Yesterday, the Westminster government launched its long-awaited draft of the National Planning Policy Framework (NPPF), and a full public consultation that will run until 17th October.
Whilst this type of Whitehall paper-pushing can seem irrelevant to day-to-day life, it will have the potential to influence what happens to the nature close to you, from local parks to internationally designated wildlife sites.
As anticipated, and indeed, as leaked, the NPPF is largely based on the earlier practitioners’ advisory group draft. It is, of course, no secret that I sat on the practitioners group – in fact I’ve blogged here before on what was a fascinating, if at times uncomfortable, experience.
With a range of diverse and conflicting views represented, the draft text we ended up with was inevitably a compromise. In other words, the practitioners’ advisory group draft of the NPPF was not my perfect NPPF – far from it – and as I was acting in personal capacity on the group, it certainly wasn’t the RSPB’s perfect NPPF.
Since the practitioner’s draft was published, the Department of Communities and Local Government (CLG) has been beavering away to turn it into an official government draft. This has meant changes not only from CLG itself, but from other departments across government, including those who don’t place a high value on either the environment or the planning system. The structure is broadly the same, as are many of the passages, but amongst the detail is a markedly different emphasis for the planning system.
Firstly, I should say that we welcome the positive remarks made by Greg Clark about the role of the planning system in protecting and restoring England’s natural environment in his ministerial foreword. We wholeheartedly agree with this sentiment, but we are concerned as to whether the draft NPPF will be able to achieve this type of restoration on the scale necessary to achieve the ambitions set out in the government’s Natural Environment White Paper.
Our first, and overriding, concern, relates to a profound shift in emphasis for the planning system, centred around the so-called ‘presumption in favour of sustainable development’. A tricky concept to bring to life, in principle this sounds good, but in practice? Well, let’s just say it has raised many eyebrows!
Ideally the presumption in favour of sustainable development would be just that – a presumption that unless development can prove it is sustainable, against a robust series of tests, it should not go ahead. This version, however, reads more like a presumption in favour of development, with the ‘sustainable’ tacked on to please the greenies.
This profoundly misses the point. Unless our much-needed economic growth is truly sustainable, we will be setting up problems for ourselves, our children and our grandchildren.
The draft establishes a reasonable (if not fantastic) definition of sustainable development at the outset, but then the presumption clearly places one ‘pillar’ of sustainability – economic growth – higher than the others as an objective for the planning system. This inconsistency is carried through the entire draft, and is a shift away from the current approach of the planning system which seeks to give equal weight to environmental, social and economic needs in decision-making.
What would this mean in practice? Basically, it could make it much harder for a local authority to refuse permission for a proposal that would damage the natural environment, unless someone is able to show that the ‘adverse impacts of allowing development would significantly and demonstrably outweigh the benefits’. And that doesn’t sound straightforward.
Our second concern relates specifically to the measures outlined in the NPPF to support and encourage the restoration and enhancement of the natural environment. Whilst there are some welcome policies on this in the draft text, they do not go far enough to achieve the ambitions set out either in the government’s Natural Environment White Paper, or in Greg Clark’s own foreword.
For example, local authorities are encouraged to work collaboratively on strategic planning priorities with Local Enterprise Partnerships, but why not also with Local Nature Partnerships, the natural environment equivalent?
But, it isn’t all doom and gloom. There’s real potential to make something positive out of the NPPF if government listens to the public and environmental NGOs like the RSPB during the consultation. For example, the NPPF establishes the right for local communities to identify areas of Local Green Space for special protection – and these could include local areas important for wildlife and people’s contact with nature.
Later today we will be asking our members and supporters to respond to the consultation as part of our Stepping Up for Nature campaign.