NPPF: The only certainty is uncertainty

Robbie Calvert is the RTPI's Head of Policy and Public Affairs

This blog is part of a series of blog and news features on the NPPF. You can see related content below the blog.

Today marks the culmination of an extremely busy few weeks and months for us at the RTPI, with the publication of our consultation response to the revised National Planning Policy Framework. This blog is the first in a series we will be publishing over the coming week, unpacking some of the key themes from our response.

Whilst there have been a number of revisions to the NPPF since its inception in 2012, this is arguably one of the most ambitious yet. This includes the reintroduction of strategic planning in national policy and an entire reworking of our approach to development management with a suite of national decision-making policies, ushering in a new rules-based approach to determining applications.  In order to get a strong steer on such wide-ranging revisions we decided to cast our member consultation net far and wide.

Through January, we held nine roundtables across all of our English regions, followed by five more English Policy Committee meetings. We worked through the outputs from the roundtables, carried out a painstaking line-by-line review of the whopping 225 consultation questions, and drafted our equally long and unruly response. I would like to take this opportunity to deeply thank the valued contributions of our members towards this work, we could not have got here if it wasn’t for sheer variety of rich professional insight we received. 

And this leaves me with my unreasonable task of trying to distil such a response into a set of blogs for you.

No doubt pulling together such an ambitious piece of policy development is no small feat. Trying to cover every facet of the built and natural environment that planning intersects with is a wildly difficult task. Unintended consequences, perverse incentives, consequential considerations and local conditions. Every circumstance, every eventuality.  

I’m sure for this reason the word ‘clarification’ will feature heavily in most stakeholder responses, ours included. And this is unfair to some degree, ultimately whilst clarity is something we should continually strive towards; it’s a utopian ideology. I think a more realistic aspiration is to produce a workable document, that gets us towards the Government’s intended outcomes and best supports decision makers as they move through the complexities and grey areas of this world. Of course, underpinned by the continuing discretionary hallmark of our planning system.

However, with a new national decision-making approach set out in the Framework, the need to strive towards this clear-policy-paradise has never been lesser. If Government wants to crack on quickly with its growth agenda, we need to avoid, as best possible, the uncertainty and subsequent inevitable deluge of appeals and high court challenges.

To do this, let’s start by nailing down some key definitions wherever we can. What is a walking distance? How do I define my settlement? How do I assess the need? Can I readily apply TC3 with CC1 hanging over me? Nit picking, maybe yes, but cumulatively this could have a profound impact on how effective our new system is. Does it all need to be in the revised NPPF? No, with the right hooks, guidance will often suffice but that needs to come forward in an expedient manner.

But behind the immediate excitement, or indeed immediate concern, of a whole new approach to decision making, is the new plan-led system. Indeed, this is an area which we identified a need for more clarity, in particular throughout the proposed Framework the reference to the Development Plan often leads to a fair amount of confusion over what is considered proportionate in terms of detail and approach to preparing plans at different spatial scales.

Pivotal to success is how the new Development Plan system aligns with decision making. A clear delineation should not be a reason to avoid harmonisation. In fact, it’s that golden thread, that purpose of planning, that’s needs to flow through the framework. From regional large-scale infrastructure to a modest house extension. The ambition to manage the use and development of land in the long-term public interest should be writ large.

And we urge each of our members to take some time and respond to this consultation; speak now or forever hold your peace. We hope our response acts a means to help guide you, inform you, provoke you, or at least assure you that the institute has worked tirelessly to ensure the needs of our members are now firmly in front of Government.