04 Mar 2018
What Kind of National Planning Policy Framework (NPPF) do we Need
On Monday 5th March 2018 the revised and much changed NPPF will be released for consultation. Its predecessor started off life in 2012 amidst much ministerial acclaim that it was reducing 1000s of pages of planning guidance to 55. Yet, since 2012 there have been reviews of the NPPF and its impact on the built environment which have identified significant failings with the way it was been operating. First the CLG Select Committee report into the operation of the NPPF in 2014 exposed a number of shortcomings related to the sustainable development credentials it was championing. In particular, the impact of viability on housing schemes; the impact on town centres and the impact on communities. A year later the House of Lords Built Environment Committee released Building Better Places which echoed these concerns. In the summary it stated : “ More fundamentally, however, we are concerned that the overall emphasis on speed and quantity of housing supply appears to threaten place-making itself, along with sustainable planning for the long-term and the delivery of high quality and design standards”. However, both these reports fell on stony government ground with the recommendations largely rejected. The fetish for housebuilding was now embedded in DCLG’s culture with institutional myopia threatening the placemaking goals which spatial planners like myself champion.
However, since then we have had the publication of the Industrial Strategy2017 and the 25 Year Environmental Plan 2018. These documents highlight the need for the planning system to be more integrative and make the connections between places to live, learn, work and play. Working within this opportunity space is essential for the NPPF, but not within separate siloed chapters. Indeed, it is how they are prioritised and interact that lies behind some of the problems with the current NPFF.
In advance of tomorrows publication therefore here is my take of what we need a revised NPPF to do.
Define sustainable development explicitly linked to monitoring of NPPF performance. The planning system is a key delivery vehicle towards sustainable development. The previous NPPF defined sustainability as based upon ALL the 200+ paragraphs when taken together. This led to paragraphs being selectively cherry-picked that supported developments, generating significant uncertainty. This was magnified where local authorities did not have a 5 year housing land supply and, in the absence of a finalised local plan, led to the NPPF being the prime determinant of applications.
Thus we need a much clearer sign up to a definition of sustainable development which can then be used as part of future monitoring processes. Here I favour the endorsement of the UK Sustainable Development Principles: living within the planet’s environmental limits; ensuring a strong, healthy and just society; achieving a sustainable economy; promoting good governance; and using sound science responsibly. There should also be explicit linkage to the achievement of UN Sustainable Development goals within a new section on monitoring success of the NPPF
Use placemaking as a key spatial planning concept within the NPPF. Placemaking is more than building houses. It is about building great places and resilient communities that are connected to the services and infrastructure (grey and living (green and blue)) that they need for the present and into the future. However, this should not be just about building NEW places; it is also about RETROFITTING infrastructure and services into existing areas. All too often deprived areas remain neglected and bypassed in investment decisions. The 25 year environment plan made the connection between nature and social justice. Indeed, the planning system was founded on social justice considerations and thus more attention needs to be placed on revitalising areas and communities that suffer from poor services and associated issues of air pollution, poor health and poor quality of life.
Viability has social and environmental components too. Currently the NPPF defines viability in purely economic and financial terms with a 20% margin from development taken as standard. This is a pretty good return in today’s world! The wording of the paragraph is such that affordable housing and other essential community infrastructure could be all too easily lost resulting in a sustainability deficit that impacts negatively on the place, the environment, the people and community resilience. Paragraph 173…. “ the sites and the scale of development identified in the plan should not be subject to such a scale of obligations and policy burdens that their ability to be developed viably is threatened. To ensure viability, the costs of any requirements likely to be applied to development, such as requirements for affordable housing, standards, infrastructure contributions or other requirements should, when taking account of the normal cost of development and mitigation, provide competitive returns to a willing land owner and willing developer to enable the development to be deliverable”.
However, there are also environmental limits in terms of drainage, water supply and biodiversity; and social limits in terms of access to schools, doctors and public transport that surely need to be taken into account into a revised viability assessment process. Furthermore, by taking such issues into account, synergies between them can actually strengthen the deliverability of developments for the long term. So for example improving the green infrastructure within developments through the provision of SuDS and woodlands, green roofs ad play areas can actually bring increased profit.
The environment is part of the development jigsaw not a constraint. Across the Industrial Strategy and the 25 year Environment Plan the common term used is natural capital This therefore should feature in the revised NPPF; currently it is not mentioned at all. The link between the stock of nature (natural capital) and the ecosystem services flows needs to feature as something that is an asset and not a constraint.
The 25 year environment plan has established the principle of net environment gain. It is poorly defined and that does run the risk of selective cherry picking of the bits of the environment that are positively affected by a proposal as opposed to other bits that are not. Currently within the NPPF we have net biodiversity gain, which is not mandatory but many local authorities have built development plan policies around this notion. Furthermore, tools have been developed to help achieve this. I would like to see clarity here in the revised NPPF that provides a mandatory role for delivering net biodiversity gain with an obligation to ensure that other ecosystem services accord with policy priorities in the local plan to deliver a quality environment. Too many net gains might only serve to confuse and undermine the environment through perverse outcomes.
Duty to Cooperate is no substitute for good strategic planning. The abolition of regional planning by Eric Pickles was a mistake. It was replaced by a duty to cooperate over key strategic issues. In theory this could tackle key issues like climate change, biodiversity, transport, energy and flooding. But in reality this was built around objective assessments of housing need and the cooperation across joint housing market areas. Whilst under combined authorities model there is an option for a regional planning remit only Manchester thus far has this function. Other combined authorities like the West Midlands do not making a proverbial pigs breakfast of different roles and remits across the country. The revised NPPF needs to have a much stronger focus on all strategic issues as part of the local plan test for soundness concomitant with the need for strong cross border policies. A good example is contained in the government response to the Parks Inquiry 2016 where it states p13 that “If inspectors find that local authorities havenʼt appropriately assessed and planned for green infrastructure to meet health and wellbeing needs (alongside other functions of green infrastructure such as urban cooling and sustainable urban drainage), then they would not find the plan ʻsound”
Summary In essence the key challenge for the revised NPPF is to champion good spatial planning. Here the revised NPPF needs to go back to the roots of planning where integrated visions together with the necessary mechanisms for delivery were established. My fear is that the housing fetish will distort the NPPF and relegate planning to delivery of houses at the expense of the wider placemaking agenda we now need.