1. #neighbourhoodplanning Policy Wording

2. Policy Intent Evidence What do you want to do and why? Set it out in plain English More planning language may be needed To support choices and intention Starting to write

3. Exeter St James – Policy C1: Houses in multiple occupation Intent Halt conversions to HMO; ensure area stays attractive to all sectors; diverse population, people at all stages of life. Community balance; rapid increase in proportion of students; loss of permanent residents in some areas; 20% threshold Policy Evidence “Changes of use to houses in HMO will not be permitted unless; a), b)… e)”

4. CONTEXT Additional community facilities are provided by: a large village green which includes a cricket square and football pitches; two LEAP17 standard playgrounds; badminton, yoga and other indoor activities in the village hall. Local sports provision is enhanced for the local community by: the generosity of the independent school (golf, swimming pool and squash courts) and Academy (particularly the sports hall and tennis courts); and the village’s proximity to various towns (athletics tracks, multi-purpose sports halls, outdoor bowling greens, golf courses, hockey, rugby and mini soccer pitches). POLICY Proposals which provide for additional sports facilities on the Academy and Primary School sites, to meet the requirements of the school as well as the wider community, will be encouraged so long as they do not involve the loss of existing playground, playing fields, or areas of open space using, for example, artificial play surfaces such as Astroturf.

5. WHAT THE INDEPENDENT EXAMINER SAID Seeks to prevent use of artificial surfaces No reason given to justify such an approach Nothing in NPPF or strategic policies of the development plan to support such an approach Appears to conflict with the intent of the policy – additional facilities for the use of the schools and the wider community Possible intent has been altered by the use of grammar in drafting No indication that additional facilities could be provided using anything other than existing open space So confusingly worded as to fail to provide the clarity required However, on the basis that I understand the aim of the policy, I suggest the modification: “Proposals which provide for additional sports facilities, open in character and over and above those which already exist, on the Academy and primary school sites and which meet the requirements of the school and wider community will be encouraged.”

6. ‘policies as drafted are imprecise’ ‘the policies would not provide clear guidance’ ‘likely to cause unproductive argument’ ‘unsuitably weak or neutral’ ‘should is not the same as must’ Examining Language

7. Be clear and succinct Cringleford examiner’s report: “ I commend the Draft NDP for being logical, clear appropriately concise and intelligible to a reasonably intelligent lay reader with no expertise in town and country planning.” Rolleston examiner’s report: “The technique used in the Neighbourhood Plan to present a grid demonstrating the link between plan objectives and each of the plan policies is a fine example of best practice. These grids identify for every policy exactly which objectives the policy is addressing.” NPPF: “Planning should be genuinely plan-led, empowering local people to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of the area (…) Plans should provide a practical framework within which decisions on planning applications can be made with a high degree of predictability and efficiency.”

8. Planning Practice Guidance. “A policy in a neighbourhood plan should be clear and unambiguous. It should be drafted with sufficient clarity that a decision maker can apply it consistently and with confidence when determining planning applications. It should be concise, precise and supported by appropriate evidence. It should be distinct to reflect and respond to the unique characteristics and planning context of the specific neighbourhood area for which it has been prepared.”