Government advisory group publishes draft national planning policy framework

May 23, 2011

The proposed national planning policy framework (NPPF) must come into immediate effect and be rigorously enforced, the government’s practitioners advisory group has urged after submitting a draft to Planning Minister Greg Clark.

The government intends the NPPF to consolidate all policy statements, circulars and guidance documents into a single, simpler framework.

In a letter to the Minister attaching a draft framework, the advisory group said: “Whilst the NPPF will demonstrate that the government has devolved as much planning policy as it can, what remains within the NPPF should be regarded as being of central importance to the achievement of a number of government objectives.

“It is important, therefore, that weight is not only attached to the NPPF but that it is seen to be attached through the operation of the planning system and, in particular, through decisions made by the Secretary of State on appeal and in relation to his role in ensuring that local plans address national objectives.”

The group said that a delayed introduction of the framework would generate confusion and have the effect of deferring the contribution which the NPPF could make to national economic recovery and other government objectives. “Pending the preparation of local plans consistent with the NPPF, the NPPF itself can provide a sufficient framework against which planning decisions can be made.”

The letter also said:

There need be no inconsistency between the promotion of increased levels of development and the protection of the environment. “Properly planned, increased levels of development can enable the achievement of ‘multiple wins’ – enhanced economic growth, better access to housing and the means to achieve positive environmental enhancement”
Existing policy tests for the Green Belt and for the protection of the historic environment should be retained
New policies should be adopted to promote green spaces and wildlife corridors in order to halt the loss of habitats and biodiversity. The draft framework also proposes policies to address the challenge of climate change to facilitate the achievement of carbon reduction targets
An initiative is required to “reduce, clarify and simplify the weight and complexity” of planning guidance which sits below planning policy. Another practitioners group should be asked to generate succinct guidance for the preparation of local plans and for development management. The letter said this was “not intended to be the introduction of additional policy through the back door – quite the reverse”
They were not convinced that the government was best placed to be the arbiter of best practice guidance. The government should scope those areas where guidance would be helpful and identify the parties who can most usefully contribute to that guidance. Those parties should then be allowed to develop best practice and for it to be made clear that such guidance is useful but not policy.

The practitioners advisory group was appointed by the Planning Minister in December 2010 and consisted of Pete Andrew, Director of Land and Planning at Taylor Wimpey, Simon Marsh, acting Head of Sustainable Development at the RSPB, Cllr Gary Porter, Chairman of the Environment and Housing Programme Board at the Local Government Association, and John Rhodes, director of planning consultants Quod.

Cllr Porter said: “Our approach to the national planning policy framework provides a real opportunity to free local government from unnecessary guidance and prescription, giving councils greater control to shape and improve their local areas in ways that work for them.”

Rhodes said: “Reform is necessary to reduce complexity, devolve power and to make planning more accessible to all those that it affects. But reform is also necessary to drive growth – responsible growth that can deliver the development, the places and the environment that the country deserves.”

But town planners have expressed concerns over the draft, in particular in relation to sustainable development.

The Royal Town Planning Institute hailed the draft NPPF as a landmark step, but suggested that planning needs to be spatial to be effective. President Richard Summers said: “The RTPI has long campaigned for a national planning framework for England but the NPPF must be spatial to be effective. National planning must show the geography of planned activities, development and infrastructure and how the government’s policies and land use designations apply to different parts of the country.”

He added: “The RTPI is seriously concerned about the way in which the presumption in favour of sustainable development is expressed in their draft NPPF. It is a denial of the concept of sustainable development to give over-riding emphasis to the approval of development proposals without ensuring that that they are economically, socially and environmentally sustainable.”

The Institute said the draft had failed to meet the essential requirement to address the different needs and opportunities of different parts of the country or to incorporate the government’s existing spatial policies, such as rebalancing the economy and developing High Speed Rail 2.

The Town and Country Planning Association meanwhile warned that the proposed framework “falls short of the guidance necessary to create an effective planning framework for England”.

The TCPA outlined three concerns with the advisory group’s proposed framework:

It contains new definitions of key concepts such as Sustainable Development. “The proposed definition of Sustainable Development is not aligned with the government's own definition and is far weaker,” the TCPA said. “While the advisory group places an emphasis on achieving a sustainable economy through ‘planning for prosperity' it fails to address the other fundamental principles of sustainable development which are: living within environmental limits; ensuring a strong, healthy and just society; promoting good governance; and using sound science responsibly”
There is insufficient detail on implementation. “The draft NPPF does not provide adequate guidance on evidence, mechanisms and detail which are essential to deliver on key issues such as housing and climate change,” the association claimed. “For example, the draft NPPF walks away from a lot of valuable policy and comprehensive guidance needed to take action on climate change adaptation”
"Crucial" policy elements are missing, such as human health and social justice. “For example, this document fails to recognise the contribution well-planned developments can make in achieving long term health and well-being outcomes.”

Kate Henderson, TCPA Chief Executive, said: "We are facing unprecedented challenges from climate change and a housing crisis. This draft NPPF from the advisory group has identified a number of important priorities, but does not provide all the necessary key principles or practical tools to face those challenges. The government must move quickly to ensure there is genuine cross-sector support for the new framework based on a robust policy to deliver a fair and low carbon society."

A copy of the proposed draft can be downloaded here.

Philip Hoult