We are increasingly concerned that we are not hysterical enough in our comments on the NPPF. How are we to get a hearing amid the strident voices of the National Trust and the CPRE, aided and abetted by the Daily Mail and the Daily Telegraph? Ms Sadek will apply herself to that question in her blog. Meanwhile we keep going at asking the rational questions expecting some rational answers.
In our first piece we were left with two questions. The first was:
- How will slimmed down centralist policies really interact with local choice?
This was in part a technical question about the way the NPPF would be introduced and relate to existing plans and in part a question about the way all the differing actors in the planning system would respond.
Technically it seems to be fairly simple. Sometime early in 2012 when the final version of the NPPF is published it will become a “material consideration” and applicants and decision makers will have to take the usual balanced judgement about all the relevant factors. Plan makers will have to take a view about whether their plans are in “general conformity” with the NPPF policies and review them if not. CLG are looking at how that review process can be simple and proportionate.
There is still some way to go on the detail but that does not look like the death of planning as we know it or the end of all green fields.
The NPPF raises the significance of the Local Plan itself by the removal of much planning policy and guidance at a national level, and changes at local level including the introduction of “Neighbourhood Plans”. The slimmed down NPPF leaves a freedom for more choice; local authorities (and hence local people) can decide what they actually want in their area and how they will interpret sustainable development.
The problem with leaving local authorities with that freedom of choice is absence of good local plans in half the councils in England. They will suddenly find that planning approval is to be assumed. And that presumption applies “wherever the plan is silent, indeterminate or where relevant policies are out of date”.
The phrase “up-to-date” is used in a number of circumstances: paragraph 26, 27, 28 for example. The NPPF however fails to give clarification of the meaning of up-to-date in the framework. There is clearly a desire to avoid over prescription in the NPPF but this may be one aspect were it would be useful provide a definition in order to reduce ambiguity.
The National Housing Federation call the NPPF a ‘hugely significant milestone’ and welcome the priority put on meeting of housing need and demand. They argue this, underpinned by the robust presumption in favour of sustainable development, can help achieve a long overdue step-change in building more affordable market homes.
Hardly a day goes by at the moment without another reminder that the UK is on course to build less than half of the 240,000 homes needed each year to meet shortfalls The NPPF sets the threshold for rejecting development extremely high and development will go ahead unless a local authority can prove that it gives rise to many problems across all the areas covered by the NPPF in order to encourage development. 60,000 new homes are required every quarter in order to meet the current housing shortfall. This is a staggering number compared to how many houses per year are being built. The housing pipeline report published last week shows the number of planning applications for social housing projects was just 3,200 in the first quarter of 2011 and private housing appeals have seen a 20% decline from last year. The question needs to be addressed how to meet the changing market conditions. A change in the planning system will not necessarily meet this as market conditions and a lack of confidence in the housing and banking sectors are largely to blame. UK Regeneration is geared towards providing affordable, rented housing as there has been a shift from home ownership to long term renting. In order for the country to grow economically and rebuild its housing industry planning cannot assume a default ‘yes’ answer to development is going to be the answer. It needs to look more deeply into market conditions, such as current trends of home ownership and renting and tailor the NPPF to this.
There has been a clear desire over the last few years to make planning a positive force rather than simply a control valve, apparently frustrating activity. The NPPF continues this trend by emphasising that plans should aim to “meet” the needs of development in local areas. However this still requires someone – developers, local businesses or whoever to deliver development activity, funded and managed in a way that works for both investors and consumers.
So back to the hysteria. Almost any system (ie the laws and the processes) of land use planning can be used to deliver almost any outcome. This is a battle of wills and culture. Are we to be a country which only looks backwards, opposing change at every opportunity? Or are we to find ways of creating better places to live and adapting and improving the places we already have.
Slimming down the central prescription (“Very brave, Minister” must have been said at some stage) offers the chance to have a much wider variety of differing responses. Shades of grey rather than black or white. Professionals and all those involved in the industry have to create offers that persuade. The real debate is why this has not happened more – not about a few words in a strategy document.