Action
for a
Better
Charnwood (ABC)
– Response to
the National
Planning Policy
Framework
Consultation
ABC
is concerned
about a
number of
aspects of
the proposed
National Planning
Policy Framework,
particularly in
regard to
its treatment
of the
idea of
sustainable development.
As a
local group,
ABC began
life in
the 1990s
as a
Local Agenda
21 group
covering the
Borough of
Charnwood. It
has been
and still
is committed
to promoting
and campaigning
for measures
that contribute
to achieving
greater sustainability
and sustainable
developments in
the local
community. In
that regard,
we are
concerned that
the NPPF,
if adopted
in its
present form,
will undermine
the progress
made to
achieving a
more sustainable
society over
the past
two decades.
There
are many
fine words
in the
document but
close scrutiny
suggests that
there has
been a
re-writing of
the meaning
of the
term in
a way
that represents
a significant
shift away
from a
balanced approach
that recognises
environmental limits
to one
where economic
growth and
development predominate.
This is
at the
heart of
our concerns.
This can
be seen
throughout the
document but
most clearly
on pages
3 to
6 and
pages 18
to 19.
We would
therefore wish
to make
the following
observations about
the content
of the
document:
It
has moved
away from
the historical
and integrated
approach that
promoted a
balance between
environmental, social
and economic
needs. In
the NPPF,
the planning
system is
expected overwhelmingly
to promote
‘sustainable economic
growth’ (paragraphs
13 and
71). Despite
referring the
Brundtland Commission
view in
paragraph 9,
it is
clear that
in this
document the
meaning of
sustainable development
is synonymous
with sustainable
economic growth
and development.
At best
environmental limits
are recognised
as secondary
‘add-ons’ in
making decisions.
The three
elements – economic,
social and
environmental – are
set out
in paragraph
10 but
are not
given equal
weight in
the way
that the
NPPF requires
the planning
system to
operate. A
rebalancing of
the language
and the
meanings attributed
to the
term which
give much
greater weight
to environmental
limits and
concerns is
required.
The
presumption of
sustainable development
that runs
through the
document would
be welcome
if it
was built
upon a
balanced and
integrated view
of the
idea. As
it is,
the presumption
together with
the default
to development
provision in
paragraph 19
and provisions
requiring approval
of development
in the
absence of
an up
to date
Local Plan
(paragraph 26)
and the
requirement for
a rolling
five year
supply of
housing land
with planning
permissions (paragraph
109) will
lead to
pressure for
ad hoc
and haphazardly
located developments.
This will
undermine the
efforts of
local planning
authorities to
guide development
in a
genuinely sustainable
manner.
There
are a
number of
areas where
the commitment
to sustainability
could be
included or
strengthened in
the document:
The
removal of
the commitment
to ‘brownfield
first’ is
a retrograde
step. It
should be
a requirement
of each
local plan
to identify
previously developed
land that
could be
reused. Developers
and local
planning authorities
should be
required to
justify why
they want
to develop
green field
land in
preference to
previously developed
and ‘brownfield
land’.
Reuse of
a resource,
such as
land, is
an important
indicator of
a sustainable
planning policy
and should
be given
stronger emphasis
in the
NPPF.
Equally
there should
be a
requirement for
local plans
to set
thresholds for
affordable housing
on developments
appropriate to
identified needs
in their
area. Having
a mix
of housing
types in
local communities
would contribute
to the
creation of
sustainable communities.
We
are concerned
that the
wording of
bullet point
three in
paragraph 86
where it
states that
“development should
not be
prevented or
refused on
transport grounds
unless residual
impacts of
developments are
severe” will,
when combined
with ad
hoc and
haphazard locations
of development,
undermine efforts
to encourage
and achieve
more sustainable
modes of
transport that
cut emissions.
We
want to
see more
local food
production. Local
Food Networks
can contribute
significantly to
creating a
more sustainable
society. The
reference to
agriculture is
paragraph 167
should assert
more strongly
the need
to protect
productive agricultural
land and
set a
higher threshold
for allowing
(exceptionally) for
it to
be developed.
The
NPPF needs
to be
based on
a clear
and balanced
definition of
sustainable development.
A return
to the
definition used
in the
2005 Sustainable
Development Strategy
document – Securing
the Future
- would
be a
step forward.
This is
superior to
the vague
and misleading
use of
the term
in the
NPPF. A
stronger recognition
of the
environmental limits
within which
the economy
has to
operate would
contribute to
a much
less one
sided view
of the
relationship between
the economy
and the
environment. A
shift away
from the
view that
economic activity
(development and
growth) has
value and
that the
environment is
simply an
‘add on’
with no
real economic
value that
constitutes a
drag on
growth and
development is
essential. There
is a
failure to
recognise the
importance of
‘natural capital’
and the
economic contribution
of environmentally
oriented policies,
such as
the ‘brownfield
first’ approach.
The economic
value of
an attractive
natural environment
and countryside
in attracting
inward investment
in a
particular area
should also
be recognised.
Although
not strictly
a sustainability
concern, the
vagueness and
looseness of
the wording
throughout the
document causes
concern. Far
from simplifying
the system,
it is
likely to
cause conflict
as different
parties battle
over precise
interpretations of
what is
meant in
practical terms
by the
wording of
NPPF. This
will make
it more
difficult for
the public
to engage
with the
system. The
result of
uncertainty is
likely to
be more
planning appeals.
An unintended
consequence could
be that
the system
will become
developer rather
than plan
led. The
loose wording
could thus
lead to
there being
less sustainable
outcomes.
Sustainability
and sustainable
development are
key elements
in an
effective planning
system that
promotes the
development of
a green
and low
carbon economy
and that
reduces greenhouse
gas emissions.
It is
thus critically
important that
the NPPF
has a
proper definition
of sustainable
development that
is based
on long
term needs
rather than
short term
responses to
the current
economic, financial
and housing
crises.
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