National Planning Policy

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. Asa 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 formeasures 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 itspresent 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 awayfrom 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 seenthroughout 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:

1. It has moved away from the historical and integrated approach that promoted a balance between environmental, social and economic needs. In the NPPF, the planningsystem is expected overwhelmingly to promote ‘sustainable economic growth’ (paragraphs 13 and 71). Despite referring the Brundtland Commission view in paragraph 9, it isclear that in this document the meaning of sustainable development is synonymous with sustainable economic growth and development. At best environmental limits arerecognised as secondary ‘add-ons’ in making decisions. The three elements – economic, social and environmental – are set out in paragraph 10 but are not given equalweight 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 greaterweight to environmental limits and concerns is required.
2. 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, thepresumption 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 haphazardlylocated developments. This will undermine the efforts of local planning authorities to guide development in a genuinely sustainable manner.
3. 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 bereused. Developers and local planning authorities should be required to justify why they want to develop green field land in preference to previously developed and ‘brownfieldland’. 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 ofhousing 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 unlessresidual impacts of developments are severe” will, when combined with ad hoc and haphazard locations of development, undermine efforts to encourage and achieve moresustainable 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 paragraph167 should assert more strongly the need to protect productive agricultural land and set a higher threshold for allowing (exceptionally) for it to be developed.
1. 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 Strategydocument – 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 theenvironmental 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 thatconstitutes a drag on growth and development is essential. There is a failure to recognise the importance of ‘natural capital’ and the economic contribution of environmentallyoriented policies, such as the ‘brownfield first’ approach. The economic value of an attractive natural environment and countryside in attracting inward investment in aparticular area should also be recognised.
2. Although not strictly a sustainability concern, the vagueness and looseness of the wording throughout the document causes concern. Far from simplifying the system, it islikely 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 thepublic 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 developerrather than plan led. The loose wording could thus lead to there being less sustainable outcomes.
3. Sustainability and sustainable development are key elements in an effective planning system that promotes the development of a green and low carbon economy and thatreduces 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 ratherthan short term responses to the current economic, financial and housing crises.