The Government’s new National Planning Policy Framework (NPPF) was published on August 17th setting the direction of a whole new generation of local and strategic plans.
The Town & Country Planning Association (TCPA) engaged intensively with the consultation on the draft NPPF and welcomes movement in the final version on key campaign issues such as climate resilience and healthy placemaking. These provide the foundation for both communities and local authorities to drive some important progressive changes to the design of new development.
…movement in the final version on key campaign issues such as climate resilience and healthy placemaking…provide the foundation for both communities and local authorities to drive some important progressive changes to the design of new development.
However, we should not pretend that the overall planning reform framework represents a comprehensive platform for the delivery of long-term sustainable development, particularly climate resilience. Significant challenges remain around the Government’s new presumptions in favour of development which further tips the balance towards the needs of applicants rather than the achievement of public interest outcomes. Neither can we ignore the de-democratisation of planning which continues apace through the implementation of the national scheme of delegation.
Given the extraordinary and growing impacts of climate change on our society and economy one might expect national policy to place that emergency front and centre of our planning system. One should certainly expect a holistic vision of what kind of places that this complex policy is intended to deliver. Sustainable development is identified as the key legal objective of planning but then, as with previous versions, hobbled by paragraph 18 which makes clear that they ‘are not criteria against which every development proposal can or should be judged’ That is precisely, of course how a sustainable development must be applied if it is to be effective.
But despite these important reservations the NPPF is now a reality we all have to work with. Planners and communities must now apply this policy document in making decisions which will determine our future resilience. With that in mind five changes in policy advocated by the TCPA offer the prosect of some positive change:
Setting local energy efficiency Standards (Policy PM13)
The TCPA, alongside other NGOs such as London Energy Transformation Initiative (LETI), has been leading a campaign to defend those local authorities wishing to pursue higher levels of energy efficiency in buildings than currently set out in building regulations. Over the last two years central government has sought to curtail that opportunity, and the consultation draft of the NPPF would have prohibited such policy. The final version of the NPPF expressly allows local plans to adopt energy-efficiency standards beyond Building Regulations where they are justified, robustly costed, viability tested, and use the emissions metrics currently used in Building Regulations (known as TER/SAP).
Although the policy does not reference energy based metrics, which have been used by innovative authorities such as Winchester City Council and West Oxfordshire District Council to achieve truly net zero new buildings, the TCPA believes that the new policy wording provides a window for ambitious and innovative policies that set higher standards for energy efficiency and harness renewable technologies and battery storage. It also means that a new generation of plans can reflect their obligations on climate mitigation by setting ambitious energy efficiency design standards.
Carbon assessment of spatial development strategies (Policy CM1)
The TCPA has long campaigned for national policy to fully reflect the obligation in planning law that development plans must contribute to the mitigation and adaptation of climate change. For the first time the new NPPF expressly supports the carbon assessment of spatial development strategies in line with the objectives and provisions of the Climate Act 2008. This creates a powerful basis for spatial strategies to select locations for development which can radically reduce carbon emissions. It should be read together with the forthcoming design guidance which advocates the importance of carbon mitigation in the detailed requirements for the design and layout of new development.
Requirements on sustainable transport (Policy TR1)
The importance of locating development that can radically reduce carbon emissions is reinforced by the vision led transport section which not only emphasises the importance of climate change but the need to promote development which prioritises walking and wheeling, explicitly references women and girls in street design and crucially introduces more robust transport impact and refusal test. Used robustly this should help end some the worst excess of bolt on, car dependent development which undermines peoples’ health and climate mitigation.
Climate adaptation Policy (Policy CC3)
The TCPA is obviously disappointed that our calls to include surface water flooding in the sequential test have not been adopted. However, there is an important increase in the scope of adaptation measures that should be considered in plan making and decision-taking. After recent events these understandably include the importance of robust policy in relation to wildfires and wider requirements to give substantial weight to the resilience of the built environment. While these requirements will need further guidance, they do allow local authorities to drive the kinds of changes, particularly in terms of how multifunctional green space for sustainable urban drainage systems, fire breaks and public open space can be delivered to create resilient places.
New public health policy (Policy HC4)
The TCPA has long been concerned that national planning policy regarded health and well-being principally as a matter for the creation of healthcare facilities. The new NPPF takes a step towards recognising the importance of planning decisions in shaping a built environment which can promote people’s health and well-being. This significant shift in policy embeds health promotion as a key consideration in the planning system. Policy HC4 is explicit about the need ensure plans reduce health inequalities, improve public health outcomes and improve access to healthy food and recreation.
Accessibility requirements strengthened (H05)
The TCPA has long been concerned to deliver homes which meet people’s needs over their whole lifetime by adopting robust accessibility and design standards. It has always been illogical that planning only requires a limited percentage of new homes to be accessible when everybody, at some time in their life, will benefit from such standards. While the final version of the NPPF does not make a radical change in policy it does now require that no less than 40% of homes on major developments are delivered to M4 (2) building regulation standard. This provides the opportunity for local authorities to argue for a higher proportion of accessible homes, a demand that reflects the reality of our rapidly ageing population.
Garden Cities (Policy H04)
The government has yet to publish its final policy in relations to its new town’s programme. It may be significant that reference to new town design standards have been removed from the NPPF and that the single definition of a strategic site encompasses relatively small-scale development of 1,500 homes. That said, the NPPF continues to advocate for the importance of strategic housing sites as a solution to meeting the need for new homes. It is significant that the NPPF reference to the Garden City Principles, which had been removed in the consultation draft, has been reinstated. That is an important commitment in relation to those many authorities who have developed and adopted policy based on the Garden City Principles, including several members of the TCPA’s New Communities Group.
Making it work
There may have been little interest beyond the planning community in the publication of the NPPF. So far as there is public awareness it appears to be focused on policy around railway stations and securing the future of pubs. But the debate now moves decisively to local and regional government to make best use of the NPPF to secure public interest outcomes. Movement on the key issues set out above provides some important hooks to enable this. This NPPF is not the holistic policy framework the TCPA has advocated for, and there are many polices which we will continue to campaign to improve. But as an organisation dedicated to solutions and practical hope, we will be devoting our time and energy to helping local authorities and communities use the NPPF to drive the kind of outcomes which can deliver a more socially just and climate resilient future.
