Communities and Local Government CommitteeWritten submission from David Holmes

Executive Summary

The draft NPPF is a concise and practical document. It may need a light touch to amplify or supplement points during implementation but it is a clear and balanced approach to plan making and development management.

The authors request that it is read in the round (Paragraphs 8 and 12). If done so the key principles are very clear and provide for a planning balance to be achieved in line with the economic, social and environmental factors put forward.

It generally provides sufficient guidance to the parties identified in question one on general principles. There are few areas for supplementary guidance to be developed (calculating housing requirements, viability and strategic environmental assessment). These are detailed in the main text. As a principle however these should be kept to a minimum and only considered where necessary to provide consistency of approach.

With regard to “sustainable development” provided the document is read as a whole and all of the references to “sustainable development” are picked up it provides a comprehensive and workable framework.

The core planning principles are clear, concise and relevant.

The relationship between the NPPF and other national statements of planning related policies is clear. Effective management of the framework is key.

There remains a residual concern that the Duty to Co-operate can be viewed as a statement of faith rather than a statement of fact. The matter presumably will be dealt with through the test of soundness in the examination of local plans.

The need for the provision of up to date evidence including market trends is given sufficient weight in the document. Supplemental guidance on technical matters may be necessary. These points are referenced in our main text.

Q1. Does the NPPF give sufficient guidance to local planning authorities, the Planning Inspectorate and others, including ministers and developers while at the same time giving local communities sufficient power over planning decisions?


The guidance on general principles is fit for purpose. There are three matters which perhaps should be considered in more detail as matters for supplementary material. These relate to:

Calculating housing requirements

The drafting of Paragraphs 107 to 111 is relevant and supported.

Paragraphs 109 and 111 (in part) refer to the need for housing to be based on current and future demographic trends/market trends. There should be consistency of approach in the preparation of this evidence and an ongoing role for SHMA’s and SHLAA’s. In this context further guidance on the methodology for the calculation of housing requirements would be welcome and have the benefit of avoiding duplication of effort and debate at Local Plan examination and Inquiry if necessary.


The recognition of viability as a material factor within the NPPF is fully supported. Although a matter frequently debated it would be helpful if the NPPF could be supported by a clear statement of CLG policy on the appropriate parameters to be consistently applied in verifying viability. This would assist local plan inspectors in determining soundness of the plan, the community infrastructure levy (CIL) if a charging schedule is proposed and to inform local authorities and PINS if necessary when considering viability in the context of determining planning obligations.

Strategic Environmental Assessment (SEA)

Although there is general reference to compliance with EU environmental law it may be helpful to give a timely reminder to local planning authorities of the need to subject Development Plan Documents to an SEA. This would help remove potential for future judicial review with all of its attendant risks of costs and delay.

Q2. Is the definition of sustainable development contained in the document appropriate, and is the presumption in favour of sustainable development a balanced and workable approach?


The Brundtland definition has the benefit of simplicity and familiarity. It works in the context of the NPPF because of all the criteria which could be applied to evaluating sustainability are referenced within the main text of the framework. It may be helpful to bring all of these references together in one appendix. The Brundtland definition without these references would have little value at a planning Inquiry, for example.

Q3. Are the core planning principles clearly and appropriately expressed?


A short but considered response is yes. The principles are balanced, clear and appropriate.

Q4. Is the relationship between the NPPF and other national statements of planning related policy clear? Does the NPPF serve to integrate national planning policy across Government Departments?


The positioning and relationship of NPPF to other policy areas is clear. If applied consistently and with equal weight between departments it should facilitate effective corporate working.

Q5. Does the NPPF together with the “duty to co-operate”, provide a sufficient basis for larger – than - local strategic planning?


Provided the parties establish early strong and effective methods of co-operation then perhaps the duty of co-operation can be effective at a regional and sub regional level. The point is perhaps unproven at the moment. The matter presumably will be dealt with through the test of soundness in the examination of local plans with the default position based on the presumption in favour of sustainable development in the absence of an approved local plan.

Q6. Are the policies contained in the NPPF sufficiently evidence based?


There is an appropriate and welcome recognition of the need for up to date evidence to be applied in plan making.

Fitness for Purpose

As a starting point the draft NPPF is fit for purpose. It provides a clear and balanced approach to a plan lead system which fully recognises the basic principles and interaction of economic, social and environmental considerations with a strengthening of local choice and determination. The authors of the document call for it to be read in the round (Paragraphs eight and 12). If done so, it demonstrates a considered and comprehensive approach to plan making.

The principle of planning for prosperity (the economic driver) is self evident within the document. The draft NPPF, does not, as some parties suggest dilute environmental protection. There is simply a rebalancing of priorities and a requirement for plan making to be approached with vigour, responsibility and timeliness. The impetus which this could bring should be welcomed.

The need for supplemental guidance in a few areas is noted particularly with regard to Strategic Housing Market Assessments (SHMA) and will be dealt with more fully in formal responses to DCLG by 17 October 2011.

As a final point there is a need for consistency in plan making and for the plan making cycle to complete itself. One of the factors behind low housing delivery in the recent past has been the plethora of planning reforms introduced since the turn of the century which seem to have frustrated rather than enabled effective plan making. The introduction of the NPPF provides a very clear statement of intent, incentive and sanction to encourage effective and up to date plans to be produced. There will undoubtedly be tensions in implementing this framework, if it is confirmed in this form, but that is inherent in the nature of planning where judgment is exercised to achieve an appropriate planning balance. The strength of the document is the clarity it brings to the “core principles” of planning which are themselves balanced and contribute to “sustainable development.”

11 August 2011

Prepared 20th December 2011