Chapter 12
114) Do you agree policy L1 provides clear guidance on how Local Plans should be prepared to promote the efficient use of land? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
115) If not, what further guidance is needed?
RTPI strongly promotes the objectives of Chapter 12 and recognises the key role the development plan can play in making efficient use of land. As set out in response to Q60(a) whilst we understand the potential benefit of allocating small and medium sites, we have concerns over the feasibility of such an approach. We note that the question refers to Local Plans, but L1 references the development plan. As set out in response to Q20 this is another example where the proposed Framework needs to be clear about what is considered proportionate and relevant to different spatial tiers of the new plan-led system.
At a simple level, making effective use of land will create taller buildings and this will require a significant shift in how the development industry operates, as well as the expectations of communities and, as a culture, our perception of the built form and experience of place. The RTPI richly endorses this approach, but such a significant shift will need to be carefully managed, this includes demonstrating the upmost levels of design innovation and high-quality place-making that compact settlements can support and ushering in a new era of 21st century urban development.
116) Do you agree policy L2 provides clear guidance on how development proposals should be assessed to ensure efficient use of land? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI welcomes the substantial weight attributed to development proposals in previously developed land.
117) Do you agree policy L2 identifies appropriate typologies of development to support intensification? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) If not, what typologies should be added or removed and why?
No further comment.
118) Do you agree the high-level design principles provided in policy L2(d) appropriate for national policy? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly disagree.
a) Please provide your reasons, particularly if you disagree.
The RTPI would recommend that such design should sit within Chapter 14 or be better dealt with in the associated Design and Placemaking PPG.
119) Do you agree policy L2 (d)(i) achieves its intent to enable appropriate development that may differ from the existing street scene, particularly in cases such as corner plot redevelopment and upwards extensions. Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
No further comment.
120) Do you agree with the proposed safeguards in policy L2 that allow development in residential curtilages? 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 provisions set out in L2(1)(d)(iii) may not provide enough flexibility in terms of approaches to intensifying areas. In some areas, the cumulative growth resulting from such policies may provide considerable strain on services and not be considered sustainable, whilst in other areas a more ambitious approach to intensification may be deemed necessary. It may be that the setting of minimum requirements similarly to density may be considered a more appropriate approach.
121) Do you agree policy L3 provides clear guidance on achieving appropriate densities for residential and mixed-use schemes? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) If not, please explain how guidance could be clearer?
In regard to L3(3), a better understanding of what is considered a reasonable walking distance to a railway station would support this application. The RTPI is also aware of a different approach to understanding net developable area in this policy as to what is included in the draft Design and Placemaking PPG, which also differs from RICS’ Professional Standards.
122) Do you agree with the minimum density requirements set out within policy L3? 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 acknowledges the logic behind creating a minimum density as we strive to create a more compact and sustainable approach to urban form. However, regarding the 40 dwellings per hectare around train stations, this may be far below what would be considered the appropriate level of density to achieve the quantum level of development to receive strategic infrastructure investment. Whilst raising the expectations of density in certain parts of the country, this may lack the appropriate level of ambition to be transformative in terms of placemaking and infrastructure provision. Furthermore, it is unclear whether the additional 10 dwelling per hectare for sites next to well-connected train stations is ambitious enough. Please also see our response to Q40(a) for further consideration on development in the vicinity of well-connected train stations, in particular the need to ensure that development plans being prepared have regard to such matters.
We acknowledge that there is a difficult balancing act when setting national minimum density. Particularly in rural areas where such product and house type may struggle with marketability issues and sharp departures from local characteristic. If a transformative approach to developing around sustainable locations is to be achieved, considerably less weight will need to be placed on local characteristics with such development proposals coming through. To deliver the transformative change and quantum of development the Government wishes to see in sustainable locations, the RTPI would recommend that substantial weight be applied to DP3(1)(a) in these regards. This sets out that context should not preclude innovation and change when appropriate, especially when an increased scale or density of development is justified. Whilst scale and density of development may have to depart from local characteristics in order to achieve more compact forms of development, there would still be opportunities to respond to the history, characters and features of a site through the use of materials, architectural features and the restoration, reuse and integration of heritage assets.
In the event that a minimum is set, the RTPI would welcome the review of such an approach at a suitable point in time as a part of wider monitoring of the Framework. We note the specific issue in some parts of the country as to whether guided busways be included as a part of footnote 44.
b) Could these minimum density requirements lead to adverse impacts on Gypsies and Travellers and other groups with protected characteristics? Please provide your reasons, including any evidence
No comment.
123) Do you agree that using dwellings per hectare is an appropriate metric for setting minimum density requirements? Additionally, is our definition of ‘net developable area’ within the NPPF suitable for this policy? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
We recognise that dwellings per hectare is a well understood metric for such matters, as long as suitable provisions are in place to support other types of housing provisions, such as supported housing for older persons and PBSA.
124) Do you agree with the proposed definition of a ‘well-connected’ station used to help set higher minimum density standards in targeted growth locations? In particular, are the parameters we’re using for the number of Travel to Work Areas and service frequency appropriate for defining a ‘well-connected’ station? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons and preferred alternatives.
Please see answer to Q40(a).
125) Are there other types of location (such as urban core, or other types of public transport node) where minimum density standards should be set nationally? Yes/No
No.
a) If so, how should these locations be defined in a clear and unambiguous way and what should these density standards be?
No further comment.
126) Should we define a specific range of residential densities for land around stations classified as ‘well-connected’?
The RTPI would prefer the setting a minimum but not that of a ceiling, as some locations in well-connected urban conurbations may require substantially higher levels of density, making a specified range less helpful.
127) If so, what should that range be, and which locations should it apply to?
No further comment.
128) Do you agree policy L4 provides clear high-level guidance on good design for residential extensions? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly disagree.
129) Please provide your reasons, particularly if you disagree.
Whilst we appreciate that high level guidance on good designed residential extensions need proposing in the Framework, we do not believe it is currently inserted in the correct place and would advocate for such information to be included in Chapter 14. With high level principles set out in Chater 14, the appropriate amount of additional detail to inform decision-making would then be included in the Design and Placemaking PPG, or concise non-technical local design codes.
We have some concern with the policy as drafted. For example, the use of the word ‘blend’ does not reflect situations when a modern extension to a property is felt to be the more appropriate choice and a better design outcome. We note that L4(1)(b) may be duplicating elements of building control, therefore conflicting with policy PM13(1)(b).
The RTPI also recognises that as currently drafted, the policy does not recognise the impact of extensions on immediate neighbours, with such provisions currently held within provisions in P3(1). To support application of this policy, such elements of P3(1) should be included within this policy. Furthermore, the RTPI is aware that a number of local authorities restrict the ability of homeowners to extent property in order to control the size of housing stock in their areas, as set out in response to Q64(a), it is unclear from the Framework whether local authorities will be able to prescribe housing stock size.
