5) Do you agree with the proposed approach to simplifying the terminology in the Framework where weight is intended to be applied? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree

Neither agree nor disagree.

a) Please provide your reasons, particularly if you disagree

The RTPI supports the ambitions of providing a simplified terminology in the Framework when applying weight in decision making. However, without a clear and comprehensive approach alongside a carefully managed transition, we are concerned that the application of new terminology could lead to a significant amount of uncertainty, delay and potential legal challenge. Such an approach may benefit from exploring the standardisation of the language used for weighting, and whether this would be appropriately addressed in corresponding guidance.

We note the use of the word ‘substantial’ in the Framework as part of a move towards a simplified approach, however use of other terminology such as ‘significant adverse impact/conflict’ or ‘considerable importance’ continues to add complexity to decision-making. Regardless of terminology, conflicts between policies are to be expected and two or more policies promoting substantial weight will likely occur. Ultimately, application of planning judgement to the circumstances of an individual situation remains essential to all decision making, informed by principles of proportionality and reasonableness. It is also unclear whether tailored local plan policies, justified in their departure from the NPPF in the new local plan system, would be able to apply substantial weight.