9 Conclusion
159. We support the Government's aims to reduce the
amount of planning guidance, to make the planning system more
accessible, to give local people the opportunity to contribute
to planning in their areas, and to bring processes more swiftly
to a conclusion when a decision is uncontentious. Therefore, we
welcome the idea of a single, strategic National Planning Policy
Framework that progresses towards these aims.
160. We support the Government's aspiration to give
an impetus to the production of Local Plans across the country;
it is unacceptable that so much of England is not covered by an
adopted plan at present. It is Local Plans which will best embody
the Government's aspirations for both sustainable development
and greater localism in planning, which will give certainty and
confidence to both the community and developers, and which should
guide day-to-day decision-making. For these reasons it is crucial
that local planning authorities be given an adequate (but time-limited)
opportunity to adopt up-to-date plans, and that they receive reassurance
that plans already in place will not be cast aside, leaving the
door open for inappropriate development. Plans must, as
the NPPF stresses, be based on robust evidence of needs and the
intention to meet those needs. However, consistency in the way
in which those evidence bases are compiled will also be needed
if Local Plans, cumulatively, are to meet the needs of the country
as a whole. Above all, the NPPF's introduction of a presumption
in favour of sustainable development must be seen as a high-level
principle rather than a challenge to the predominance of local
decision-making. That is why we have recommended that it be expressed
instead as a 'presumption in favour of sustainable development
consistent with the Local Plan'.
161. The NPPF does not only seek to provide an impetus
to the production of Local Plans, however. It also aims to provide
a policy framework for those plans and to provide a basis for
decision-making in the absence of a Local Plan. For these purposes,
we find the document lacking. Its definition of sustainable development
is inadequate, and we have made suggestions for how this could
be improved. The presumption in favour of sustainable development
is a useful concept if it is intended to be an overarching, strategic
aim, but it is not an appropriate basis for making decisions in
individual cases. It is also expressed throughout the document
in inconsistent ways, which together have the effect of unbalancing
a stool supposed to rest on the three equal legs of economic,
social and environmental considerations.
162. We agree with those who have detected in the
draft NPPF a weighting towards the aim of economic growth. The
exhortation to adopt a 'default yes' to development proposals,
the way the concept of viability is framed, and the 'significantly
and demonstrably' test for evidence against development, all seek
to tip the balance of decision-making too obviously towards development
that may be unsustainable. These elements of the Framework chip
away at reassurances of protection for the environment, and have
the potential to undermine the primacy of local decision-making.
Changes to policy on transport, brownfield development, identification
of land supply and Town Centre First further unbalance the NPPF,
as the amended policies are more likely to tend towards unsustainable
development.
Further consultation
163. The Environmental Audit Committee stated in
their letter to us that "the scale of change needed to the
document suggests to us a need for a further round of public consultation
once an improved draft is produced."[326]
We put the suggestion of a second stage of consultation on a revised
draft to the Minister, Greg Clark, who argued that responses to
the initial consultation had been sufficiently clear and detailed
to enable the Government to produce a satisfactory final version
without taking further soundings. He told us:
We know what people would like to see, and they
have been very clear, even down to the wording in many cases.
We have plenty to go on to be able to have a document that meets
the ambitions that we all have, so we will not be holding another
consultation. [...] As part of any consultation, there is the
opportunity to clarify with people who have made suggestions what,
precisely, they meant by this word and whether that formulation
captures it—the opportunity to clarify submissions that
are made. I am confident that we will be able to do it.[327]
164. We see a strong case for a short consultation
to allow practitioners to make comments on the technical aspects
of the revised NPPF. This would help avoid confusion at a later
date. The Government should also consider carrying out a brief
but wider consultation if it makes substantial changes to what
might be reasonably regarded as key principles in the final NPPF.
326 Environment Audit Committee, Sustainable Development
in the National Planning Policy Framework, HC 1480, para 41 Back
327
Qq 348-49 Back
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