Monday, April 23, 2018

The Royal Town Planning Institute and the Draft NPPF

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, 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 ( 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
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

No comments:

Post a Comment