Some snippets to keep you going
Here are some bits and pieces we get emailed, just a few, but its good to know we are not alone.
———- Forwarded message ———-
From: Protect Congleton
Date: 18 May 2014 18:41
Subject: Labour Party announces it will NOT scrap NPPF
An announcement has been made by Hilary Benn (Shadow Secretary of State for Communities and Local Government) at the Glenigan Constructing Insight Conference on Thursday 15th May 2014, that the Labour Party will not, after all, be scrapping the NPPF. This is an about-turn. Mr Benn said that Labour would focus on forcing developers to release land for building. He also said that more building should be done on brown-field sites. The Labour Party commissioned Sir Michael Lyons to look at how Labour could deliver 200,000 new homes a year by 2020 and this report is yet to be delivered. See the links below for more on this.
Yesterday, the Governor of the Bank of England called for more homes to be built because of fears of a “building bubble” created by rising prices, see http://www.bbc.co.uk/news/business-27459663
Response to the Parliamentary Enquiry into the Implementation of the National Planning Policy Framework (NPPF)
Please accept the following as our group’s response to our first-hand experience of the NPPF at work in our local area:
We live in the unitary authority of Barnsley Metropolitan Borough Council (BMBC) in South Yorkshire. In recent times we have involved in a planning dispute regarding a proposed development in our local area. Our response is not to raise objections about the planning decision, which did not go in our favour, but to comment on the process by which the NPPF was implemented… or rather, ignored.
Presently, BMBC does not have an approved five year plan or strategy in place which is somewhat undermining the processes by which the NPPF can be implemented. This means that in reality that BMBC cannot fully implement the spirit of the NPPF when considering planning applications; therefore, they are making decisions based on a fear that they would not be able to defend appeals at Whitehall thereby incurring massive expenses that the underfunded local authority can ill afford. This means that they have not been able to follow the NPPF’s own guidance even when projects put forward have been clearly and demonstrably unsustainable (as was the case with our own case).
This means that the balance between the interests of local community and the proposed developer (and BMBC) is in our view compromised. Essentially, the presumption in favour of planning is over-ruling any kind genuine and realistic debate/objection being put forward by local people. The fact that financial incentives are available to unitary authorities also undermines the integrity of the process and compromises the spirit of the NPPF which is designed to allow due process to take place. We would therefore argue that the spirit of the law is being undermined by local authorities dragging their feet in terms of getting a fully developed five year plan in place.
We ask that this committee work to ensure that ALL unitary authorities get a five year plan in place and in so doing ensure that local people are consulted about where ‘demonstrably sustainable’ sites are within the local area and that the presumption in favour of building is not seen as an open cheque to build anywhere at any cost regardless of suitability, sustainability or environmental impact. In our experience, some of the more unscrupulous unitary authorities (that are largely left unchecked) are riding roughshod over the National Planning Policy Framework and in so doing do not take into account the views of residents, MPs or other locally elected representatives. This cannot be right in a democratic society.
It is our group’s assertion that the views of local people should be of paramount importance to the implementation of the NPPF process and that a balanced approach between the interests of developers and local residents should not only be seen to be delivered but should be a tangible reality in practice. This was not our experience nor is it the experience of other groups within our authority who feel that the balance is always in favour of development regardless of contextual factors which clearly make the proposed sites unsustainable. It is our view that there is a need for sustainable sites to be found and for houses to be built on them rather than just filling every available inch of green space that exists in our countryside… we support the view that brown field sites should be targeted first before we lose all our green space and local heritage.
We believe that people have the right to live safely on the sites that are being proposed. This means that the local infrastructure issues must be taken very seriously when considering the suitability of a site so as to guarantee the safety of future residents and safeguard them, especially young people who will be particularly vulnerable, from potential harm. How can a presumption in favour of planning assure the safety of all future residents (especially the most vulnerable ones) if these safeguarding issues are not given proper consideration? Very often it is local residents who are aware of these contextual factors. If their views are not considered properly, because of a presumption in favour of building and an ad hoc implementation of planning policy, then there is a great danger that people’s lives could be seriously affected, even put at risk, by these demonstrably unsustainable developments.
Our group is not opposed to the NPPF and its guidance. We would like to see it implemented properly, fairly and without prejudice. It is our view that the implementation of the NPPF (which is a balanced and potentially ‘fair’ document if implemented in the spirit that was intended) is only possible if local authorities are in a position to implement it without fear of financial penalty. Our group found the NPPF easy to follow and to challenge; however, our objections were rejected by BMBC’s Planning Regulatory Board (PRB) because the authority does not have a five year plan in place so they are basically rubber-stamping all applications for building regardless of any beaches of regulation or process inherent in the NPPF. It was even stated in our case that regardless of the fact that our proposed site did not meet NPPF regulations this did not matter and the PRB approved the site for outline planning permission regardless; this is unacceptable in our eyes.
Thank you for taking the time to read our objections.
Mr John Hutchinson
Spokesperson for BRAND
Shortwood Green Belt Campaign
A Response to the CLG Select Committee’s Inquiry into the workings of the NPPF
1.0 Executive Summary
1.1 Shortwood is a Victorian colliery hamlet set on the edge of Greater Bristol, within Avon’s Green Belt. Shortwood Green Belt Campaign cannot honestly be characterised as “anti-development,” rather it is “pro-sustainable development.”
1.2 Because of Shortwood’s setting, this submission primarily concerns itself with the treatment within the NPPF of the nation’s designated Green Belts. The NPPF is not protecting the inner edges of green belts and the result is “urban sprawl”, far worse than in previous generations and quite simply not sustainable.
1.3 Sustainable Development, a frequent phrase in the NPFF, is now accepted as meaning “development which meets the needs of the present without compromising the ability of future generations to meet their own needs.” This is not how the term is being interpreted by developers, planners & inspectors.
1.4 The NPPF strategy of concreting over green belt areas, open green fields and urban green spaces to meet the current national housing crisis is clearly not sustainable development, and even less so when other more truly sustainable options exist but are routinely ignored by developers, planners and politicians.
1.5 The NPPF assumption that governments can stop “urban sprawl” by protecting Green Belt land at the same time as promoting economic growth by building supposedly sustainable “Urban Extensions” is pure sophistry.
1.6 The five purposes served by Green Belts, though endorsed by NPPF are not being rigorously managed. The point of regulations is that they are enforced.
1.7 “Enabling developments” are pernicious & inappropriate mechanisms for under-pinning financially unviable, unsustainable green belt developments. They are “State Aid” and as such probably illegal under E.U. competition regulations.
1.8 When discussing any planning objections, ministers, MPs, councillors and officers routinely revert to labelling any legitimate objectors as NIMBYs (Not In My Back Yard,) contrary to Article 12 of the UN Declaration of Human Rights.
2.1 The nonsense at the heart of the scandalous treatment of the nation’s Green Belts, (totalling 1.6 million hectare or 13% of England’s total land area,) is the attempt by successive governments and now the NPPF, to hold to two mutually contradictory planning policies, i.e. to stop “urban sprawl” by protecting Green Belt land at the same time as promoting economic growth by building “Urban Extensions” around key economically critical cities which are surrounded by Green Belts. It is the planning equivalent of trying to “have your cake and eat it”. Trying to defend the status quo in the face of this reality is pure sophistry.
2.2 In the National Planning Policy Framework, the Coalition Government asserts that it attaches great importance to protecting the Green Belt:
“9. Protecting Green Belt land
79. The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.”
2.3 However, back in the real world, in terms of the protection our nation’s
green fields, urban green spaces and designated green belts, the 2010 General Election might well not have happened. The previous Labour government planned to concrete over the nation’s Green Belts with massive “Urban Extensions”. Following their abandonment of Labour’s programme of centrally imposed targets embedded within the Regional Spatial Strategies, the incoming Coalition Government simply went ahead and planned for even bigger Urban Extensions anyway, aided & abetted by the unaccountable Planning Inspectorate who are even now imposing ever greater central targets on local authorities via the Core Strategy ratification process.
2.4 The concept of “permanence” is also somewhat elastic in NPPF terms, as the inner edge of green belts are re-designated and released for development within the 20 year span of any Core Strategy. When the Prime Minister and his depart-mental ministers routinely assert that green belts are being protected, what they neglect to tell the public is that this year’s green belt designation is a bit different to last year’s and that a bit of what was in last year’s green belt has now been concreted over. It is’nt a “like for like comparison.” It is a subterfuge.
2.5 But rural communities, a minority with less than 25% of our population, have become inured to their interests being marginalised by the metropolitan elite, who do not wish to bear their share of urban re-development. So much then for “Localism”. Members may judge how well the NPPF green belt protection is working by studying the aerial photo of Shortwood accompanying this submission.
3.0 Some Issues Pertaining to the Shortwood Context
3.1 Villagers in Shortwood can see ways for contextually significant housing developments to take place within the existing settlement boundaries of this linear village, which would not compromise the integrity of this socially diverse community, nor impinge on the green belt. Local planners are unenthusiastic.
3.2 Yet even when a major brown field site falls into the council’s lap, as with the 2,000 acre Filton Airfield site, South Gloucestershire’s myopic planners approve plans for a lowest common denominator, off-the peg, low rise “Brookside” development rather than an economically vibrant “Canary Warf” vision.
3.3 Allowing the sale of urban playing fields & green spaces for housing and then permitting these recreational functions to be transferred to the green belt does not in any way increase community assets, it merely destroys two green spaces rather than one, whilst moving recreational facilities even further away from those urban communities under stress. The case of Cleeve Rugby Club shows the process closing the green gap between Mangotsfield and Shortwood. With the club house and car park adjacent to the road, this stretch of green belt no longer feels like green belt, even though it remains green belt.
3.4 Such permitted developments can isolate small sections of green belt land that immediately come under threat of development, such as the land off Cossham Street in Mangotsfield. Developers can leave such land to go to rack & ruin, build unsightly fences around it and then claim to be fulfilling a civic duty by offering to build over the eyesore that developers themselves have created. In such ways is the green belt gradually nibbled away. Any development at Cossham Street would also irrevocably alter the elevated view of the historic village centre from the nearby earthwork alongside the Avon Ring Road.
3.6 Oddly, along its whole perimeter, the Avon Green Belt butts up against parts of surrounding market towns, distorting development. For example, Thornbury High Street is no longer central to the town, but rather has become its outer edge, since developments are only possible on three sides. Thornbury is now a very strange settlement indeed, resulting in dramatic civic tension that deserves an official inquiry in its own right, once the police enquiries have been completed.
3.7 Settlements some way from the outer edge of the green belt could also be detrimentally affected by changes, since developers are forced to leap across the green belt and focus on distant towns and villages in their pursuit of profit, In Oxfordshire. Oxford City is dominated by its heritage & the countryside is a protected green belt, so Grove & Wantage, 15 miles distant, are threatened with becoming commuter dormitory suburbs, which can’t be described as sustainable.
4.0 Some Wider Issues & Observations
4.1 The effect of the abolition of Regional Spatial Strategies and the introduction of the National Planning Policy Framework.
4.1.a It may seem counter-intuitive, but the abolition of the one and the introduction of the other have resulted in further widespread ravaging of green belt areas. In the South West the unrealistically massive central government targets for house building in the unapproved SW RSS have been abandoned, only to be taken by the Planning Inspectorate as being the baseline for huge percentage increase in house building targets for the Core Strategies of local authorities.
4.1.b On the ground this still represents “Central Government Targets.” Indeed the very same central targets, since the Planning Inspectorate are still working to the same Treasury inspired 2004 Kate Barker Report data, which assumed uninterrupted, unrealistically huge levels of growth since it was compiled before the 2008 economic crash and has not been properly revised since. A reading of Planning Inspector Chryssel’s recent comments on the draft South Gloucester-shire Core Strategy illustrate how these self-same figures are still the bedrock of the Planning Inspectorate’s perceptions of the issues, and Baroness Ford (a Non-Executive Director of Taylor Wimpey who did at least declare her “interest” in her opening remarks), so uncritically rehearsed the figures recently in a Lords debate about Social Housing.
4.1.c The experience of South Gloucestershire’s Core Strategy has unequivocally shown that when a planning authority adopts a robust housing development programme that does not require building on Green Belt land, government or Planning Inspectors will continually up the figures until the green belt has to be concreted over. Inspector Chryssel, having previously threatened South Gloucestershire with the loss of their planning functions (again,) then bulldozed through a near 33% increase in house building targets from 21,500 to 28,355 !
4.1.d I cannot see that the introduction of the “Presumed approval in favour of sustainable development” will make any appreciable difference. It is simply a re-statement of what existed before the NPPF, i.e. that there had to be specific policy reasons for turning down any planning application. I have never heard the second clause quoted by minsters, only ever that of the “presumed approval.”
“12. This National Planning Policy Framework does not change the statutory status of the development plan as the starting point for decision making. Proposed development that accords with an up-to-date Local Plan should be approved and proposed development that conflicts should be refused unless other material considerations indicate otherwise. It is highly desirable that local planning authorities should have an up-to-date plan in place.
4.2 Local councils are not taking their obligations on greenbelt preservation seriously and are placing greenbelt land under threat, contrary to NPPF requirement.
4.2.a The NPPF quite clearly summarises the purpose of the Green Belt, it is quite succinct, there is no scope for confusion or prevarication. The NPPF is simply being ignored in this important respect.
“NPPF 9. 80. The Green Belt serves five purposes:
a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.”
Given the total lack of Local Planning Authority protection, The NPPF needs to be strengthened to ensure that these existing five green belt purposes are actually implemented. There is little point in regulations that are not enforced.
4.2.b No councils in southern England are seriously preserving any piece of green belt land. All green belts are under threat from their own planning authorities. Chris Skidmore MP will remember Nick Boles MP, then newly appointed Under Secretary for Planning at DCLG, asserting in a meeting with campaigning groups at Kingswood Community Centre, (and here I paraphrase):
There has to be massive growth in the south and around Bristol in particular, because the north/south divide is getting wider. No entre-preneur wishes to build businesses in the north. Successive governments of all shades since Harold Wilson’s White Heat of Technology have failed in their attempts to promote significant growth in the North, so the south has to have above average levels of the nation’s growth, necessarily leading to the destruction of green belts in the south.
4.2.c There is also a fundamental misconception within local communities at the heart of the green belt issue. Whatever the intentions of those formulating the original green belt legislation (and I have been unable to find the original wording of the act on any government website) in the mid-1960s local authority planners have succeeded in getting the focus of the legislation shifted to one whereby the Green Belt became a zone wherein the planning authorities could manage the release of land for development, which was something not made clear in the old Planning Policy Guidelines 2:The Green Belt. This has been re-iterated to Save Our Green Spaces (SOGS) in many meetings with various local and national planning officers.
4.2.d Once you have grasped this paradox, everything becomes understandable. The planners’ view is that any piece of green belt land is not actually to be preserved “for as long as can be envisaged” as the old PPG 2 guidelines said, (or “its openness & permanence” as NPPF asserts,) but it is to be reserved and released for development as & when the planning authority thinks it appropriate, replaced by new land on the out edge being brought under the scope of the green belt.
4.2.e This widespread misconception over the purpose of the nation’s Green Belts leads to the “sophistry” at the heart of prime ministerial and government claims to be protecting and increasing the green belt. Statistics show the area green of belt land to be increasing, omitting to mention that year by year it is in fact different land, therefore not a like for like comparison. Government green belt statistics are at best dissembling. Even the government’s own Chief Planning Officer has made the point to Save Our Green Spaces in a face to face meeting that the green belt is merely a tool for managing urban development, not for protecting green spaces from development.
4.2.f The rate at which councils nationwide are building on newly de-registered green belt land along the inner-edge of the green belt, two government departments have been unable to tell me, because once local councils take the land out of the green belt, government departments tell me they no longer take an interest. Hilary Benn MP has now asked similar written questions, receiving the same obfuscation in response. My hope is that the new NPPF focus on “land” will at last put a stop to this, but I won’t hold my breath.
4.2.g Local authority planners seem to have no “vision” for their own authority, sustainable or otherwise, beyond mere numbers and are fixated upon delivering whatever the number of dwellings demanded by speculative developers, rather than defending their right to deliver the housing which is required by the local authority to meet local need and local circumstance. Local planners have become an adjunct of the mass housing developers’ commercial aspirations, rather than public servants planning viable local communities for the future.
4.2.h Planners’ timidity in the face of bullying developers is part of the Green Belt problem and Bristol cannot be alone in that almost every acre of land around the inner edge of the Bristol Green Belt is under the control of one or other developer. As a consequence, however many developers’ planning applications are approved, there is always a greater number of aggrieved developers shouting about local authorities’ planning inadequacies. Yet in recent years in SouthGlos., the developer “build rate” is less than half the “planning approval rate.”
4.2.i The NPPF should impose on planning authorities a duty to negotiate, or where necessary impose, sequential approaches on development, i.e. brownfield land should be used before green field developments.
4.3 What Do Planners Mean by Sustainability?
4.3.a So, we first need to be clear on what we are talking about when we use the term “sustainable.” The term is currently explained on the DEFRA website thus:
“The concept of sustainable development emerged from the post-War environmental movement, which recognised the negative impacts of human growth and development on the environment and communities.
Since publishing the first ever national strategy for sustainable development in 1994, the UK Government has played a lead role in promoting sustainable development at home and overseas.
The term sustainable development came to prominence through the United Nations Brundtland Commission. The commission’s 1987 report, Our Common Future defined sustainable development as “development which meets the needs of the present without compromising the ability of future generations to meet their own needs”.
4.3.b It has also become increasingly evident that, despite often being quoted by NPPF, “sustainability” currently means very different things to different people, it has become a mantra quoted by every developer, meaning anything one wants it to mean. Whilst building thermally efficient homes is rightly accepted as sustainable, not allowing green fields to be developed when brown field sites are left untouched is not seen by government agencies as sustainable. There needs to be an urgent clarification of the government’s perception of “sustainability” in term of planning, since according to DEFRA in 2011:
“The Coalition Government is committed to sustainable development. This means making the necessary decisions now to realise our vision of stimulating economic growth and tackling the deficit, maximising wellbeing and protecting our environment, without negatively impacting on the ability of future generations to do the same. These are difficult times and tough decisions need to be made. This Government believes in going beyond the short term with eyes fixed firmly on a long term horizon shift in relation to our economy, our society and the environment.”
4.3.c A proper sustainable way forward for the NPPF to meet the nation’s current housing crisis, and one which would add protection to the green belt, would be:
- To make developers build those dwellings for which they already have planning permission, but which developers are disinclined to build until the market improves. The Conservative Home website puts this figure at 500,000 plots.
- To utilise the nation’s available & uncontentious “brown field” sites first. CPRE calculate there is sufficient brown field land for 1,500,000 dwellings.
- To bring back to market those 279,000 (of the estimated 720,000) currently empty homes that have been empty for more than six months.
The NPPF does little or nothing to address these issues, restricting itself to the need to increase the number of planning permissions for much needed dwellings that developers have no intention of building in the foreseeable future.
4.3.d Without such innovative approaches to meeting the need for new housing, the pressure exerted by unscrupulous developers to use green belt, green field & green space land will be unstoppable. I feel able to use the term “unscrupulous” because it is those self-same developers who are refusing to build on planning permissions they hold and yet who argue to the Planning Inspectorate as “exceptional circumstances” the fact that so few houses are being built!
4.3.e With such innovative & sustainable approaches a great deal of “heat” would be taken out of this contentious debate, allowing communities & planners to move forward, engage in positive dialogue and begin to resolve the housing crisis.
4.3.f The recent flooding again highlights the folly of developers building on green fields which they know to be at risk of flooding, because they are called Flood Plains. Yet this they continue to do and avoid any responsibility for future flooding. Both developers & mortgage companies should retain shared financial liability for newly built houses they build, or issue a mortgage on, for the entire lifetime of the property. Communities should not have to bear the cost, through council tax and increased insurance premiums, for the greed of speculative developers. This is a simple piece of basic consumer protection. Houses built on flood plains, whatever micro anti-flood measures put in by developers, are by definition not “fit for purpose.” Even in a world of climate stability, they will flood or cause flooding sooner or later.
4.3.g The current NPPF statements about the nation’s Green Belts need to be properly enforced for a change, including the commitment to keep their permanence and openness of the land,
“NPPF 9. 83. Local planning authorities with Green Belts in their area should establish Green Belt boundaries in their Local Plans which set the framework for Green Belt and settlement policy. Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan. At that time, authorities should consider the Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period.”
4.4 Exceptional Circumstances and Enabling Developments
4.4.a Developers’ “exceptional circumstance” arguments should be truly exceptional and pertinent to that particular piece of land, not simply reflecting a general housing shortage, whether local or national, that could be met by building anywhere rather than on green belt land. Otherwise the specialness, openness & permanence of the green belt by NPPF is again cynically over-ridden.
“NPPF 9. 87. As with previous Green Belt policy, inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances.
88. When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.”
4.4.b “Enabling Developments” are also a scam and should not be accepted on green belt land, if anywhere. If any developer cannot afford to develop a particular scheme, then any “enabling development” which would otherwise be deemed inappropriate amounts to state aid/subsidy, illegal under E.U. competition rules.
4.4.c For example, in the original planning application submitted for Bristol City Football Club’s proposed new Ashton Vale Stadium on green belt land, the developer in effect asked for the city’s council tax payers to massively subsidise the stadium, yet ownership would remain vested personally in the club chairman, via his stadium holding company, rather than the football club itself. The developers asked for:
- The right to build 200+ dwellings on green belt land
- Exemption from any Sect. 106 requirement for social housing
- Taking 1/3rd of the Alderman Moore Allotments for yet more houses
- Taking over ownership of the council owned car park at Ashton Gate
- If required, Bristol City Council would itself pay to erect a further 10K temporary World Cup seats to meet FIFA requirements for 40K capacity
4.4.d In a similarly complex stadium deal for Brighton & Hove Albion FC, Labour’s Deputy Prime Minister John Prescott is now apparently quite happy to concede in his memoirs, (the stadium having been built!), that he did not understand objectors’ arguments when finally approving the project!
5.0 Some miscellaneous technical & procedural issues
5.1 It would also help were the NPPF to remind councillors of the need to take planning decisions genuinely in public as required by The Nolan Committee’s Seven Pillars of Public Life, rather than in closed, back room, party group meetings – whose decisions are then simply ratified in public. What is the point, for example, of public statements in open committee of any “declared interest” if the councillor was party to decision making in a closed political “group meeting” in a back room? Currently, from the moment any large scale planning consultation is launched there are dark mutterings of “already a done deal” within the wider community, as with Thornbury’s Park Farm development application.
5.2 There is no current requirement for the planning authority to declare any kind of interest, pecuniary or otherwise, even when they themselves have close links with the developer, or may benefit from government incentives if they approve plans, or indeed when they are approving their own development projects. Yet it was The Local Government Ombudsman who, in a judgement about a previous Bristol Rover’s application for planning consent for a stadium, reported that there had been unminuted meetings with Bristol City councillors without officers being present and unminuted meetings with officers without the presence of councillors, such that there was no record of what had been promised to whom, by whom, nor when!
5.3 However, the basic problem with the structure of the current planning regime remains that it surely contravenes the E.U.’s Human Rights regime for developers can appeal the decisions of the planning authority time & time again until they get approval, whereas those directly blighted by contentious planning approvals have no such right of 3rd Party Appeal to any independent arbiter ( and the Planning Inspectorate are no longer independent since they are now specifying housing figures.) This was South Gloucestershire’s sad experience of the Carson’s Road development, on green belt land between Mangotsfield, Warmley & Siston, which was eventually “signed off” again by Labour’s Deputy Prime Minister John Prescott.
5.4 And finally, not forgetting Article 12 of the United Nations Universal Declaration of Human Rights, for when discussing any planning objections, ministers, MPs, councillors and officers routinely revert to labelling objectors as NIMBYs (Not In My Back Yard). This is contrary to Article 12 of the UN Declaration of Human Rights, viz
“No-one shall be subjected to arbitrary interference with his privacy, family, home or correspondence, nor to attacks upon his honour and reputation. Everyone has the right to the protection of the law against such interference or attacks.”
45.6 I do not expect everyone to necessarily agree with points made by objectors. However I do expect persons of authority to treat any objector’s views, when properly framed and properly submitted, as being genuinely & legitimately held, handle them appropriately and consequently to treat objectors courteously.
(Part of the Save Our Green Spaces network & Community Voice on Planning)