March 2018
It was a great step forward for planning when the Prime Minister Theresa May launched the National Planning Policy Framework Draft text for consultation on Monday. Although by no means a perfect document, this represented a shift from the bad old days when planners were seen as the ‘enemies of enterprise’ (David Cameron, March 2011) to recognising that some of its problems may lie in ‘allowing some developers to game the system’. Although the rhetoric of the launch day was firmly set on building our way out of the housing crisis, this shift in attitude and the presence of the Prime Minister must empower planners.
Empowered planners can only be a good thing for our environment, the landscapes and the rich biodiversity that we all treasure. I hope this shift will motivate planning authorities to plan great communities that enhance the environment whilst preserving our most special places. Below are a few key points on the draft NPPF.
Sustainable Development
The presumption in favour of sustainable development remains but the golden thread has gone - what this means in reality no one is really sure! However, the definition of sustainable development is much clearer than the previous iteration. Gone is the confusing sentence that states that the whole of the NPPF excluding the definition represents the Government’s view on sustainable development (paragraph 6). This is a change that Link has long campaigned on.
The closing of footnote 7 (formally footnote 9) to create a definitive list is worrying. Whilst the inclusion of ancient woodland and aged and veteran trees is welcome, the exclusion of Local Wildlife Sites and other environmental assets is a backward step for nature.
Creating great new communities
There is a little more detail on design, and walking and cycling are mentioned more than previously, plus the inclusion of green infrastructure in the strategic policies in 20(f) is a positive step forward. But whilst there is a bit more emphasis on good design, there is very little to prevent bad design. There is nothing that local planning authorities can really hold planners too. For example, the text states:
92. Planning policies and decisions should aim to achieve healthy, inclusive and safe places which:
……c) enable and support healthy lifestyles, especially where this would address identified local health and wellbeing needs – for example through the provision of safe and accessible green infrastructure, sports facilities, local shops, access to healthier food, allotments and layouts that encourage walking and cycling.
The provision of safe and accessible green infrastructure must be at the heart of new developments if they are to be healthy, sustainable and desirable places to live. It is disappointing that the current draft treats green infrastructure as an optional extra.
Housing Numbers
The draft puts increased emphasis on the developer to deliver housing numbers rather than just local planning authorities delivering permissions. This is to be welcomed but there is no obvious link to the work of the Northern Powerhouse, the Industrial Strategy and efforts to rebalance England’s economy. Instead it continues to be demand-led. This approach fails to recognise that this is putting unsustainable pressures on the south east and London, whilst other parts of the country suffer from lack of intervention and investment.
The Right Homes in the Right Places consultation stated that the housing need methodology was the first step in assessing housing requirements. As it stands the draft NPPF fails to provide guidance on the following points; taking account of environmental constraints; opportunities for growth; and the capacity of the house building industry to deliver – this last point is of particular importance given the introduction of the housing delivery test.
The Environment
Paragraph 173 c) improves the protection given to ancient woodland making its loss or deterioration ’wholly exceptional’. However, oddly, it decouples ancient woodland and aged and veteran trees, specifically stating that the latter must not be considered to be irreplaceable. This runs contrary to the original NPPF and the Government’s aspirations set out in the Housing White Paper.
The draft maintains protections for the Green Belt, a relief following concerns in the build up to publication. The draft also states that the scale and extent of development in National Parks and Areas of Outstanding Natural Beauty should be limited; the first time in over a decade that national policy has said this.
Next Steps
The consultation period is an opportunity for Link members to respond strongly, to ensure that the biodiversity and landscape are at the heart of this shift in attitude. The Planning Group will be working with government and other partners to respond to this consultation and the others that were released as part of the package.
Victoria Bankes Price
Planning Advisor at Woodland Trust and Chair of Link's Planning Group
Follow Victoria and Woodland Trust on twitter: @VBP2011 and @Woodlandtrust
The opinions expressed in this blog are the author's and not necessarily those of the wider Link membership.
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