The earlier post on the National
Planning Policy Framework Consultation suggested that this was of paramount importance. I would again urge those interested in land use planning to respond to the consultation before 10 May (and copy their Member of Parliament and professional institute) explaining why the modest changes being proposed would not start to produce a NPPF that would do anything to reverse the damaging changes since 2012 occurring to climate, air, soils, housing, traffic and biodiversity. I would draw particular attention to point 6 below on community led housing, as the official Government position (see the hyperlink) would continue to be meaningless without the NPPF privileging this form of housing.
I made the following notes following a regional meeting of RTPI members on 19 April 2018
1.
The 2012 NPPF can be seen to
have failed in every measure of ‘sustainability’ (and see SDGs); eg.: availability
and affordability of housing, the acceleration towards a ‘mass extinction’ of
flora and fauna, increase in car dependency and decrease in bus usage, no
increase in air quality, no decrease in the probability and severity of
flooding. The first question that needs
to be faced is, what is there in the 2018 version that would secure a reversal
of these trends? The RTPI should have no hesitation in saying that if the
‘presumption’ is to remain in favour of
‘sustainable’ development then such development must be seen to be
sustainable (ie access, carbon emissions, biodiversity, social inclusion
etc). The ‘presumption’ could continue
to be applied to development and lack of sustainability could then be named as
one of the criteria for justifying refusal of permission.
2.
There seems to be serious
confusion as to the future of local planning (see TCPA response). There are
serious flaws and limitations with neighbourhood planning and unless the
Government reintroduces strategic and/or regional planning, the plan-led system
(including the relative certainty provided by s38(6)) appears to be under threat.
3.
The fact that ‘affordable
housing’ is defined as 80% of market rents is another matter of (in)credibility
that requires terms to be changed to relate to reality ie normal English usage.
The Labour (does that make it unacceptable
to this Government?) proposal for Living Rents and FirstBuy related to income
levels is a more honest (and politically attractive?) approach.
4.
The ‘landlords premium’ seems
to indicate that land prices will remain as high as the market will bear, limiting
the ability of development to be carried out at a high standard and at
affordable prices. If the developer is
expected to have a 20% profit for taking the risks involved in delivery, why
should the landowners have substantially larger profits for taking no risk (or just the risk of the land price
inflating still further).
5.
Sajid Javid is
reported as saying that the UK’s housing crisis is, “above all a supply side
problem. At the end of the day, we need to build a lot more homes”. (Interview
with Liam Halligan for UnHerd.com, April 2018).
This should be seriously questioned, given the level of landowners’
profits and demand side stimuli. (ie £10billion to Help to Buy) and the NPPF
should not include any references to increased supply leading to lower prices.
6.
The Government strongly
supports community-led housing (https://www.gov.uk/government/speeches/community-led-housing)
that, contrary to the Minister’s wishes, will simply remain a minority interest
unless this sector is privileged by
plan making and decision taking. All the
significant benefits understood by the (then) housing and planning Minister
will be foregone if the planning system relies on the position of ‘encouragement’
or ‘not being against’ this form of housing.
There could and should be a very significant synergy between community
led housing and the statutory registers of those hoping to be offered a serviced
plot, and likely to be disappointed without being given a substantial impetus
in the new NPPF. The Minister acknowledges that community led housing is
commonplace abroad and the fact that a particular co-housing development which he
mentions took twenty years to materialize,
and most groups give up long before that, are stains on the planning system.
7.
Another sector that requires
assistance through the updating of national policy is that of agroecology and/or
local food production, processing and distribution. This sector has substantial
potential for health/wellbeing, community development, employment, reduction in
food miles, biodiversity, carbon sequestration, flood control and soil health. These are all material planning
considerations which justify a ‘local food policy’ in the NPPF to be replicated
in local plans.
8.
The NPPF should be seen by
Government as one of the main ways in which the 25 Year Environment Plan will
be implemented. This does not currently
seem to be the case. The same applies to
the Clean Growth Strategy.
9.
Another emerging sector that
the land use planning system should be encouraging is ‘forest gardening’. The NPPF should catch up with the view
increasingly being taken that tree planting should be seen as part of a rich,
multi-layered and biodiverse addition to the landscape. Government needs to
understand why it is that despite the apparently sound advice at para 118 of
the 2012 NPPF there continue to be significant declines in biodiversity. The
2018 NPPF should be designed to reverse this trend, or Ministers need to be
aware that plan making and decision taking are failing in this important
regard.
10.
The question of
planning contributing to the reduction of carbon emissions was not discussed on
the advice that there were two experts ‘on the case’. These experts might be
interested in the analysis https://drive.google.com/file/d/0B2VqOwDufNpbeVE3alBCRnJ4NjA/view
11.
There
seemed to be general agreement that the opportunity to actively plan to secure
the potential benefits from electrification and automation was being missed.
The TCPA has submitted a
very powerful critique of the draft NPPF. It would be disappointing and
potentially damaging to the credibility of both organisations if they are seen
by Government to be too far apart on the main issues of housing, climate change
and biodiversity
