Consultation
Response to the draft National Planning Policy Framework
From
Helen Chadwick Sustainability Consultant
Introduction
The introduction of a
succinct National Planning Policy Framework (NPPF), with clear
objectives, is to be welcomed. It should clarify and reduce the
opportunities for conflicting policy goals across national planning
policy. It should also allow for easier review and assessment of
progress against objectives as we move forward.
There are however
concerns in relation to the internal conflicts within the framework
and more widely with other Government Policy, particularly the
“Localism” agenda. The main objective of the planning system has
always been to facilitate and bring forward development. The
recognition of the need to retain plan based is welcomed, but the
wider presumption for development in the event of absent plans could
lead to a substantial amount of poorly considered development, at
odds with local wishes that blights our towns and countryside for
generations to come.
Sustainable development
objectives are poorly defined. The draft framework narrowly defines
sustainable development with with pure economic growth goals, without
the wider issues of health, social issues and environment really
being fully integrated. It also does not recognise the role planning
in managing contraction and even retreat from development in certain
challenged areas across England.
It is easy to blame
planning for all the ills of development within the country, but this
is a simplistic view. It is important to have clear planning policy
and process, but we should also recognise that the many stakeholders
in an area have very different goals and views about local
development. Planning provides an arena for these views, to be heard
and possible conflicts to be positively addressed. It is clear though
that there are often significant variation in views and it is not
always easy to resolve the issues quickly. There is a danger that a
presumptive approach will often lead to poor development in the wrong
place and meeting the wrong needs. It is most likely that the poorest
development will also occur in or near those communities that are
most disadvantaged and least able to make their voices heard within
the system. This could contribute to widening the already worrying
equality issues across our country. The highly political nature of
planning should be acknowledged.
The NPPF requires an
evidence led strategic approach to much development. There are
questions to be answered as to whether many of the smaller borough
and district councils have the capacity to deliver this level of
plan. Many have lost planning skills through redundancy over the past
few months. The costs of evidence collection and monitoring are
significant and stretched budgets will make this challenging. In
addition some aspects of delivery require careful partnership with
highways, utilities, private companies and other public sector
partners. Many stakeholders will find that it is too challenging to
engage actively with the large number of planning authorities. There
is a need to consider a strategic sub-national approach to replace
the soon to be abolished Regional Plans. This will be necessary to
facilitate partnerships and to ensure that infrastructure spending is
aligned and that cross boundary development is well managed and
delivered.
Planning
For Posterity: Business and Economic Development
Town
Centre Vitality
Planning can never on
its own cause development to occur. Developers will not bring forward
sites if market conditions are not suitable. This and the political
nature of planning must be acknowledged if policy and process are to
be appropriately changed and improved.
The NPPF seems to
weaken the policy support for town centre development, which could
challenge delivery of the congestion and greenhouse gas emissions
objective by encouraging more car use. This may also impact on public
health objectives related to obesity and healthy life styles.
Town centre sites are
often more difficult, and more costly to develop, given a larger
number of stakeholders, including landowners, so a stronger support
for town centre development is required. Some distinction should
probably be included for different town sizes. A small town will be
more affected by out of town development than a city, especially
where the out of town development can be clearly linked with a local
community.
Transport
Additional policy
support is needed to deliver integrated transport solutions and to
ensure that non- car infrastructure is adequately considered in all
development. In some cases development could be driven to the
boundaries of the plan area, with significant consequences for the
transport planning of a neighbouring authority. This is particularly
an issue for the many under-bound cities, where suburbs are in other
authority areas. Although cooperation between authorities is
encouraged, it may be necessary to have more detailed ways of dealing
with such matters. There is a need for clear implementation plans and
identification of streams of public and private finance that will
help to deliver
Waste
Whilst it is understood
that waste will be dealt with elsewhere, this document should at
least include the high level objectives on the spatial issues around
waste planning.
Renewable
energy
The NPPF should include
renewable energy in the “Planning for Posterity” section not in
the environmental section. Renewable energy is clearly part of the
required energy infrastructure for the country and has similar
planning implications to communications infrastructure. Energy policy
should as far as possible be addressed together and would sit well
with the energy minerals section. Renewable Energy, particulalry
on-shore wind, would benefit from as clear a planning regime as
possible and the current material in NPPF would benefit from
strengthening. Renewable energy is also a massive growth industry for
our country and should be recognised as such. The specific links
with the National Infrastructure Guidance should also be clarified.
Planning
for People
Housing
It
is clear that insufficient housing is being developed year on year.
Planning certainly has a major role in housing. The Planning System
can allocate land, but cannot deliver housing, or homes. It is clear
that a housing market that relies on mainly private sector
development will always be subject to variations in the wider market,
including the effect of reductions in profitability and demand. It is
similarly not clear that the current set up can deliver the range of
types of housing needed. Affordability is related not only to market
cost, but also the ability to keep running the house within household
budgets. For some people their lifestyle is too precarious for them
to be exposed to the risk inherent in a investment-led housing
market. It may be time for a much wider debate on what we want from
housing, public, private and other in the 21st
century.
There is a major gap in
the framework. The recognition that some individuals and groups do
not conform to the general approach to dwellings. This is
particularly so for gypsies and travellers. Delivering appropriate
sites is certainly an area that needs careful policy direction, as it
often an area for significant conflict in local areas.
Local Planning
Authorities will struggle to keep evidence bases complete and up to
date. Some strategic sub-national evidence and monitoring could lead
to more robust cost effective information and reduce repetition
Design
The emphasis on good
quality design very welcome. However, once a site comes to planning
many of the major design issues have been set fast. Good quality
master-planning at an early stage, with community input, can be an
excellent way to embed design criteria and fully engage local
communities meaningfully. The wider site design can then be
incorporated.
Sustainable
Communities
There are many
challenging aspects to helping communities become more sustainable.
This involves recognising that not all communities will be growing.
Planning needs to play it part in encouraging a major shift to more
sustainable lifestyles. This will require integration of policy
across a number of key stakeholders including: private investors,
public health teams and a range of local authority finance streams
(including education, highways and others). Careful implementation
plans are necessary to ensure that there is good value for money
delivered.
Similarly the
environmental and social goals of delivering green space need to be
aligned to ensure that green spaces are multifunctional, delivering
recreation, biodiversity and resilience to climate change and flood,
in a safe well used space. This requires significant partnership
working and a strategic approach to sites and local areas. There is a
risk that the many different strands of funding will deliver poorly
developed green space and there will be no funds for upkeep, which
will blight local areas.
There is a deep
conflict in the guidance in the NPPF and the Localism agenda. Local
groups will expect to have a real say in development decisions and
often this will involve wanting to say no. The NPPF, or some
subsequent guidance, must clarify how communities can say, “yes,
if...”. A lack of real engagement and empowering of communities
will lead to greater distrust and cynicism in the process. In
addition the inequality divide will be exacerbated as poorer
communities lack to power to ensure their voice is heard.
Planning
for Places
Climate
Change
It is encouraging to
see the issues of climate change mitigation and adaptation well
embedded within the document. However the delivery of local policy
will require the development of significant evidence and the upkeep
of data. This will be extremely challenging and costly for small
local planning authorities. The evidence and monitoring is more
suited to delivery at a sub-national level, allowing better value for
money to be realised. Similarly adequate implementation required
close partnership working and integration of funding streams to
maximise benefit. It is not clear that the capacity is available in
the local planning system, particularly with the loss of so many
staff by Local Government and other public sector bodies.
Natural
Environment
The above comments are
also relevant in the areas of biodiversity, landscape and heritage.
It may be helpful for LPAs to be able to designate a samll number of
sites as locally important to ensure that those are given some
protection from more contentious development, particularly
infrastructure development, like masts and renewable energy or waste
sites.
Summary
and
Conclusions
The NPPS would benefit
from a sustainability appraisal to highlight conflicts and gaps.
There are a number of potential unintended consequences of the
objectives stated here that could lead to difficulty in achieving
both planning and other government objectives.
Waste Planning should
be included at least at objective level.
Renewable Energy
should clearly be addressed as an economic and infrastructure issue,
not an environmental issue.
Strategic planning and
evidence base development is essential across Local Planning
Authorities. The Regional Plans provided the ideal vehicle for this,
ensuring value for money and appropriate monitoring. Recently there
had been excellent partnership working and implementation, that had
delivered real benefits in cost saving and delivery.
It must be recognised
that delivery of planning objectives involves many stakeholders and
planning has limited ability to deliver if markets are not working
in favour of development.
The current format of
the NPPF risks seriously increasing the inequality of development
and may lead to future social and economic problems. Quality and
delivery will vary greatly across the country and even across
planning districts.
The conflict between
the NPPF and the Localism agenda is likely to increase the
difficulty in delivering good qulaity development and may lead to
many more appeals than currently.
Monitoring and
implementation need further consideration.
Helen Chadwick
Helen Chadwick
Consulting
helen@helen-chadwick.co.uk
