BLOG: Planning policy is still not up to scratch on sustainability
The National Planning Policy Framework is a crucial lever of government policy, which dictates the physical places and spaces in our everyday lives – and therefore has a huge impact on sustainability and the green economy. There is still a window of opportunity to influence the crucially important draft revision, which progressive businesses, local authorities and NGOs need to grasp with both hands.
In recent government pronouncements on housebuilding and development, it’s noticeable that ‘design’ seems to be back on the agenda. Sajid Javid said “quality is as important as quantity when it comes to building the homes we need”. This is to be welcomed.
On closer inspection though, there is a fairly narrow interpretation of what good design looks like – and environmental sustainability does not come off well. This is reflected in the revised draft of the NPPF where there are some subtle changes and missed opportunities which need to be challenged and addressed. I will highlight three (there are more).
Firstly, and perhaps most fundamental of all, the definition of sustainable development within the revised draft is too vague and weak. Unlike the current NPPF, the definition ignores the 2005 UK Sustainable Development Strategy and the obligations of the UN Sustainable Development Goals, which are clearly articulated as government objectives in the 25 Year Environment Plan.
Not only is the definition weakened, but the draft then goes on to make clear that even these weakened objectives “are not criteria against which every decision can or should be judged”. So, if that pesky issue of sustainability gets in the way, well – maybe don’t worry about it?
This represents a significant weakening of the wording of the current NPPF, which states that the economic, social and environmental roles of the planning system should not be “undertaken in isolation, because they are mutually dependent….economic social and environmental gains should be sought jointly and simultaneously”.
Secondly, the NPPF doesn’t recognise the important emergence of social value as a concept that is being increasingly applied to the planning and development process by trailblazing local authorities and developers. This is a topic UKGBC reported on just last month. Social value is a means of articulating and quantifying the impact that development has on residents, businesses and other stakeholders in a community – which might range from jobs and apprenticeships to reduced energy bills, resilience to flooding or health and wellbeing benefits.
Delivering social value should be set out as one of the overarching ambitions of the National Planning Policy Framework and planners encouraged to utilise it as a tool for ensuring good outcomes for communities.
Thirdly, the draft NPPF reinforces perceived limitations on local authorities to drive higher energy performance standards in new homes through planning – but does leave the door ajar for a different approach.
Currently, there are multiple interpretations by local authorities of the requirements or limitations on them. Some believe they cannot go further than Building Regulations. Others believe they have free reign. This is a complex area, and we have produced guidance, as well as taken informal legal advice, and published recommendations in conjunction with Core Cities UK. But in an age of devolution, metro mayors and strong city leadership on climate change, it is surely perverse to artificially limit the powers of local authorities.
With local authorities now showing an appetite to move forward collectively and consistently (always a legitimate concern of developers) the time has come for MHCLG to clarify its position, and enable and encourage leadership from local authorities to help us meet our carbon targets.
A final thought. This is of interest beyond just the NPPF itself. To what extent does the BEIS Clean Growth Strategy and Defra 25 Year Environment Plan carry weight with MHCLG? For a department often maligned by green campaigners as a blockage to any progressive planning policy, this is a crucial test.
John Alker is Director or Policy and Places at UKGBC. Follow John on Twitter.