27 Jul 2018
Mainstreaming nature in planning policy: Finding the hooks and crooks in the new NPPF
There has been much comment and hype over the long awaited NPPF released on the last day before summer recess (24th July 2018). This blog uses a green infrastructure lens set within the wider umbrella of spatial planning to pass comment on the NPPF’s environmental credentials. In a previous output from a research project on mainstreaming green infrastructure, a collective response from the Green Infrastructure Partnership was made under my editorship highlighting our concerns over the draft NPPF. This may provide useful reading to put this blog in context.
I have framed this piece looking at the NPPF in its entirety and then drilling into specific sections. It forms a starting point for further discussions and comment.
Overall purpose and vision.
The NPPF is currently being framed as a set of planning rules by both government and press in its external communications. This is not what the NPPF is or should be. In many ways this reflects the lack of vision within the NPPF itself. Good planning is much more than applying a set of rules. At its heart is the concept of designing and building better places and environments within a placemaking agenda. Here planners have a set of skills and tools to do this and have undergone years of professional training to do this well. The NPPF represents a missed opportunity to provide a powerful and positive vision for the kind of planning we want to see in England. The lack of any strategic spatial plan reflecting the different challenges and opportunities across England is also a disappointment.
The English planning system had its roots in a concern for social and environmental justice. The current 2018 manifestation of the planning system does not really address these issues at all. Given that some of the biggest issues we face such as climate change, air pollution and obesity impact most on the most vulnerable groups there was a key opportunity to address this as a central theme that runs across the document.
Reading the document in its sections there is a distinct lack of cross referral meaning that mainstreaming of issues across other agendas is relatively weak. Thus you will get people promoting paragraphs in one section as core to their case with no clear sense of priorities. This hides conflict till the plan and decision making processes kick in. I would liked to have seen more cross referencing through a separate challenge section that shows how the different paragraphs intersect.
Whilst viability has a particular meaning through the NPPF its wider environmental and social components exist and can be costed into proposals. The current focus on viability assessments being part of the plan is now welcome as is the requirement for public disclosure. However, there is still a missed opportunity to reform viability in line with environmental and social limits to try and achieve other commitments such as health, climate change and biodiversity.
More specific comments follow
Read the NPPF as a whole (Paragraph 3) Danger to cherry pick one area given the need to view and read the document as a whole. Many agencies tend to look at their particular policy area in isolation which may give a misleading picture of the cumulative effects of the paragraphs. It still strikes me as somewhat strange that the NPPF itself is not subject to a SEA.
In terms of other documents and plans that should be read alongside the NPPF there is no mention of the HM Government 25 year environment plan. This is a serious oversight.
Sustainable Development (Par 8ff) Net economic, social and environmental gains introduced in par 8 (Sustainable development) but only net biodiversity gain mentioned in the natural environment section. The relationship between net environment gain and net biodiversity gain is not stated and crucially there is no definition of these in the glossary. Interestingly in our submission we offered these points
There is no explicit recognition of the UN Sustainable Development goals (Par11ff) despite significant numbers of requests to do this in order to provide a more contemporary definition of SD with indicators and outcomes that could allow for international comparisons. This is a missed opportunity. Instead we see a housing led approach which reinforces existing policy silos.
Plan Making (Par 17ff) There has been clarification over the role of strategic and local policies and the role of local plans. However there is still the prospect in combined authorities that there will be only a strategic spatial strategy and thus for parts of England there will be no detailed planning policies unless there are neighbourhood plans.
Strategic Policies (Par21) Given the key importance of climate change, water management, biodiversity as key strategic issues emerging from HM Governments Environment Plan it would have been beneficial to require local planning authorities to address these as core priorities. However it lies with them to identify them. Lack of resources and staff may hinder this resulting in housing becoming the dominant concern.
Enforcement (Par 58) Enforcement remains the Cinderella of the planning system and to have one paragraph is perhaps indicative of its almost forgotten status. However it remains crucial to the successful delivery of planning.
Net Environmental gains ( Par72) With reference to this concept it is pleasing to see the subtle change from net environment gain in the draft to gains in the final version. This addresses concerns that there could be a trade off across different ecosystem services to derive one net gain measure. However the lack of definition is problematic and thus needs urgent practice guidance.
Ensuring the vitality of town centres (Chapter 7) This section would have benefited from the explicit mention of the role of green and blue infrastructure in helping provide opportunities for investment and improved economic performance. There is evidence from investment in area like the High Line in New York that green investment leads to economic benefit and increased turn over for businesses. Work undertaken as part of the SWEEP initiative highlights the role that natural capital can play in generating such effects in SW England.
Achieving well designed places (Chapter 12)
Here the NPPF stresses that the achievement of high quality buildings and places is a fundamental tenet of the planning system (paragraph124). However if this is the case why is it not elevated to the introduction and as a key component of the sustainable development section. This appears to have been bolted in but as part of a section on design this seems to be in the wrong place and as many have argued the core planning concept of placemaking should be one of the core planning principles.
Green Belt (Chapter 13)
It is important recognise that green belt represents a core part of the green infrastructure network itself and should be planned as a strategic issue. There is a danger to silo different areas of the NPPF and there is no reference that green belt forms an integral part of the green infrastructure network. It is welcome to see that exceptional circumstances to change green belt need to be justified and evidenced (par136).
Climate change (par 149ff; footnote 48)
It is good to see the footnote changed to reflect the objectives of the act. However, reflecting the ambitions in the 25 Year Environment Plan to be a world leader in climate change there was a chance for a stronger set of measures to climate proof new developments such as mandatory Suds and greywater systems for example.
Par 157 somewhat captures the missed opportunity where for flood risk climate change needs to be taken into account.
Par 165 on Suds being required for major developments is welcome. However, it raises the question why small scale Suds measures should not be mandatory as the cumulative impacts of these can be significant.
Chapter 15 Conserving the natural environment.
As stated before it does seem strange that throughout this chapter net biodiversity gain is mentioned yet within other chapters affecting sustainability, housing and use of land the term net environment gains is used. This inconsistency is worrying and does in my view need explanation.
In the original response to the draft NPPF a significant section of the response was on the need to translate the provisions of the 25 Year Environment plan into the NPPF. The revised version has made some changes but much of the aspirations are not translated or where they are such as for net biodiversity gain and net environment gains they are not mandatory. The linkages of green infrastructure to statements of common ground would have helped ensure that this is included in cross authority discussions. By leaving it optional there is a risk that with limited resources it gets left out.
Par 170b recognising the value of natural capital and ecosystem services provides a relatively weak requirement but nonetheless is still a hook to build upon. The details of a natural capital approach in the 25YEP and how it can be used to improve plans and decision making has not been addressed.
Par174 plans should map ecological networks ….. privdes an improved base upon which to plan naturally.
Par174b important word change to enhancement rather than re-creation
Par 175c the inclusion of ancient and veteran trees is welcome as irreplaceable habitats but peatlands should also have been added.
The definition of green infrastructure still does not include blue and this again risks hiding a key part of the green infrastructures network. I argue that we should use green and blue infrastructure simply to reinforce that not all living infrastructure is green.
Other key terms used in the NPPF such as natural capital, ecosystem services and the net biodiversity and environmental gains are not defined. This seems inexplicable given their lack of understanding in the built environment. Furthermore suggested definitions were included in my original response.