Today we submit our final response to the Government’s consultation on a revised National Planning Policy Framework (NPPF) for England. You can see our previous commentary on it here and here.

The changes to the NPPF are wide-ranging, and most aim to deliver a significant increase in the supply of new homes. As I pointed out previously, this is understandable given the importance of housing to this Government and to people personally, who struggle to own or rent a home. 

However, biodiversity declines continue unabated across England and the rest of the UK. The State of Nature 2016 report showed that between 1970 and 2013, 56% of species declined and urbanisation was one of the key drivers of biodiversity change, with a largely negative impact. 

The Government has clearly worked hard to try to address these tensions through the NPPF review. However, its balance is tipped in favour of housing – indeed the pro-development tone of the framework is set in the first paragraph.  There’s further work to do to ensure that the final NPPF results in high quality developments in the right location, and isn’t just a numbers game. 

It’s also a missed opportunity to set out a vision for the kind of country we want to see. This is in marked contrast to the situation in Wales, where the Welsh Government is also consulting on its equivalent of the NPPF, Planning Policy Wales (PPW). PPW introduces the concept of place-making, which runs through to the preferred option for the successor to the Wales Spatial Plan, the National Development Framework. While it’s not perfect, we think PPW (now in its tenth version) is a more balanced representation of how planning can contribute to sustainable development than its predecessor. We warmly welcome the step change in environmental consideration which shows planning’s great potential to contribute towards our well-being goals, and thereby sustainable development, and to maintaining and enhancing the resilience of ecosystems.

Unlike Wales, we’ve never had a national spatial plan in England, which could provide an effective framework for spatial planning at the local level, and at the same time help integrate and deliver other public objectives, including for the natural environment. In light of the housing crisis and competing demands for the use of land, particularly in the South East of England, we call on the Westminster Government to develop a National Spatial Plan to address this failure, as we argued in this report at the time of the first NPPF.   

We also call for an NPPF that:

•             Recognises the role of the planning system in delivering the Sustainable Development Goals in England.

•             Expands the list of environmental assets in the ‘presumption policy’ to include National Nature Reserves, Local Wildlife Sites and Priority Habitats.

•             Gives clear and appropriate weight to other environmental assets. 

•             Requires planning authorities to plan effectively for all strategic priorities, not just housing.

•             Places a stronger emphasis on the need for Local Plans and local policies. 

•             Sets out clearly how environmental constraints should be taken into account in determining housing figures, recognises that it will not always be possible to meet need in areas of constraint and provides clarity on what to do in these circumstances to ensure a consistent approach.

•             Makes clear that the Housing Delivery Test relates to the final housing figure once constraints have been built in and provides scope to apply the test flexibly.

•             Includes a new policy on Nature Recovery Networks.

•             Provides a clear and unambiguous definition of irreplaceable habitats.

•             Provides the same level of protection for ancient woodland and aged and veteran trees.

•             Reinstates the requirement for criteria-based policies for wildlife sites and maintains protection for local sites of importance to nature conservation, including Local Wildlife Sites.

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