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Simon Marsh

On Monday, after what felt like a never-ending process of drafting and honing, we submitted our response to the Department for Communities and Local Government’s consultation on the controversial draft National Planning Policy Framework. 

Our response was formed of three parts.  The first was our consultation response in which we answered relevant consultation questions.  The second was our proposed track changes to the draft text of the NPPF (not our usual approach, but apparently that preferred by officials at CLG).  The third was our legal advice on SSSIs from Nathalie Lieven QC.

In a nutshell, we declared the NPPF unfit for purpose and set out the major concerns we have with the document:

  1. As it stands, the presumption in favour of sustainable development is little more than a presumption in favour of development. Significant amendment is required in order to ensure it encourages sustainable development, and to avoid undermining important protective policies, such as those for SSSIs.
  2. The presumption should link back to a robust definition of sustainable development based on the principles of the UK Sustainable Development Strategy (Securing the Future, 2005), including the need to live within environmental limits.
  3. The NPPF as currently drafted would make it significantly harder to refuse environmentally-damaging development, including those that threaten nationally-important wildlife sites. The RSPB has obtained legal advice that the draft NPPF would undoubtedly lessen protection for SSSIs not protected by European law. Nor does the NPPF adequately reflect evidence about the economic value of the natural environment and the need to value it accordingly in decision-making.

The real battle, of course, lies ahead.  We have many months of discussions with officials and ministers ahead of us.  Our team here worked extremely hard at our response, and we consider it to be well-thought out and balanced. We believe our proposed amendments would put provide the appropriate protection and enhancement of our natural environment, whilst allowing the homes and businesses we so urgently need.

Let’s hope government agrees!

If you’re really keen, you’ll soon be able to download our full response to the consultation from this page.