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CPRE’s initial analysis of the National Planning Policy Framework

27 March 2012

The intrinsic value of the ordinary countryside is recognised. The intrinsic value of the ordinary countryside is recognised. Photo: © Gail Johnson/Shutterstock

The Campaign to Protect Rural England (CPRE) believes Ministers have made significant progress towards meeting the concerns raised by rural campaigners about the draft planning framework published last year, making some vital improvements that should achieve better planning outcomes.

We are pleased with the direction of travel on several of our key priorities, including the recognition of the value of undesignated countryside, the definition of sustainable development and the explicit acknowledgement that use of brownfield land is a core planning objective. Ultimately, however, the proof of the new policy framework will be how it works in practice. We and our supporters up and down the countryside will work with the Government, local authorities and communities to try to secure the best results for what Planning Minister Greg Clark rightly referred to today as ‘our matchless countryside’.

Our initial statement is available here: http://bit.ly/GU1Usb .  Looking at the National Planning Policy Framework (NPPF) in more detail, CPRE has broken applied a ‘traffic light’ assessment to the key issues - Green (improved/good), Amber (unchanged/caution) and Red (poor/area for concern):

KEY ISSUES

Green: The undesignated (ordinary) countryside
The draft NPPF made no reference to the intrinsic value of the more than 55% of English countryside not in a National Park, Green Belt, Site of Special Scientific Interest or other designated site, but nonetheless of huge value to millions of people who live in, visit and enjoy it. So we are delighted that Ministers have heeded our campaigning, and included as one of the core planning principles recognition of 'the intrinsic character and beauty of the countryside' which applies whether that countryside is specifically designated or not. This will not mean no development in the countryside, but it will help ensure that building on green fields is not an option of first resort.

Amber: Brownfield
We commend the Government for acknowledging explicitly that using previously developed (brownfield) land should be a core planning objective. Making sure that land is used effectively is essential if local authorities and developers are going to deliver genuinely sustainable development.

The wording in the NPPF falls short of the existing guidance, however, in that it does not require brownfield sites to always be developed before greenfield ones. We will therefore be monitoring very closely how this policy is put into place on the ground to ensure that greenfield is not being developed when alternative brownfield options are available.

Amber: Sustainable Development
The draft NPPF made no reference to the existing (2005) UK Sustainable Development Strategy or to the five guiding principles of that document. The final version rectifies this by including a box summarising the 2005 Strategy, and is stronger on achieving the environmental and social aspects of sustainable development at the same time as economic growth. There is a continued lack of clarity, however, as to what sustainable development actually means in practice, and no suggestion that environmental limits in the UK (as opposed to the global) context should be identified or respected.

The presumption in favour of sustainable development has been helpfully qualified, however, in comparison to the draft. There is no reference to a default ‘yes’ to development and applications should only be approved where they are either clearly in line with Local Plans or are demonstrably sustainable. It is also made clear that the presumption does not override policies protecting the Green Belt or other important areas of landscape.

Red: Economic Emphasis
While much of the alarming language in the draft, such as the 'default yes' to development, has been removed, the final NPPF contains some worrying wording on economic development. Paragraph 19 refers to the need for 'significant weight' to be placed on the need to support 'economic growth' and suggests that planning is an 'impediment' to such growth.  Our research shows there is little evidence to support such a contention and that planning brings huge, long term benefits to the economy.  Local planning authorities need to be able to refuse proposals for economic development in the wrong places and to steer it to appropriate locations.

OTHER ISSUES

Green: Light pollution and tranquillity
CPRE welcomes the inclusion of policies to enable local authorities to combat light pollution, by encouraging good design, planning policies and decisions to control lighting. We hope that more local authorities will now seek to limit the impact from artificial light on local amenity, intrinsically dark landscapes and the natural environment. CPRE also welcomes the first reference in national policy to the need to identify and protect areas of tranquillity for their value for recreation. We will work to ensure effective implementation of this policy to protect and enhance areas of tranquillity for their contribution to health and quality of life.

Green: Plan-led system
We warmly welcome the NPPF’s clear reiteration of the law that decisions on development must be taken in line with locally agreed policies unless other relevant issues indicate otherwise. We are pleased that where neighbourhood plans are drawn up in line with local policies, development will have to conform to the policies in those plans.

We welcome the Government’s positive response to calls to allow local authorities time to get their local plans up to date before the presumption in favour of sustainable development kicks in. It will nonetheless be a significant challenge for many resource-strapped authorities to get their plans right within the 12 month deadline.

Red: Housing
Government has continued with its misguided approach to requiring the planning system to make available a 5 year supply of “deliverable” housing land and adding additional “buffer” requirements (5 or 20 % now judged on house building performance of planning authorities). The Government needs to recognise that planning can’t actually deliver hew housing, only make sites available.

This overall approach to land supply is not new, but the additional buffer requirement is.  It could significantly increase pressure to develop easy, lower cost, greenfield and rural housing sites instead of, or in addition to, planned developments and brownfield regeneration.


End

Notes to Editors
[1] Department of Communities and Local Government, National Planning Policy Framework, 27 March 2012 http://www.communities.gov.uk/publications/planningandbuilding/nppf

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