ON the 19th for a bit of fun we published an accumulator – though also with the serious purpose of being able to mark how truly sustinable the end result is. remember anything above zero is positive.
I omitted points for protection of open space so it is not 100% comprehensive.
Just 1 point, does not include economic, social and environmental wellbeing or the ‘three pillars’ approach of balanced development of all three based on protection and enhancement of eco-system services.
In addition as the SDS and Brundtland principles are in the past tense and referenced as decisions in the past and by others it is unclear how they can be applied day to day and if the government is committed to applying them as current principles. It looks like the Treasury was looking for a way of ‘ringfencing‘ sustinability issues of avoiding each and every cases being assessed on impact on environment limits or social wellbeing. This plan may have failed however as the legal advice to the NT is that paras. 1-17 of the NPPF are of equal weight to the rest of the document, as it does not say that some paras are to be given priority or extra weight in decision making. Para 6 is saying – this is how we implement paras 1-17, but of course it cant ever be comprehensive, as the decisions maker has to take into account all material considerations of which sustainability is one.
However there is one negative bonus point for each mention of growth which misses out sustainable. The switch between use of sustainable economic growth and growth in the document – I count minus 7 points. Twice it even uses the different terms in the same sentence, exercising sustainable economic growth as the objective and decisions ehancing just growth in decisions – very telling. Para 19 is a classic of confusion. Sustainable economic growth is not defined.
So score of Minus 6.
Just 1 point – and that is generous. The mention of the primacy of the development plan gets it, as does the deletion of the notorious Yes para. get it that but it does not set clear tests to apply when plans are out of date, even for example delting the tests from PPS3 for housing. It still uses vague terms, does not dewfine of clarify thenm and implies that harmful schemes should be approved.
By splitting the plan making presumption from the decision making one it dodges a negative bonus point.
1 point – and that is generous. There is an implementation period, but that is for existing plans not emerging plans. Beefing up the prematurity test is not the same as transition as plans not yet with preferred option will carry no weight at all. Back to appeal led planning.
Larger than Local Planning
No text at all to properly implement and clarify the duty to cooperate – very surprising.
Ok so how far does it take us away from narrow 80s style plan making – mentioning
land management 0
Settlement/Spatial Strategy 0
Place Shaping/Spatial Planning 0
Integrating Transport Planning 0
Infrastructure Planning 0
Grand Total: o points
Perhaps the NPPF should enter the euro-vision song contest.
The accumulator awards 3 points for a ‘clear ‘brownfield first’ approach’
It is not clear, it does not prioritise as past policy, it only encourages, it is described only as an option – so will it apply on appeal where no up to date plan, it semes to be worded as approving brwonfield sites, not clearly refusing greenfield ones.
Just 1 point – and that is generous.
It does include reference to the intrinsic character and beauty of the countryside but only as an objective not as a policy. Incredibly there is no countryside section still. We know civil servents drafted one, so why was it not included?
No mention of smart growth no mention of the general desirability of controlling sprawl, but thought i fair to give it a point for adding reference in the design section to efficient use of land.
Of course the Treasury would not ever accept the use of the term as it implies they were dumb in the past. Only a major shift in the political landscape would see it adopted.
o points as no explnation of how to claculate 5 years supply, and no mention of the methodology to clacuklate need,
It also score minus two bonus points for discriminating against travellers on two grounds. Firstly a reference to CPO to bricks and morter but not travellers, and secondly a policy for ‘strictly controlling; travllers sites in the countryside (as in PPS3) but no such policy for bricks and morter,
Minus 2 point as well on affordability issues.
If we thought for a moment it would have deleted the policy tests for what happens when you have no 5 years supply it would have got minus 10 for that.
Minus 4 points
Maximum Points 3
3 points, strengthens town centre first, allows local zoing choice on planning for employment and mentions in a roundabout way coordination and balance of planning for jobs and housing.
4 points – near maximum, puts back the SSSI test, mentions NIAS, natural networks and natural environment white paper. Just falls short of maximum by still failing to correctly transpose the Habitats directive.
1 point – Nothing on integrating transport and land use planning – which is utterly breathtaking – or any of the other matters which would have gained points, other than a mention of carbon emissions in the section on setting parking standards.
1 point Mentions ‘cumulative landscape and visual impacts’ but not national CO” reduction targets – (the reference to the 2008 act is on the wrong paragrpah
properly transposes PPS5.
No Index – Minus 1
Ministerial Forward – that lawyers favorite – Minus 20
So total (excluding bonus points for style- are 17 just as we predicted high teens – but disappointing as the maximum was 63, but with bonus points MINUS 19