Coalition of Charities set Smart Growth Red Lines for Final #NPPF

Press Release CPRE/Wildlife and Countryside Link – its great to see Smart Growth featuring so prominently – however it is surprising the CPRE would not inist on ‘protection of the countryside for its own sake, and without setting down a transition period as a red-line how can planning by appeal on the ‘ordinary countryside’ be avoided?

A coalition of charities today set out ‘red lines’ for the Government’s controversial reform of the planning system, the National Planning Policy Framework (NPPF). 

The groups, represented by umbrella body Wildlife and Countryside Link, which counts RSPB, WWF-UK, the CPRE, The Wildlife Trusts and Friends of the Earth as members, warn that if these lines are crossed, planners are likely to become tied up with direct action, court challenges and appeals.

The charities say that without the introduction of these safeguards in the NPPF, more environmentally damaging developments are likely to get the green light. Critically, they say that the NPPF needs a clear definition of genuine sustainable development, which ensures that economic, environmental and social concerns are fully integrated rather than traded off against one another. The group’s ‘red lines’ are that:

  • Sustainable development must be defined in line with the current UK Sustainable Development Strategy;
  • The presumption in favour of sustainable development must be designed to promote development that is sustainable, rather than development at any cost;
  • The natural environment must be properly and consistently protected;
  • The NPPF must achieve ‘smart growth’, meaning growth that makes efficient use of land, utilises existing infrastructure and reduces the need to travel.

Emmalene Gottwald, senior planning advisor, WWF-UK: “It’s ludicrous that the Treasury thinks the planning system is a ‘block’ to growth. There’s little evidence that an NPPF biased towards development at any cost will usher in economic growth in the short term – but as it stands, the reforms are a clear threat to the environment and our long term prosperity.

“The Prime Minister said that he’s serious about protecting the countryside, but it’s starting to look like his heart isn’t in it. An NPPF that doesn’t have sustainable development at its core will leave this Government heading down the wrong path.”

Simon Marsh, head of planning policy at RSPB, said: “The public, having shown their opposition to the reforms, won’t take environmentally damaging development lying down. We’re likely to see local opposition groups springing up across the country wherever an environmentally damaging development has been approved.

“The Government must get these reforms right, otherwise local communities, our landscape and our wildlife will bear the brunt of unsustainable development It is critically important that misguided attempts to stimulate economic growth do not jeopardise our natural environment.

Paul Wilkinson, head of Living Landscape for The Wildlife Trusts, said: “We believe that the planning system should make a positive contribution to creating wildlife-rich places, where people want to live. The new framework should help this, not hinder it. Will the Government have the imagination and courage to really understand the value the natural environment, and to contribute to its recovery? We wait and hope that the default answer to natural environment restoration is ‘yes’.”

Paul Minor, senior planning officer for the Campaign to Protect Rural England, says: “The public values the countryside highly and expects good planning to protect it. We need to continue making the best use of brownfield sites, and not create the urban sprawl seen elsewhere. We urge Ministers to show that they have listened to the clear message the public has sent on these issues.”

Craig Bennett, Friends of the Earth’s director of policy and campaigns, said: “Ministers say new planning guidance has ‘sustainable development’ at its core, but unless they spell out what this means we’ll see ever more new roads clogged with traffic and families struggling to insure homes built on floodplains.

“The planning system must give the green light to building the clean energy systems and warm, affordable homes the country urgently needs – but George Osborne’s countryside-wrecking plans for growth at any cost will not do this and must be stopped.”

The coalition of organisations also warn that if the NPPF does not meet the sustainability criteria laid out in the ‘red lines’, England may revert to having a ‘planning by appeal’ system. They argue that even if local authorities tried to refuse applications more developers would opt to go to appeal if they are turned down by the local authority because of the expectation that the default answer to all new development should be ‘yes’. This would effectively take the decision-making process for local planning decisions out of town halls and put it into the hands of Government-appointed inspectors, seriously undermining the Government’s commitment to localism.


Notes to editors: 
[1]Red lines for the National Planning Policy Framework (March 2012), published by Wildlife and Countryside Link, is available here. The document is supported by the following Link members:

  • Badger Trust
  • Buglife – The Invertebrate Conservation Trust
  • Butterfly Conservation
  • Campaign for Better Transport
  • Campaign for National Parks
  • Campaign to Protect Rural England
  • Environmental Law Foundation
  • Friends of the Earth England
  • Royal Society for the Protection of Birds
  • Open Spaces Society
  • The Wildlife Trusts
  • Woodland Trust
  • WWF-UK

[2] Wildlife and Countryside Link is an umbrella body, whose purpose is to bring together voluntary organisations in the UK to protect and enhance wildlife, landscape and the marine environment. The Link currently has 37 members who collectively employ over 10,000 full-time staff, have the help of 170,000 volunteers and the support of over 8 million people in the UK:

[3] The Government is expected to publish revisions to the proposed the National Planning Policy Framework in March.

Ministers face ‘major headache’ if they don’t address concerns on #NPPF – Daily Mail

Daily Mail

Countryside campaigners warned ministers last night that they face a major ‘headache’ if they press ahead with controversial reforms of the planning system.

George Osborne is reported to be determined to include the most contentious element of the plans – a presumption in favour of planning – in this month’s Budget.

The Chancellor wants to press ahead with the shake-up which he believes is vital to promote growth and jobs.

Ministers have enraged countryside campaigners with proposals that local councils should approve all building projects unless there is a strong reason to refuse them.

The proposals represent the biggest change in planning law for more than 50 years and aim to ‘dramatically’ simplify the system by slashing 1,000 pages of policy to just 52.

The most significant change is that local authorities would adopt a default position of answering ‘yes’ to proposals for sustainable developments.

Despite signs that ministers were preparing to water down the plans, Mr Osborne is said to be determined to include the reforms in the Budget and sources have confirmed there would be no ‘significant’ changes to the document.

Ministers will, however, strengthen safeguards to protect green belt land in an attempt to appease the countryside lobby. They are also expected to spell out what they mean by the term ‘sustainable’ development.

But Neil Syndon, from the Campaign to Protect Rural England, said: ‘It would be a great shame and potentially damaging, not just to this country’s precious countryside, but to its long term well-being if the Government were to fail to listen to the rational and impartial evidence that has been put to it.

Tory MP Zac Goldsmith said ministers would have a real ‘headache’ if they did not address concerns raised by campaigners.

He said: ‘Millions of people will be very worried. They are right to be worried because whatever reforms are brought in will have a lasting legacy that will extend well beyond this generation. It is really important that we get it right.’

Roberta Blackman-Woods MP, Labour’s shadow planning minister, added: ‘Reports that the Government is to make no significant changes to its draft planning reforms are extremely worrying.

‘If there really is no significant change in the document and this Tory-led Government continues to ignore the millions of members in these organisations, such an out of touch and complacent approach will raise serious concerns amongst all those who love our countryside.’

A National Trust spokesman added: ‘We have never been in doubt that planning reforms would go ahead, and agree that changes do need to be made.

‘We’re reserving our judgement until we see the final Planning Policy Framework for ourselves – we’re confident that a robust plan-led system can deliver social and environmental benefits, as well as economic growth.’

CPRE publishes briefing on where we are with the #NPPF



Date of Publication

The exact date of the publication of the final NPPF is still unknown, but the Government has made clear that it will be issued before the end of March. There has been significant speculation that its publication may coincide with the Budget (Wednesday 21 March).  This would be a good day to bury bad news, or to incorrectly assert that the overriding purpose of the reformed planning system is to deliver economic growth.

Points of agreement and contention

There is wide agreement that the planning system needs to be reformed to improve public involvement. Giving more say to local communities in planning decisions formed a key part of the coalition agreement. It is also generally accepted that we need to increase housing supply, including affordable rural housing, and support the sustainable development of rural businesses.

However, following the release of the draft framework, which was subject to public consultation for three months from July last year, it became clear that some parts of the Government, particularly the Treasury and Department for Business, wanted to change the role of planning to make it a tool for facilitating economic growth above all else. This was reflected in the tone of the draft NPPF, which many believed to be unacceptably biased in favour of short term economic considerations. It is important that the planning system does what it can to facilitate sustainable economic growth, but it has other equally important functions. The draft failed to give sufficient weight to the environmental and social purposes of planning.

Key issues to look out for in the final NPPF

CPRE raised a number of significant concerns about the draft NPPF which we believe would not help promote development that is genuinely sustainable. In summary, we believe the final NPPF should be improved to:

  • recognise the intrinsic value of unprotected countryside which covers more than half of England, and set out stronger policies to protect the Green Belt and specially designated areas;
  • retain an explicit ‘brownfield first’ policy to promote urban regeneration and efficient use of land by ensuring previously developed land is used before greenfield sites, as well as effective integration of transport and land use planning;
  • define sustainable development so that environmental limits are respected and pursued alongside other objectives, rather than giving primacy to economic development;
  • reinforce the plan-led system and ensure appropriate transitional arrangements are put in place to allow time for up to date local plans to be developed; and
  • promote, rather than undermine, the delivery of affordable housing in appropriate locations to meet identified needs, particularly in rural areas.

The Yorkshire Argument for Building Less Housing – Low Job Growth #NPPF

In the South of England the argument most frequently used to build less homes than household growth is to plan to restrict inward migration by not including it in estimates of local need.  As if new houses on the local market are restricted to locals only.  Of course this silly argument results in less houses for locals as wealthy incomers will move in anyway.

In the North of England different arguments are used and a novel one is used in Kirklees which yesterday agreed its local plan for submission.  Household growth requirements (including adjustments for demolitions etc.) of 1,900 a year (the RSS was only 1,700), but now planning for 1,248 a year, 22,470 from 2010 to 2028, less than the 25,470 proposed last year and resulting in a Green Belt deletion being omitted at Ainsly Top.

The justification used is an Ecotec report proposed for all the Yorkshire authorities in 2010 –  Impact of Employment Growth on House Buying.

The Local Plan is admirably clear and members have been fully engaged.  But this is just another indefensible fix to build less than household growth levels.

What the study is doing is attempting a new method of projecting household growth – through having differential headship rates by occupation and then multiplying the anticipated employment growth in that sector to derive household growth.

I would not entirely dismiss this approach, providing the workforce is contained by demographic factors and it is applied at a regional level – which this report did.  If employment growth is higher in some districts than others then people will move their and residents will be more able to form new households, the converse where employment growth is less.  In the longer term demographic factors and employment growth must even out.  If new housebuilding does not keep up in high employment areas house prices will rise and older households will retire to cheaper areas realising house price increases.  The freed up existing stock will induce household formation through in-migration in the freed up homes inducing inward migration.

The report concludes that even with rapid recovery there will not be the effective demand to build the level of housing required in the old RSS, around 20,000 houses a year, even though the underlying demand was far greater, over 3,000 houses a year.  Of course many would conclude from this that this requires additional employment growth to meet the gap including land release for both jobs and housing to make it happen.

The problem though is attempting to take a regional report and apply a local conclusion.  If Kirkless is building less than household growth people will move out looking for areas with a better house price to wages ratio – like where?  Under the duty to cooperate have you signed up those areas?

If land released were to lie vacant this would be unwise, but the rationing of landbanks by the existing parsimonious volume house-builders is to protect their profits, whereas if they lowered asking prices there would be a ready market.   As the Economist Steve Keen has proved firms ration output to maximise profits at a level of production much less than marginal revenue equals marginal costs.  Only new entrants to the market with lower costs will drive outputs up and the rate of profit down. So if the restricted housebuilding industry was opened up, as the IPPR suggests, it should not be assumed that output of new housing would be lower than land released. Indeed if new entrants bought an expanded land supply this land would be cheaper than the landbanks held by the existing house-builders and so they could compete with lower house prices – and this creates an expanded market with expanded housebuilding.  Effective demand is not a fixed once and for all thing.    As Leeds City Region is one of the healthiest in the North of England it is likely that people will move their in search of work and chaper housing if their was a large stock of relatively affordable housing.

The mistake then of the Ecotech report is to focus solely on the demand curve of housebuilding – which it is very good at, but not look at the rational response of firms on the supply curve to a lowering of production costs.  Housebuilding and household formation exist in a dynamic two way relationship. Similarly this Yorkshire argument for frugality is self defeating because effective demand, and employment in the wider economy, could be depressed by households having to spend so much of their income on expensive housing. Its a good example of the paradox of saving repressing aggregate demand. Whereas increasing land supply will lower housing costs and boost effective demand and local employment.

Government Privatises Flood Defence – Households must pay for their own

The Guardian reports that at a conference this week the flooding minister Richard Benyon has announced that the government will not renew the Statement of Principles that ensures that cover is renewed in the most at risk area (1 in 75 or more) if flood defences are planned within 5 years.  The quid pro qou with the last government was of course significant investment in flood defences – so this is just a cover for cuts.  The Minister has stated that it did not cover most households, but this is disingenuous as it was only ever intended to guarantee insurance to those who would otherwise have greatest difficulty in obtaining it.

The insurance industry believes the government has now reneged on its part of the deal and consequently it does not want to continue with the agreement, a situation that leaves thousands of households at risk of becoming uninsured by next summer.

Benyon said households should instead be encouraged to invest in their own flood defences, including the installation of air brick covers, non-return valves and seals for cat flaps.

Gavin Shuker, the shadow minister for water and waste, said: “‘This Tory-led government is playing Russian roulette with people’s homes and livelihoods. …Ultimately, catastrophic risk resides with us all – a denial of this basic political principle is like trying to deny gravity. It is short-sightedness of the worst kind. We need leadership from government in ensuring the flood investment is made, and to put in place a framework that will ensure high-risk homes are able to access the protection they need.”

The answer surely is to provide a national insurance scheme for natural hazards, funded by a levy on all property insurance, as in the States, France and the Netherlands.

Flexible Regulations and Local Plan Prevarication #NPPF

What can be done to speed plan preperation?

The regulayions are tortuously written, not in the current ‘light touch’ style and certainly could be simplified from their reliance on endless cross-references.

But the last major redraft of the regulations in 2007 tells us a cautionary tale.

This removed the requirement for the unncessary ‘preferred option’ phase – replacing it with a flexible reg. 25 period of pre-submission consultation.

But in many authorities rather than quickening plan submission have taken the opportunity to publish an endless series of iterations.  Of course there is a minority of laggards who have produced nothing at all.

At every slightest possible excuse another iteration is produced.  I know have some authorities who have produced five regulation 25 rounds.  If plan making doesnt move swifly it stalls, loses political momentum and creates consultation fatigue as the initial evidence base withers on the vine.

The abolition of regional strategies, new consultation, the evidence base being four years old, new consultation.  We didnt consult on realistic options full time, new consultation.  The county council and utilities didnt tell us the real infrastructure constraints until we had produced a plan, new consultation.  The concentrated strategy was unpopular, new dispersed startegy, oh dear that even more unpopular.  Developers tell us the new locally derived housing figures will result in an unsound plan, new consultation.  New Household projections, new consultation.

Plan preparation requires a fairly stable period from a firm baseline.  If you have that stability with good project management you can get a plan to submission in 18-months to 2 years from first publication of the project plan/project commencement.  This requires a period of political stability, no looming elections, national policy stability, and stability in the evidence base – so ideally should be commenced at publication of the latest  two-year household projections.

If their is not that stability then members may panic and their is always the pressure to avoid the pain by kicking the can down the road further.  Council leaders will see the controversies of plans to build more housing as a distraction from getting elected and most chief executives seem to see this as a distraction from the quiet life from the rare four or five year tenure which will see them earn enough to retire on.

So even a super simplified set of regulations wont avoid these issues as they all occur during the regulation 25 period where LPAs have total flexibility what to do.

The only solution I can see is to set a fixed timetable at the outset of 18 months to two years and stick to it.  The stick from central government being that if you delay then you cant argue prematurity, and you risk appeal led planning if you don’t have a 5 year supply.

Central government can do its part by ensuring a period of national policy stability, but that of course requires a quality final NPPF that I have little faith will be produced.  NBets are on for how long before events and the need for ‘clarifications’ force a need for a major review – a year, 18 months?

The biggest cultural shift needed though is to move away from the idea that plans some how fix a permanent line in the sand between sites absolutely protected and those allocated.  Most of the major sites allocated in this plan round were probably those rejected in the last – certainly if they are greenfield sites.  Which of course is why they are so controversial.  Plans that rank sites – and draw the line at latest point of evidence of need will be much more robust to changes such as new household projections.