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Consultation Response to Fracking as Permitted Development

Response from the South Downs Society (Friends of the South Downs).

The ‘Friends of the South Downs‘ is the membership charity, working to campaign, protect and conserve the landscape of the National Park.

These are the views of the District Officers – who respond to planning consultations and Local Planning Issues on behalf of the Society.


We do not consider that the scope of drilling exploration fits within the definition of permitted development.  It has landscape impact and restoration consequences; archaeological implications; aquifer implications; earth tremor implications for historic structures; and traffic implications on rural roads that may need Grampian conditions to alleviate.  This is well beyond the scope of permitted development even if the permission is time limited.

Permitted development is not used for temporary planning permissions but for minor works to which ‘a reasonable person’ would not take exception.

Requiring Planning Permission is not onerous in itself but it does have in place checklists to ensure that development proceeds in an orderly and neighbourly manner.

The Background Statement makes the assumption that Fracking to extract gas is a non controversial benefit whereas in terms of the government’s intent to become carbon neutral, it is a retrograde step, quite apart from its potential landscape impacts.  The opening statement is disingenuous and should be balanced with the cons as well as stating the government’s current pros.

If Fracking is ‘safe and sustainable’ then the industry needs to declare just what is being pumped underground.  As we understand , it is not “water” as stated on national television last week by a Fracking Industry spokesman for Cuadrilla.

It is not understood how such a large operation, considered to be part of a Nationally Significant Infrastructure Project could possibly be also regarded as permitted development. 

Permitted development is for non controversial matters and that is not the case with exploration for gas to be extracted by Fracking.

Paragraph 10 would be more honoured in the breach than the observance if fracking exploration ignored and overruled the democratic concerns of local communities as has happened in Lancashire.

Question 1

  1. a) Do you agree with this definition to limit a permitted development right to non- hydraulic fracturing shale gas exploration? Yes/ No
  2. b) If No, what definition would be appropriate?

No permitted development right should be granted.  The drilling compound is a large structure and would not be clearly defined and bounded resulting in an unsightly impact in an open landscape and harm in a woodland one.  The drilling rig is a high structure and could be an intrusive and ugly feature in an otherwise undeveloped rural area.  There are noise implications for the activity and traffic implications often on narrow country lanes. There would be no control over the restoration of the site.  There would be no search required for archaeological impacts, no search for impact on SSSIs or protected landscapes.  A temporary planning permission that sets out restoration measures and a financial bond to make sure it occurs should be required.  This would also define the boundaries of the site and hours of operation and traffic routes if necessary or Grampian works to provide access where essential to protect the public.

Question 2

Should non-hydraulic fracturing shale gas exploration development be granted planning permission through a permitted development right? Yes/ No

Surely this should be question 1?

It is new, unproven technology and highly controversial in the public’s eye.  Riding roughshod over public concerns as in Lancashire has sent out entirely the wrong message.  Secrecy about the liquid, called a “toxic cocktail” by objectors and ‘water under pressure by the operator’ has not allayed public fears regarding the long term pollution of our water supply.  Britain has a complex fractured geology, not vast uniform beds as found in the USA.  We are a crumple zone.  The precautionary principle should be followed and each application properly scrutinized under full planning regulations, including a financial deposit to ensure restoration if a temporary site proves to be un-useful or a company fails.

Question 3

  1. a) Do you agree that a permitted development right for non-hydraulic fracturing shale gas exploration development would not apply to the following? Yes/No

This is worded in a misleading manner in that we hold that  Permitted Development  should not regarded as appropriate under any circumstances.

However if the Government goes ahead then clearly the exclusions should apply to specially protected landscapes and their settings.  Any adverse noise or visual impact or traffic impact is also unacceptable.  The deposit of sufficient finance for site restoration and any water supply pollution should also be required.

It is not clear why if fracking is regarded as a ‘safe’ activity by the current government, that it considers that safety hazard areas, military explosive areas and land safeguarded for aviation or defence purposes should be on the list of land where fracking exploration is to be avoided.  An explanation of the reason for the inclusion of these areas would be welcomed.

To this list should be added areas of dark skies or tranquility – usually tracts of undeveloped countryside defined in adopted Plans where flaring floodlit working and noise of drilling or heavy traffic would be in appropriate..

Question 4

What conditions and restrictions would be appropriate for a permitted development right for non-hydraulic shale gas exploration development?

The list takes permitted development into planning permission territory where it is required to ensure there is compliance with all of the listed organisations within a reasonable time frame.  Despite the government’s support for “localism” and the involvement of local communities in planning their future development, this controversial activity goes against localism in that it actively precludes the need to consult locally as with planning applications.  I.e. that they should be advertised and comments received from the affected community.  It would be appropriate to add to the list that all exploratory drilling operations should be advertised and comments sought from the affected communities.

Question 5

Do you have comments on the potential considerations that a developer should apply to the local planning authority for a determination, before beginning the development?

Prior approval – in theory this is used for urgent national infrastructure e.g. telephone masts or agricultural buildings.  The problem with prior approval arises where there is a time limit set.  The cuts to front line planning staff caused by the shortage of funds at present to employ sufficient staff, mean that planning case officers can have impossible work loads.  Prior approval will only work if there is no 60 or 90 day deadline.  Getting responses form overworked understaffed government departments within the deadline is also problematic.  Given the need for legal agreements to ensure restoration or any Grampian conditions in practice it is unlikely to be satisfactory without extra resources given to both local and central government for front line staff.

It would not be acceptable for activity to start on any site within a Local Authority’s jurisdiction without warning. This could heighten any local concerns and ride roughshod over local democracy.  Local knowledge and acceptance is an essential part of information gathering for any planning process.  This is why localism was introduced in Neighbourhood Plan Making. 

Question 6

Should a permitted development right for non-hydraulic fracturing shale gas exploration development only apply for 2 years, or be made permanent?

No, it should not be permanent as  Permitted Development.  Exploratory drilling is noisy and intrusive.  It is not a minor non controversial activity but one that excites much public concern.

Making Permitted Development sites a permanent permission is unsuitable for operations of this scale.  It does not apply to other ‘greener’ power generation like wind power generation sites or off shore wind farms.  If  Permitted Development is just for exploration, then the results should be available in less than two years and 18 months should be sufficient. 

Question 7

Do you have any views on the potential impact of the matters raised in this consultation on people with protected characteristics as defined in section 149 of the Equalities Act 2010?

This consultation uses jargon and there does not appear to be a plain English version available.  That will restrict it being accessible to many groups with learning or reading difficulties or restricted English.  It is available on line thereby excluding a quarter to a third of all households from being aware of the consultation at all.  The closing of local libraries also cuts access on line for those without such facilities at home. I could not see an audio version for those with no or poor eyesight. 

It does appear that by proposing that planning permission is not required for a controversial activity; and by making fracking exploration a Permitted Development activity; to be a deliberate intent to exclude local democratic institutions from any involvement in an activity which has clearly caused public alarm.  The ‘public sector’ would be actively excluded from involvement in exploratory drilling considerations if the proposals in this document go ahead.

It is our considered opinion that full planning applications should be submitted for such a controversial activity.

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A27 Dual carriageway between Lewes and Polegate

Maria Caulfield MP, Chairman of the A27 Reference Group, has announced that a business case to dual the A27 is ready to go before Government Ministers.

The Friends of the South Downs have expressed their concerns about the proposal to put a motorway-style road in between Lewes and Polegate near Eastbourne as it will destroy the beautiful countryside and be visible from the South Downs and the South Downs National Park.

It will be a scar across the countryside whether you’re standing on Mount Caburn near Lewes or whether you are on Firle Beacon on the South Downs.

Spending an estimated £450 million, at more than £50M/mile is a huge amount of tax payers’ money to allow people to drive a bit faster over the 9 or 10 mile stretch of road. This stretch of road is often slow, due mainly to the single lane traffic. READ MORE…

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Chichester local plan

Chichester’s Local Plan was adopted in 2015. The independent planning inspector, however, required the district council to complete a review within five years to make sure sufficient housing would be planned to meet the needs of the area. This work will form the Chichester Local Plan Review 2034 and covers that part of the district outside the national park. The Society keeps an eye on plans being drawn up for areas just outside the national park to ensure that the park is adequately protected.

Our response to the recent public consultation appears below:

 

Chichester Local Plan Review 2034 Issues and Options Consultation

These are the comments of the South Downs Society, the national park society for the South Downs National Park. The Society has nearly 2,000 members and its focus is the conservation and enhancement of the special qualities of the national park and their quiet enjoyment. Our comments on this consultation are restricted to those questions of greatest relevance to us.

Qu 1: Cross boundary issues/duty to co-operate

The setting of the national park is a key element of its quality. The District Council, through the local plan and other decision making processes, has a statutory duty under Section 62 of the 1995 Environment Act to have regard to the designation of the park. The local plan must demonstrate how this duty is to be discharged.

Qu 9: Spatial principles

The Society’s three highest priorities from those listed:

  1. Locate development to minimise its impact on protected or locally important landscapes, heritage and biodiversity
  2. Focus development in locations where there is greatest potential to maximise sustainable travel (public transport, walking and cycling)
  3. Focus development in locations where there is greatest accessibility to employment, local services and facilities

 

Qu 12: Suitable locations for strategic development

Sites within Chichester City and south as far as the A27 should be considered to accommodate strategic residential development that will be well served by rail and bus services and close to the city’s amenities. City centre development is suggested in order to minimise the need for travel, and to encourage the use of sustainable modes of transport as an alternative to the private car.

 

 

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“A place to fly in peace”?

Concerned walkers have approached the Society on finding that their quiet walks through the Balsdean valley near Woodingdean have been disturbed by drones flying. The Society took up their complaints with the national park authority which has taken enforcement action. Despite this the activity has continued. The Society has written to the Sussex Express as follows:

It is for good reason that the Balsdean valley between Kingston, Woodingdean and Saltdean has been referred to as the “hidden” or “secret” valley. Those who follow the public footpaths to this special place discover a surprisingly tranquil haven, a rarity so close to centres of population in this precious part of the national park.

Until recently, that is. 
Visit www.hidden-valley.org — “a place to fly in peace” (we’re talking drones here) — and you will find that not everybody has the same ideas about tranquillity. The activities taking place do not have planning permission and those involved have been instructed by the national park authority to cease. The park planners would appreciate any first hand information from walkers, horse riders. cyclists and others who may have experienced the drones in order to take matters forward.

 

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National park society gives cautious welcome to new park plan

The text of the Society’s submitted comments on the “South Downs Local Plan: Preferred Options” is already on our website, but for information, here is the text of our press release issued today:

 

The South Downs Society, the Friends group for the national park, has submitted a 5,000 word set of comments on the draft plan for the national park drawn up by the South Downs National Park Authority in a consultation which ran until the end of October.

The Society has participated regularly during the preparation of the plan and has not found too many major surprises amongst the 59 draft policies and sites proposed for development.

Said Robert Cheesman, chairman of the Society, “We welcome the way the plan places its emphasis on the national park purposes of conservation and enjoyment taking precedence over development – while recognising the need for appropriate levels of new “affordable” housing on brownfield sites, suitably located and designed.  We have added our own commentary and suggestions for new and amended policies which would help to protect the park’s special qualities.”

The Society has challenged some of the housing target figures in the plan and has repeated its strong objections to the use of farmland at Old Malling Farm on the outskirts of Lewes for a new housing estate.

The plan will, once it has gone through its various stages of consultation and examination, become a key document in conserving and enhancing the landscape and townscapes of the park and guiding development. It is anticipated that the plan will be formally adopted around June 2017.

 

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National park society gives cautious welcome to new park plan

The South Downs Society has submitted its comments on the draft plan for the national park drawn up by the South Downs National Park Authority in a consultation running from 2 September to 28 October.

The Society has been fully engaged in the preparation of the plan and has not found too many major surprises amongst the 59 draft policies and sites proposed for development. We have welcomed the structure of the plan with its emphasis on the national park purposes of conservation and enjoyment taking precedence over development – while recognising the need for appropriate levels of new “affordable” housing, suitably located and designed.  We have where necessary added our own detailed commentary and suggestions for new or amended policies aimed at achieving the purposes for which the park was designated.

The plan will, once it has gone through its various stages of consultation and examination, become a key document in conserving and enhancing the special qualities of the park and guiding development. It is anticipated that it will be adopted around June 2017. Click Here for the text of the Society’s full response.

 

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Hands off Old Malling Farm!

Hands off Old Malling Farm!

“80 new houses in Lewes at Southdowns Road behind Tesco and 400 more at North Street – we have no problem with either of those in principle, both on brownfield sites, provided the mix of uses is right and the design and layout are good enough for Lewes and the national park,” says Robert Cheesman, chairman of Friends of Lewes, “but turning good quality farmland into 200 more homes is simply unacceptable.”

The Friends of Lewes and the South Downs Society – the “Friends” group for the national park — have joined forces to fight a proposal to build 200 new houses on a greenfield site in the heart of the Ouse Valley between Landport and Malling.

This is a site already considered for development, and rejected, by the South Downs National Park Authority but its future is back in the melting pot following a public examination of the draft local plan for Lewes (covering land both in the national park and outside) last January. The planning inspector concluded that the plan would yield insufficient new dwellings to meet local need and suggested that land at Old Malling Farm could be developed to make up some of the shortfall.

Steve Ankers, Policy Officer for the South Downs Society, says, “We are in total agreement with the Friends of Lewes on this. The national park was designated to ensure the protection of its special qualities and there’s nowhere in the park more special than Lewes and its setting. Both societies want to see affordable housing available in and around Lewes on brownfield sites but development at Old Malling Farm would be a very worrying precedent for building on other greenfield sites on the edge of town or anywhere else in the national park.”

A further round of consultation on possible changes to the plan is taking place until 2 October, with a likely reopening of the public inquiry in December to consider comments on this site. The Friends of Lewes and the South Downs Society have submitted a joint response strongly objecting to the proposal to develop Old Malling Farm and highlighting the impact on landscape quality, views across and into the site, tranquillity and dark night skies, archaeology and the vital green finger of land reaching into the heart of the town.

Details of the proposals are available on Lewes District Council website:

http://www.lewes.gov.uk/planning/22277.asp

And the joint submission from the Friends of Lewes and the South Downs Society is available on their own websites:

 http://friends-of-lewes.org.uk/2015/09/27/fol-and-south-downs-society-joint-response-to-sdnpa-and-ldcs-joint-core-strategy-proposal-for-old-malling-farm-development/

https://friendsofthesouthdowns.org.ukwp-content/uploads/2015/09/Modification-MM05-Spatial-Policy-4-%E2%80%93-Old-Malling-Farm-Lewes.pdf

 

 

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Equestrian development

Horse riding is a welcome recreational activity in the South Downs National Park, allowing many to enjoy the park’s special qualities. But one person’s enjoyment can be another’s “bad neighbour” and the Society receives many approaches from members of the public concerned about existing or proposed equestrian development. To guide the Society’s response to such developments, we have drawn up our own set of guidelines:

 

OUR POSITION

The South Downs National Park provides an ideal location for recreational horse riding.

The South Downs Way was the first long distance bridleway to be established by the former Countryside Commission, and activities such as racing, eventing, showjumping, dressage, driving, endurance riding and polo, including for the disabled, may prove acceptable in planning terms as well as enjoyable activities.

Looking after horses supports local businesses such as saddlers, carriage makers, farriers, vets, equine dentists, retailers of horse and rider equipment, and tourism.  Farmers may let their land to horse owners for grazing, so supplementing their agricultural income, and owners of stables provide livery for other owners of horses and ponies.

While the keeping, training and riding of horses gives pleasure and income to many, there is no doubt that some associated activity – such as the construction and operation of indoor and outdoor facilities, traffic, lighting – can cause problems for neighbours and have adverse environmental impact.  Each planning application, or unauthorised activity, needs to be considered on its merits. The proposed activity should be seen to contribute to the conservation and enhancement of the landscape of the South Downs National Park and its quiet enjoyment – that is, the statutory purposes of national park designation.

 

HOW WILL WE HELP TO MAKE THIS HAPPEN?

With the aim that provision for equestrian activity in the national park is properly planned and managed we will:

  1. Seek to influence the local plan for the national park, the local plans for adjoining areas and neighbourhood plans with a view to ensuring that provision is made for horse riding in the park, subject to adequate and appropriate safeguards to protect its special qualities.
  2. Respond to planning applications for equestrian development, recognising the contribution that may be made to quiet enjoyment of the national park and to the economic and social wellbeing of the park communities, while seeking to protect the park’s special qualities and their quiet enjoyment by residents, visitors and other recreational users.
  3. Query possible unauthorised development and support appropriate enforcement.

 

 

In carrying out 1 to 3 above the following considerations may apply:

 

  • Buildings and equipment

 

Stables are best established as a block, near the dwelling, to improve security and keep the “footprint” compact.  The materials used should be in keeping with local buildings. If a metal roof is proposed, attention should be paid to reducing its “shine” in the sun. Floodlights, security and roof lights may contribute to light pollution, reducing “dark skies” and tranquillity.

 

Stable effluent may be disposed of through a cesspit or septic tank which will need regular emptying and this may put strain on the rural highway network.

Field boundaries: division by electric tape fences into “pony paddocks” may help the owner to control equine diet but it can be unsightly, and if this sub-division can be avoided it may help to promote lower grazing densities and so maintain the biodiversity of the grassland.

 

Screening of buildings and equipment with native hedging and trees may reduce the impact on the landscape.

 

  • Bridleways

 

Horses can be legally ridden on bridleways and byways so proximity to them may be an advantage for an equestrian development, especially if there is direct access other than along roads. Horses cannot be ridden on footpaths, unless with the landowner’s permission.  If there is high equine population density in the area the pressure may be  high on some routes, contributing to erosion and possibly extensive degradation. If a part of the bridleway network is already subject to high usage from existing equestrian establishments, it may be appropriate to resist further developments of this type in the area.

 

  • Highways and traffic

 

Equestrian facilities generate vehicular activity – both cars (owners, staff, riders, parents) and large vehicles such as feed and bedding supply lorries — which may lead to difficulties on the local road network. Single track roads require passing places for lorries to reduce the need for reversing; vehicles may access and damage highway verges and vegetation when passing.

 

If manure is not being composted and spread on site, its removal by skip may take place, with potential impact on the local route network.

 

Livery yards may offer lorry and trailer parking as well as car parking to the horse owners. A large area of hardstanding may prove an eyesore.

 

 

  • Amenity value and conservation

 

Riding tuition may impact on local tranquillity and the quiet enjoyment of the national park by others. Noise, traffic and the visual impact of equestrian development may affect users of local rights of way.

Change from agricultural to equestrian use may damage biodiversity or landscape character.

 

Archaeological and historical features may be compromised.

 

 

NB

The draft “Preferred Options” Local Plan for the national park currently (August 2015) contains the draft policy below. This will be subject to public consultation as one element of the draft Local Plan during September and October 2015:

“Development Management Policy: SD50 Equestrian Uses

  1. Development proposals for equestrian development will be permitted provided that they comply with other relevant policies and they: a) have a scale and/or an intensity of equestrian use which would be compatible with the landscape and its special qualities; b) demonstrate good design which responds to local character and distinctiveness including location and siting, any subdivision of field(s) and earthworks; c) have a location which satisfactorily relates to existing infrastructure, where necessary, which includes vehicular and field accesses, tracks and bridleways; d) re-use existing buildings wherever practicable and viable; e) locate new buildings, stables, yard areas and facilities adjacent to existing buildings provided they respect the amenities of surrounding properties and uses; f) provide new or supplementary planting, hard landscape features and boundary treatments consistent with local character, where appropriate; and g) are compatible with other users of the countryside.
  2. Development proposals for equestrian development that would have an unacceptable adverse impact on the special qualities of the National Park will be refused.”

 

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Save Our Green Fields

The Society and Friends of Lewes have jointly issued the following press release under the above title on 12 August 2015:

Two local environmental campaigning groups, Friends of Lewes and the South Downs Society, are joining forces to fight a proposal to build 200 new homes on a greenfield site in the heart of the Ouse Valley between Landport and Malling.

The independent planning inspector, who conducted a public inquiry in January into the latest stage of the local plan covering the whole of Lewes district including that part in the National Park, concluded that the plan would yield insufficient new dwellings to meet local need. He suggested that land at Old Malling Farm in Lewes could be developed to provide more houses. But this is a site already considered – and previously rejected – by the South Downs National Park Authority.

Said Chairman of the Friends of Lewes, Robert Cheesman, “This must be resisted. The designation of the National Park, and the decision to include the town of Lewes within it, was to ensure the protection of our precious landscape, the downland setting of Lewes and its cultural heritage. All of these are seriously threatened by the proposal to build 200 houses on quality farmland at Old Malling Farm which is highly visible as well as having historic associations and archaeological significance.”

Says Steve Ankers, Policy Officer for the South Downs Society, “Both societies want to see more affordable housing available in and around Lewes on brownfield sites but, as the official Friends group for the National Park, we very much share this opposition to any new housing estate at Old Malling Farm. Development there would be a worrying precedent for building on other greenfield sites on the edge of town or elsewhere in the National Park.”

 A further round of consultation is taking place between 7 August and 2 October, with a possible reopening of the public inquiry in the autumn to consider comments on this site. While the Societies will be putting forward a strong objection to the 200 houses proposed for Old Malling Farm, it is vital that members of the public make their views known.  Details of the proposals are available on Lewes District Council website:

http://www.lewes.gov.uk/planning/22277.asp

Send in your comments by emailing ldf@lewes.gov.uk or by post to Lewes Planning Department at Southover House, Lewes.

 

 

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Monitoring the National Park Planning Committee

At the end of 2013 the Society reviewed the decisions reached by the National Park Authority’s Planning Committee at its more or less monthly meetings through the year. We posted our report on the Society website and shared it with senior national park staff. We have just repeated the exercise for 2014. The results are below. We will again share the report with the park authority.

Of the four thousand or so planning applications received each year in the national park, approximately 450 are likely to be determined by the NPA itself, the remainder being delegated to the councils which have an agency agreement with the park authority. During 2014 the NPA’s Planning Committee determined 68 applications in addition to responding to consultations from neighbouring planning authorities and emerging planning policies at park, county, district and neighbourhood level. The 68 applications determined by the Planning Committee comprised applications either called in for determination from the “agency” councils on the grounds of “significance” or, within the “recovered service” authorities (Arun, Brighton and Hove, Wealden, Eastbourne and WSCC), because for various reasons they were not delegated for officer decision. Around 400 applications, therefore, were determined by NPA officers acting under delegated powers, the great majority of which were located in the “recovered service” areas. Reasons for applications to be reported to members for decision, rather than being determined by officers, include: an objection by the parish council, a minimum of five representations from third parties, or a request by a member of the NPA.

Within the 68, perhaps 33 might be regarded by the Society as particularly significant, involving, say, at least half a dozen dwellings, a commercial operation including equestrian or holiday accommodation, travellers, nursing home, agricultural silos, oil or gas exploration or extraction, recreation facility or a newbuild or conversion proposal affecting a particularly sensitive listed building or conservation area. Of the remaining 35 applications determined by the Committee, no fewer than 27 were located in the “recovered service” areas of Arun and Wealden. This report focuses on the 33 “key” applications.

Of these 33 the Society commented on 20, out of a total of 96 comments submitted altogether by our District Officers (DOs, the Society’s planning volunteers) in 2014, compared with a 2013 total of 80. Some, though not all, of the key applications on which the Society did not submit comments fell in areas of Hampshire with no current DO cover.

22 of these 33 key applications were recommended for approval in the officer report and were approved by members, while the remaining 11 were recommended for refusal by officers and were refused by the members. (There was one instance during the year of an application being recommended for approval but then deferred by members at the October meeting – an application to demolish the former magistrates’ courts in Lewes and replace with a three storey newbuild for Premier Inn and retail/commercial units – but this has not been included in the 33 decisions made as it was neither approved nor refused. A revised scheme was approved at the December meeting in line with the officer recommendation).

Of the 20 applications on which the Society submitted comments, 14 decisions were made broadly in line with our comments including, notably, in relation to an application for oil and gas exploration at Fernhurst. On five applications the Society had submitted an objection or had expressed caution and the need for improvements or conditions but was in effect overruled by the Planning Committee, in respect of: ground based satellite dish antennae near Winchester; insensitive conversion of farm buildings in Greatham conservation area; an amended scheme for housing at Drewitts Farm, Amberley; the Premier Inn, Lewes; and affordable housing at Coldwaltham (on design grounds and the accuracy of the case made for local housing need). In one instance – the construction of a water storage reservoir for a golf club – the Society expressed conditional support but the application was refused.

On a number of occasions the Society chose to address the Committee meeting to underline its views, having in some instances been invited to do so by local residents or other organisations seeking support or a more strategic perspective. In 2014, as in previous years, the Society has chosen to address the Committee on more occasions than any other body and our contributions do appear to be influential, frequently being picked up by local media.

The issue of the impact of the NPA on the decision making on the thousands of applications determined each year by the “agency” councils is a harder one to monitor. The NPA has been developing methods of measuring this “added value” and the Society has indicated to the NPA its keen interest in the methodology and the outcome.

 

Steve Ankers, Policy Officer

January 2015