National Planning Policy Framework Consultation Response

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.

2. 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 21^st 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

http://www.helen-chadwick.co.uk/

helen@helen-chadwick.co.uk