National Planning Policy Framework Forensic Analysis #3 Prudent use of Natural Resources

A few shorter ones today.

The term ‘prudent use of natural resources’ appears several times in the draft.

As a general principle, as a requirement for policies on the subject, and as justification for policy on recycling, re-use of existing buildings and on renewable energy.  There is reference to use of resources, but not prudent use, in the minerals section.

Completely lacking is the PPS1 para.17 reference to a high level of protection being given to natural resources.

Also lacking are paras 21 and 22 of PPS1 specifically on this subject.

Para 21 in particular shows an overall philosophy of resource management.

The prudent use of resources means ensuring that we use them wisely and efficiently, in a way that respects the needs of future generations. This means enabling more sustainable consumption and production and using non-renewable resources in ways that do not endanger the resource or cause serious damage or pollution. The broad aim should be to ensure that outputs are maximised whilst resources used are minimised (for example, by building housing at higher densities on previously developed land, rather than at lower densities on greenfield sites).

This is far from perfect but at least it sets out a broad philosophy.

I think it is essential that the NPPS sets out a philosophy of prudent resource management, one that minimises energy, transport and resource inputs, maximises outputs and wherever possible uses outputs as inputs in a cyclical green economy.

If the NPPS sets out such a philosophy then it will not pages reims of text as so much can be deduced from this principle – such as combined heat and power, integrating housing and energy etc. etc.

As a general principle I think the NPPS needs to be technology and methodology neutral, rather simply setting out simple principles of resource management against any proposal can be judged – including unexpected innovations in the future.

I think too we can learn from the experience of planning reform in New Zealand in terms of its attempts to integrate and simply resource management regimes. This has often been painful and bureaucratic, not easy for the planners concerned, and has had to be simplified, but it is possible I think to take the main advantage – of integrating resource management considerations into planning, and discard the baggage.

Take for example the definition of sustainable management from section 5 of the RMA 1991 which defines it as

managing the use, development and protection of natural and physical resources in a way, or at a rate which enables people and communities to provide for their social, economic, and cultural well-being and for their health and safety while-
(a) Sustaining the potential of natural and physical resources (excluding minerals) to meet the reasonably foreseeable needs of future generations; and
(b) Safeguarding the life-supporting capacity of air, water, soil, and ecosystem; and
(c) Avoiding, remedying or mitigating any adverse effects of activities on the environment

The minister had quite specifically emphasised physical constraints, ‘the biophysical bottom line’ in order to move away from the overly broad and unweighted list of socio-economic and environmental objectives in the Town and Country Planning Act it replaced. Although clause (c) was far too restrictively worded – should all adverse effects be fully mitigated?

As drafted the NPPS implies there is no biophysical bottom line – that position is not sustainable rhetorically or scientifically.

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