations of national security) we need our farmland to remain as such. According to the NPPF, major developments could be permitted in National Parks, the Broads and AONBs if it can be demonstrated (by whom?) that they are in the public interest. We would like to see completely clear statutory protection for these areas. Item 168 has good things to say about minimizing impacts on biodiversity and geodiversity but again we have the rider that permission should be refused "unless the need for, and benefits of, the development in that location clearly outweighs the loss". Who decides? - on what criteria? The NPPF states that "planning permission should not be given for development resulting in loss or damage to irreplaceable habitats, including ancient woodland". We very much hope this will be the case and yet there are suggestions that the line of HS2 would destroy some areas of ancient woodland.

Heritage Assets (Items 178 - 191)

We broadly welcome these statements, which show a clear understanding that heritage contributes greatly to our sense of place, pleasure in our surroundings and interest in our daily lives (beside having the potential for economic benefits through tourism and attracting inward investment). We also welcome: "Councils should have up to date evidence about the historic environment in their areas, and use it to weigh up the significance of heritage assets and how they contribute to the local area". Sadly this will remain wishful thinking in the wake of the current massive cuts in public services. In Birmingham, the country's Second City, our Conservation Planning team has been reduced from eight officers to just two. Several conservation areas in the city lack up-to-date character appraisals and management plans. This includes two of our three CAs in Sutton Coldfield; we are still waiting for the plans for the third CA (promised over two years ago) to see the light of day. Central government will have to decide how to reconcile their laudable intentions for the historic environment with the reality of the situation in local government offices. Also, we are sorry to hear that the Local Listing of buildings is to be discontinued. This seems against the spirit of Localism.