On the National Planning Policy Framework (NPPF)

Earlier this week I was asked by a journalist from Building Design ‘what does the NPPF mean for architects?’ This caught me on the hop, despite the fact that I’ve been meaning to write something on the NPPF for some weeks now. Just in case you missed it, the NPPF is a new 50-page document which the government intends will replace over 1,000 pages of Planning Policy Guidance Notes and statements (PPGs and PPSs) as the overarching guidance on planning policy and development control – sorry; development management, in the new parlance.

Speaking as a practitioner, having all central-government planning-guidance in a single document, readable in one short session, is a laudable aim – but its publication in draft/consultation form in the tail-end of the summer holidays, stirred up a hornet’s nest of excitement rivalling those around the aborted national forest privatisation and the heavily re-worked NHS/GP commissioning reforms.

What got the National Trust et al so worked up is the document’s repeated use of the phrase ‘presumption in favour of sustainable development’, which should, apparently, ‘be seen as a golden thread running through both plan making and decision taking’ (paragraph 13 in the document). This presumption has been portrayed by the NPPF’s critics (especially those who have not actually read it) as the government giving a green light to all ‘green-washed’ development, on all green-field sites, including in the green-belt.

I have read the document a number of times and in reality it seems substantially less exciting than the furore it has generated. Each local planning authority will still have to prepare a properly consulted-on local plan and determine planning applications in accordance with it (para.14). The Core Planning Principles (para.19) include a requirement that:

‘planning policies and decisions should seek to protect and enhance environmental and heritage assets in a manner appropriate to their significance’

…and that:

‘planning policies and decisions should actively manage patterns of growth to make the fullest use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable’.

This is reinforced later:

‘Planning policies and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised’.

The document continues the presumption against new isolated dwellings in rural areas (para.112), spells out continuing protection for the green-belt (paras.133-147), considers the need to protect the viability of town-centres (para.76) and maintains a ‘sequential approach’ for large-scale retail and leisure development (paras.77-79) – i.e. requiring that town-centre then edge-of-centre locations should be considered before out-of-town locations.

So far, so business-as-usual. What of this ‘presumption in favour of sustainable development’ which has so disturbed the National Trust. Well my reading of the document is that this is mostly a rhetorical device (a ‘golden thread’?!) which has backfired badly on the NPPF’s authors. The main area where the presumption will come into effect is (para.14):

‘where the local plan is absent, silent, indeterminate or where relevant policies are out of date’

The NPPF’s critics point out that many local authorities have not yet completed their new-style Local Development Frameworks (the last government’s ‘radical shake-up’ of the planning system) – 43% are work-in-progress according to one source, and with the NPPF requiring local authorities to increase all their housing supply targets by 20% (para.109), its most out-spoken critics maintain that all local plans are now out of date. More moderate commentators are arguing for a ‘period of grace’ – a year perhaps – to let local authorities focus on completing their plans, before developers and their legal teams set to work testing the new NPPF with a barrage of appeals. The devil in the NPPF will be its lack of detail!

If the presumption in favour of sustainable development does come in to play, the word ‘sustainable’ is a poor defence against harmful development argues the National Trust and its supporters, and they have a point: the NPPF defines ‘sustainable’ only with the Bruntland Commission’s rather vague: ‘Sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs’.*

For what it’s worth, I do think the NPPF should state the case for the protection of the countryside more clearly. The current national planning strategy – limited, sustainability-driven growth in villages, an emphasis on re-using brownfield land and major new development provided as relatively dense (‘walkable’) mixed-use new settlements, served by good public transport and cycle paths (see Norwich’s tri-district ‘Joint Core Strategy’ for example) – is broadly the right way forward. This should be spelled out more clearly in the NPPF and we should then focus our thinking on how such new sustainable communities can be delivered more quickly and to a higher standard of design – in spite of the inevitable NIMBY-ism.

So what does the NPPF mean for architects? Well, assuming the document is as benign as its supporters suggest, the answer is not a great deal; it heralds business as usual – despite the rhetoric. If the National Trust is right, the NPPF will be the start of a new era of peri-urban and rural sprawl, comparable to that which created the dormitory villages such as Frettenham in the 1960s and 70s. In this case, there will perhaps be more work for architects, but I fear this will mean simply more, not better work; there’s little in the NPPF’s section on design (paras.114-123) to suggest a step-change in quality. If the sprawl scenario does emerge, we will be participating in something that may well be judged very harshly indeed by the ‘future generations’ which the Bruntland Commission implored we should bear in mind as we satisfy our own push for growth.

*The World Commission on Environment and Development (The Brundtland Commission) report to the United Nations, 1987.

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