Does the NPPF adequately define 'sustainability'?
Will NPPF open a Pandora’s box of unsustainable development?
Yes, says Liz Peace, it’s time to stop arguing and get on with it; while Fiona Howie thinks the definition need to be made absolutely clear
Yes
I started off thinking that we probably did need a more detailed definition of sustainable development than is set out at the beginning of the draft National Planning Policy Framework. But then I re-read the document more closely and the penny dropped. The NPPF does exactly what its title says and, when taken as a whole, provides a comprehensive framework for achieving sustainable development against which local planning authorities should be drawing up their plans and, where they have failed to do, against which applications should be judged.
In its 52 pages it covers just about everything that needs to be taken into account to create environments that actually work and in which communities can thrive — from design to transport links, from land conservation to biodiversity and from pollution risk to economic viability. And it wraps all that in the widely accepted Brundtland definition about meeting the needs of the present without compromising the ability of future generations to meet their needs, which it then further defines as integrating economic, social and environmental considerations.
It is difficult to see what more could be included. Nor is any more detailed definition going to stop disputes, appeals and judicial reviews. More words simply provide more to argue over. So let’s stop this theological debate and get down to what really matters: drawing up sound plans that provide for a sensible balanced outcome in our small island and allow us to provide jobs, homes and communities in a way that doesn’t cost the earth.
No
One of the problems with the draft National Planning Policy Framework is that the definition of sustainable development is too high level and the policies do not articulate what the term should mean in practice for local decision makers.
If you ask a developer they might argue that it’s about speeding things up and getting things built. If you talk to environmental groups we’ll tell you it’s worryingly vague and weighted in favour of economic growth.
The presumption says proposals should only be rejected if their adverse impacts “would significantly and demonstrably outweigh the benefits, when assessed against the NPPF as a whole”. Yet the document when taken as a whole contains so many contradictions that it is rendered almost meaningless. Any proposed development can and will be argued to be sustainable. The resulting disagreements will lead to legal appeals and considerable delays.
Including a clear definition of sustainable development would provide clarity. The government already has workable principles for sustainable development set out in the 2005 report Securing the Future and these should be restated in the NPPF.
By making it crystal clear what sustainable development means, and where the burden of proof lies when it comes to proving a proposal for development is sustainable, the government would go a long way to reassuring its critics and speeding up the planning system.
What do you think?
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Readers' comments (1)
The draft National Planning Policy Framework (NPPF) promises to be the biggest reform to the planning system in England in 50 years. It is planned to replace all the existing national planning policy statements and guidance including regional special strategy plans, and is expected to come into force in April 2012.
The aim is to make the planning system more straightforward, transparent and accountable. In support of this, the Department of Communities and Local Government have claimed that in producing a concise National Planning Policy Framework they are condensing 1,000 pages of planning guidance.
“The Framework will replace the current suite of national Planning Policy Statements, Planning Policy Guidance notes and some Circulars with a single, streamlined document.”
“The Framework condenses the near 900,000 words of national planning policies (over 1,000 pages) into a user friendly and accessible document which can be understood and used by everybody who has an interest in shaping the development of their area.”
Reforms introduced in the NPPF promise to give communities unprecedented power to influence the shaping of their neighbourhoods, with the underlying requirements that there should be constructive dialogue and also a presumption in favour of sustainable development. This provides substantial opportunities for developers and home builders able and willing to meet these conditions. It may also mean that projects that have previously been refused, even dismissed at appeal, may successfully be revisited provided that dialogue and sustainability can be demonstrated.
From the community point of view, it is to be hoped that constructive engagement and dialogue will result in an increased sense of community, better use of existing infrastructure and underused or empty buildings as well as greatly improving the standards of new developments, in terms of space planning, energy consumption and environmental considerations.
Presumption in favour of sustainable development
Quoting directly from the NPPF it is clear that the key concept behind the new policy is a presumption in favour of sustainable development.
“All plans should be based upon and contain the presumption in favour of sustainable development as their starting point, with clear policies that will guide how the presumption will be applied locally.”
Additionally, there is a requirement on the Local Authority to work with applicants in finding solutions to overcome any substantial planning objections as long as proposals are seen to be sustainable:
“At the heart of the planning system is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan making and decision taking. Local planning authorities should plan positively for new development, and approve all individual proposals wherever possible.”
“In considering applications for planning permission, local planning authorities should apply the presumption in favour of sustainable development and seek to find solutions to overcome any substantial planning objections where practical and consistent with the Framework.”
What Is Sustainable Development?
Some have criticised the NPPF for not defining fully what constitutes Sustainable Development.
Instead, the NPPF has placed the onus on local authorities and neighbourhoods to define what constitutes sustainable development in the context of ‘Neighbourhood Development Plans’.
In paragraph 8 of the NPPF we find:
“Sustainable development means development that meets the needs of the present without compromising the ability of future generations to meet their own needs. It is central to the economic, environmental and social success of the country and is the core principle underpinning planning. Simply stated, the principle recognises the importance of ensuring that all people should be able to satisfy their basic needs and enjoy a better quality of life, both now and in the future.”
So sustainability is far more than just energy efficiency or ‘add-on’ technologies claiming renewability.
It is also concerned with economic growth, historic context, transport, community infrastructure, space standards, ecology and more. It must be seen as contextually specific to the site or neighbourhood, and therefore it is appropriate not to rely on a single definition but to allow this to be defined appropriately at local level.
Some fear that the absence of a single definition of sustainable development may lead to uncertainty, confusion and a period of planning by appeal. Where local authorities or neighbourhoods have failed to create a local detailed framework for planning in their locality, the onus will be on developers to demonstrate ‘sustainability’ using their own definitions.
Under these circumstances developers will probably utilise the existing BREEAM, the Code for Sustainable Homes, and SBEM/SAP Energy Assessments. However an important point is that the emphasis on sustainable development requires far more than the manner in which a property is constructed, and the level of compliance may well be set fairly low with little thought to wider contextual considerations. This may lead to objections at local level with a large amount of developments being refused locally and subsequently granted at appeal.
Sustainability relates to economic and social planning as well. Neighbourhood plans should consider in the economic role planning for prosperity (business and economic development, transport, community infrastructure, minerals) and in the social role planning for people (housing, design, sustainable communities, historic background, and environmental issues such as the “green belt”). Without a Neighbourhood Plan, the framework is clear:
“Local authorities should ... grant permission where the [local] plan is absent, silent, indeterminate or where relevant policies are out of date.”
“In the absence of an up-to-date plan, planning applications should be determined in accord with this Framework...It will be open to local planning authorities to seek a certificate of conformity with the Framework.”
It is clearly very desirable for Neighbourhood Groups and Local Authorities to work closely with Architects, BREEAM/Code for Sustainable Homes Assessors and SBEM/SAP Assessors to address sustainability issues and set appropriate standards within their own localities.
Good Design
The importance of ‘Good Design’ is also incorporated as a cornerstone within the NPPF and is regarded as inextricably linked with sustainability.
“Good design is indivisible from good planning and should contribute positively to making places better for people. The Government’s objective for the planning system is to promote good design that ensures attractive, usable and durable places. This is a key element in achieving sustainable development.”
Considerations such as minimum space standards, access, storage provision, as well as contextually appropriate aesthetics all become important considerations. This promises to give proactive Local Authorities and Neighbourhood Groups the chance to ensure the end of unimaginative “little boxes” housing developments and soulless commercial development. It represents an opportunity for local community/neighbourhood groups to have a huge influence in defining the architectural character and quality of their area.
The emphasis on good design is an admirable aspiration and fantastic news for Architects, Neighbourhood Groups and forward thinking developers.
Jonathan Braddick – RIBA Chartered Architect Devon
www.jonathanbraddick.co.uk
With huge thanks to Graham Gover Solicitor for his expert planning knowledge and advice.
http://www.ggsolicitor.co.uk/