UK-GBC response to the NPPF
I had to read this one several times because I was looking for some comments on green buildings standards – nothing? How odd.
UK-GBC is a membership organisation that is campaigning for a sustainable built environment – one that minimises negative environmental impacts whilst maximising benefits for people everywhere. Launched in 2007 to offer clarity, cohesion and leadership to a disparate sector, we bring together anyone involved in the complex process of planning, designing, constructing, maintaining and operating buildings. A registered charity, we work with our members – who are mostly businesses, but also NGOs, government agencies and academic institutions to deliver radical change.
UK-GBC supports efforts to simplify the planning system and streamline planning guidance and we welcome the opportunity to comment on this consultation. Feedback from our members suggests the current system of PPSs and PPGs is overwhelming and time consuming for all involved, and therefore we welcome efforts to make the system more straight-forward and more responsive.
UK-GBC believes that new developments should be a means to help solve sustainability problems and issues, rather than create new ones. They can do this by for example, delivering high quality, efficient and well-designed buildings supported by sustainable, low carbon infrastructure; through the regeneration of urban fabric; by enhancing biodiversity and community facilities and through the creation of jobs.
UK-GBC believes the industry has a responsibility to deliver the highest quality, most sustainable development it can in any given location. In return, the industry needs as much certainty as possible about what they will be required to deliver through a clear national planning policy framework and reliable local plans, thereby enabling and de-risking investment decisions.
We are working with our members to outline what best practice standards and guidance at the local level should look like and we will be pleased to share this with CLG in due course.
Definition of sustainable development
We strongly support the emphasis on ensuring development is sustainable, and acknowledge the reference in the NPPF to the Brundtland definition. However, we would prefer to see a definition of sustainable development which explicitly recognises environmental capacity, and is based on the 5 principles of sustainable development outlined in the 2005 Sustainable Development Strategy Securing the future. We would support the inclusion in the NPPF of the following statement (proposed by Friends of the Earth in an amendment to the Localism Bill):
sustainable development” means development that meets the social, economic and environmental needs of the present without compromising the ability of future generations to meet their own needs including the application of the following principles:
(i) living within environmental limits;
(ii) ensuring a strong healthy and just society;
(iii) achieving a sustainable economy;
(iv) promoting good governance;
(v) using sound science responsibly.”
However, even with the inclusion of this statement, the NPPF is a high level national document, and in order to ensure we actually deliver sustainable development on the ground, it is vital that local plans are both robust in terms of requiring high standards but also pragmatic in terms of ensuring development is deliverable, viable and offers the best sustainability solutions for the location/build type.
What the industry needs most from the planning system is certainty. When business has certainty it can make investment decisions based on a stable policy framework, and create jobs and growth. When the system is uncertain, this can result in legal disputes, delay and a hiatus in development.
Our serious concern is that local planning authorities (LPAs) often do not have the capacity and resources to produce comprehensive and timely local plans. In order to help fill this capacity and resource gap, and in order to learn from and build on best practice projects delivered by our members across the country, UK-GBC proposes to develop good and best practice guidance for developers and planners as part of our Green Building Guidance Task Group1. This will be developed with cross-sectoral input and will not re-invent wheels or recreate tools, guidance and standards but will sign-post to those currently available. Our intention is that this would provide some ‘default’ sustainability performance standards for both developers and planners and we propose that these could then be used to help LPAs to develop their local plans.
Specific points There is a need for clear ‘transitional arrangements’ from the old planning system to the new system. Otherwise there will be a lack of certainty amongst both planners and developers, and a potential for conflict and a hiatus in development.
The lack of focus on ‘town centre first’ policy is deeply concerning. Out of town offices/other developments are often not a sustainable option, and instead we need a focus on urban regeneration which helps town centres to flourish and protects the countryside.
UK-GBC supports the particular emphasis on the need to achieve ‘radical reductions’ in greenhouse gas emissions through both new and refurbished developments.
Developments will also need to adapt to the changing climate over the coming decades and we would welcome clearer advice on climate change resilience and adaptation.
There was a welcome emphasis in Open Source Planning on a collaborative approach to planning. However there are concerns that this emphasis is not so strong in draft NPPF. Experience on the ground is that it can be difficult to get developers, planners and local communities around the table, so we would welcome a stronger emphasis on a collaborative approach and the opportunity to facilitate this with our members.
There is a need to unlock funding and sites for infrastructure development. We have an infrastructure deficit and we need to ensure the delivery of infrastructure is joined up. In the absence of Regional Spatial Strategies, the duty to cooperate across local authority boundaries should include a requirement for authorities and key stakeholders to plan jointly for strategic infrastructure. This could, for example, include reviewing opportunities to roll out district heating networks in suitable areas. Zero carbon energy infrastructure could be supported through capital raised by developers of new buildings through ‘Allowable Solutions’ payments into a Community Energy Fund as previously recommended by the UK-GBC.
Good design is critical – development is not sustainable if it does not also promote good design. Local authorities should have a clear vision for their area. We welcome the proposed design review, and believe the panels should be independent and expert.
Sustainability is a complex subject and the development of skills for the delivery of sustainable development is essential for all stakeholders involved in the planning process. Through the UK-GBC Sustainability Training and Education Programme (STEP) we are improving awareness and understanding of sustainability across the industry and building the capacity of professionals, including planners and developers, to embed it in their decision making.