The National Planning Policy Framework - Communities and Local Government Committee Contents

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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Prepared 21 December 2011