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NPPF - RTPI responds

27 March 2012

Colin -approved _small _172x 258RTPI President Colin Haylock said: "Overall, the Government has listened to the RTPI and others and the NPPF is a significant improvement on the draft. In particular we welcome the strong emphasis on local decision making to achieve the three aspects of environment and social aspects of sustainable development and to do this through up to date plans.  The challenge for all of us is to make this work with constrained resources."

The National Planning Policy Framework has been published.

Rt Hon Greg Clark MP speech is here.

Letter from Chief Planner is here.

Technical guidance on flooding and minerals here.

Listen to Colin Haylock on Radio Five (2 hours 19 minutes in).

Our key points

What we said when the draft came out and what we think about the NPPF, and what our position is now.

1. Managing the Change: The changes proposed in the draft NPPF are significant and cannot practicably be assimilated by councils, developers or communities in the intended timetable without unintended consequences – as with the implementation of the proposals of the Localism Bill, there is a need for careful change management including a transition phase.

Yes, the Government has announced transitional arrangements. The Rt Hon Greg Clark MP said: \"I have introduced transitional arrangements suggested by, and agreed with, the Local Government Association. They accord weight to plans according to how advanced they are. However, I have gone further in two respects. I have allowed 12 months from today for existing plans to be adjusted to be in complete conformity with the new framework, and made clear that weight can be given to emerging plans."

The choice of 5% (rather than 20%) extra housing supply helps authorities get up to date plans.

2. Language: Large parts of the draft NPPF policies are ambiguous, as is evidenced by the different interpretations put on policies by government, conservation bodies and others. 

The language is improved but still includes various versions of \"sustainable\" : \"sustainable economic growth\" (18) \"sustainable growth\" (Presumption in Favour of Sustainable Development: In principle, this is an evolution of the existing presumption in favour of development that accords with a development plan, but contains weaknesses that may result in unintended consequences.19) as well as sustainable development.

3. Presumption in Favour of Sustainable Development: In principle, this is an evolution of the existing presumption in favour of development that accords with a development plan, but contains weaknesses that may result in unintended consequences.

Whilst it is not the version we and the Select Committee suggested,  the definition in the NPPF is better than in the draft.

Paragraph 7 sets out a helpful three legged approach to sustainable development, which helpfully drops the obscure \"3 Ps\" and uses commonly understood language. The 2005 definition is noted a box, but not applied. 

4. The NPPF as a spatial plan: The NPPF misses an opportunity to express a vision for the development of the country as a whole, recognising the different impacts policies are intended to have in different parts of the country, which runs counter to government commitments, such as that \"prosperity must be shared across all parts of the UK\".

The NPPF is not a spatial document. In fact it is not a national planning framework at all, but a series of prescriptions on how localities produce their own frameworks.  As a result it is not clear how it relates to the NPSs or to HS2 for example. It doesn't address the kinds of issues raised recently in the Sunday Telegraph for example (ie where the housing growth will be).  People need to be able to debate these issues. The RTPI recently launched a campaign arguing for a Map for England which would provide easily accessible data on these matters  – see

5. The relationship of the NPPF to the Localism Actl: The status of and procedures for producing and reviewing the NPPF need to be embodied in statute to ensure proper public debate of issues and restore democratic accountability through Parliament, as is the case for National Policy Statements (NPSs) for infrastructure.

Pressure has resulted in three debates in Parliament about the draft, scrutiny by two select committees and extensive media scrutiny and comment.

Additionally, the Rt Hon Greg Clark MP said: \"Having shaped the development of the new framework, I will ensure that Parliament supervises the implementation of the policies starting with a debate on the floor of the House soon after we return."

The NPPF was not embodied in the Localism Act.

6. Promoting real positive planning: The draft NPPF exhorted councils to undertake positive planning but does not afford planning, and plan making in particular a truly holistic role. It focused on providing a basis for determining planning applications rather than place shaping . It seemed to regard spatial planning as having no role in influencing any parallel strategies at either national or local level.

There are improvements to the draft here. For example in para 17 the government says that planning is \"not simply about scrutiny\".  However the NPPF still seems to regard planning  as a largely receptive activity rather than a driving  force.  For example in para 17 it says that planning should  \"take account of and support\" Health and Well Being Strategies. Surely it should be saying that planning  should  \"shape\" HWBs.

There is a potential mention of coordinated provision of public services in towns and cities, in the reference to  \"shared spaces\" in para 70, but little apparent expectation that local authorities could  use the local plan to coordinate public  and private sector investment at all.  At a time of considerable upheaval in how public and ex-public services are delivered in individual places this is a serious omission.

7. Brownfield first

The term Brownfield is reintroduced though left to local decision making. The NPPF says \"Planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land), provided that it is not of high environmental value. Local planning authorities may continue to consider the case for setting a locally appropriate target for the use of brownfield land.\"

8. Resources

The framework requires  properly resourced planning services and the RTPI regrets the fact that planning has been hard hit by the current cuts. We call on the Government to decide on the question of resourcing planning through local planning fees as soon as possible.