Communities and Local Government CommitteeWritten evidence from Neil Blackshaw

In this brief submission I would like to focus simultaneously on the three questions on which the Select Committee is seeking evidence that relate to the “integrative” role of the NPPF, that is:

Is the relationship between the NPPF and other national statement sufficiently clear?

Does the NNPF serve to integrate national planning policy?

Does the NPPF provide a sufficient basis for “larger than local planning”?


The NPPF fails to articulate and adopt a truly spatial approach.

The NPPF does not provide a national and sub-national spatial framework to guide local decision making.

The NPPF does not provide a framework for identifying the spatial implications of and for the better integration of public and private policy making and investment.

An alternative approach, in the shape of a national spatial plan as exemplified by practice in Europe and the devolved administrations would provide a much more effective set of tools to address urgent challenges of rebalancing the economy and of delivering sustainable development.

The Submission

1. The title, National Planning Policy Framework, can be interpreted, as the government has largely done, merely as the list of planning policies that it expects councils to follow. In this sense it will have much the same function as the sum total of the Planning Policy Statements, albeit as the government never ceases to remind us, in a much shorter format. But I would like the Committee to consider what the NPPF could have been and to put forward an alternative vision that addresses the above questions.

2. Planning is a quintessentially spatial activity. However, the NPPF uses the word just once and the government in getting to this point has consistently sought to avoid the phrase spatial planning. Spatial planning under the current policy regime, PPS 1, “goes much further than traditional land use planning”. One is led to conclude that in some way this government wishes to get back to traditional land use planning. I will argue that this is a retrograde step.

3. The country faces a complex hierarchy of issues many of which have a spatial dimension. The global economy and climate change are supra national challenges, the imbalance in our economy is an intra- or sub-national problem. The most effective role for a NPPF is to provide a strategic policy context so that local action can be aligned and synergized to achieve national aims. On the contrary, the NPPF fails to provide such a context. The European dimension of growth and the regional imbalances in the UK get no mention. There is no clear exposition of how local climate change action on mitigation or adaptation can contribute to global action. .

4. The government rightly acknowledges the need to “rebalance the economy”. This too has a clear spatial dimension. The variation in economic performance and of social conditions has bedeviled the UK economy for many years and is still ensuring that our potential is not being fulfilled. The recession and fiscal crisis will inevitably add to those disparities. Yet the NPPF has nothing to say about how these spatial disparities can be addressed through the planning system.

5. The government places great emphasis on localism, which I n principle is entirely appropriate. However it is clear that this emphasis has been at the expense of a coherent national and sub national framework. The aversion to “top-down” targets is in danger of abrogating the natural role of government in this arena that is unquestioned in other spheres. One of the first acts of the government was to throw away the by now well-established tools for sub national spatial planning, the Regional Spatial Strategies. It is inconceivable that the ad hoc collaboration of councils and LEPs will fill the vacuum that has been created and would in any case take a great deal of time when time is of the essence. It is simply not credible that the sum total of “local plans”, modified in an ad hoc way through sporadic co-operation will amount to a national spatial plan. There is in reality no contradiction and need not be any conflict between localism and a national planning framework, quite the opposite. The one gives meaning and direction to the other and a clear national spatial plan will enable localism to flourish. The NPPF as it stands lacks, in cybernetic terms, requisite variety. It is not adequate to support the weight of expectations that the government places on it. The tensions that this will create with localism will generate great problems unless resolved.

6. The government may aver from a national spatial plan. But it is the clear implication of a national spatial planning policy. The NPPF would be strengthened and the government’s aims facilitated if it articulated such a spatial plan. This would address the key issues of sustainable development and of improved economic performance and inform the need to provide for more and better homes. In part this national framework has been articulated in so far as major infrastructure is concerned. This needs to be extended and brought back within an integrated planning regime. The key is strengthening the planning regime i.e. making it more effective and fit for purpose in order to deliver the governments priorities. Without this national spatial framework the government is denying itself a powerful tool.

7. The potential for spatial development frameworks has been demonstrated in the European context and it is essential that the English NPPF draws on that good practice. The aims set out in the second National Planning Framework for Scotland for instance are very much in line with the concept of a NPPF that is being suggested here. A NPPF of this nature would provide a spatial framework for integrating a wide range of significant policy, development and infrastructure decisions, public and private. A spatial dimension has been lacking from decision making many spheres and this has resulted in a lack of coordinated or joined up policy and implementation, which has been clearly identified as a national weakness in many authoritative reports in the past. The NPPF offers a unique opportunity to imbue public and private policy and investment decisions with a spatial dimension. The integrative potential of such a framework would be entirely positive. The private sector in particular would welcome such a clear statement of spatial priorities and would invest with greater confidence. Public sector policy and investment would benefit too. The NHS for instance has a demonstrably poor record in integrating a spatial perspective with the result that major hospital investment has been made in the sub optimal locations and a postcode lottery has operated in healthcare generally.

8. The NPPF as its stands represents, above all, a gigantic missed opportunity. The question that should have been asked to how can national priorities best be delivered through the planning system not how can planning be manipulated so as to conform to political priorities. That way it is being set up to fail. Hopefully this paper has sketched a powerful alternative vision.

September 2011

Prepared 20th December 2011