Communities and Local Government CommitteeWritten evidence from Living Streets

Living Streets is the national charity that stands up for pedestrians. With our supporters we work to create safe, attractive and enjoyable streets, where people want to walk. We work with professionals and politicians to make sure every community can enjoy vibrant streets and public spaces.

We started life in 1929 as the Pedestrians Association and have been the national voice for pedestrians throughout our history. In the early years, our campaigning led to the introduction of the driving test, pedestrian crossings and 30mph speed limits. Since then our ambition has grown. Today we influence decision makers nationally and locally, run successful projects to encourage people to walk and provide specialist consultancy services to help reduce congestion and carbon emissions, improve public health, and make sure every community can enjoy vibrant streets and public spaces.

Living Streets has taken an active interest in the progress of the National Planning Policy Framework (NPPF), including meeting with Department of Communities and Local Government officials, together with representatives of the Campaign for Real Ale, to highlight the importance of access to local shops and services and the crucial need for active promotion of walking-friendly streets and neighbourhoods within the NPPF. We have also been engaged in discussion with a range of other third sector stakeholders on the issues.

As expressed in our response to the initial call for thoughts on the NPPF, Living Streets called on the Government in our manifesto in 2010 to “set a simpler national framework of planning guidance that is navigable and easy to use”. We welcome the idea of a localist, integrated and concise National Planning Policy Framework that makes it easier and less intimidating for local communities, and civically minded groups such as our own Local Groups, to understand the ways in which they can work with local authorities and other local stakeholders to secure lasting and meaningful improvements to their streets and neighbourhoods.

However, we have some substantial concerns with the provisions of the current draft document and advocate that significant changes are made, in conjunction with relevant stakeholders and experts, before the NPPF is finalised. We would refer the Committee to our consultation response, to be submitted in October, for more detail, but would wish to make a few brief points in response to the Committee’s lines of inquiry.

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

The NPPF as it stands does not provide either sufficient guidance or sufficient power for local communities. It is often vaguely worded: at several points the draft document contains statements that are supportive of environmentally and socially sustainable development, but these are often caveated with phrases such as “where possible” and “where practical”, undermining the importance of elements such as sustainable transport provision and accessibility of local services. If the NPPF is intended to “set out national economic, environmental and social priorities” (Clark, 2010) and to provide a clear direction of travel to local planning authorities, these caveats are unhelpful and should be removed. Other elements such as quality public realm are scarcely mentioned at all.

The presumption in favour of sustainable development, and the stipulation that development should be permitted “unless the adverse impacts of allowing development would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole” is likely in practice to result in permission being given to development that is unsustainable, with local authorities constantly wary of exposing themselves to the considerable financial and other costs of appeals. This would severely undermine the ability of local communities to influence the shape of their areas through engagement in the planning process, hindering rather than furthering the Government’s worthy ambition of more such engagement.

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?

Living Streets does not believe that the definition of sustainable development is appropriate and has supported calls for a robust definition of sustainable development to be included within both the NPPF and the Localism Bill. The Brundtland definition included at Point 9 of the current draft of the NPPF is a useful starting point but difficult to apply in practice, and totally at odds with the stipulation expressed in the draft document that development should, by default, be permitted. More insidiously, the document continually conflates the physical definition of “development” meaning the improvement of land with the broader policy goal of sustainable development. To avoid confusion, ensure consistency and identify a common purpose for planning, Living Streets advocates the inclusion of a credible statutory definition of sustainable development, including, for example, the five principles published by DEFRA:

Living Within Environmental Limits

   Respecting the limits of the planet’s environment, resources and biodiversity – to improve our environment and ensure that the natural resources needed for life are unimpaired and remain so for future generations.

Ensuring a Strong, Healthy and Just Society

   Meeting the diverse needs of all people in existing and future communities, promoting personal wellbeing, social cohesion and inclusion, and creating equal opportunity for all.

Achieving a Sustainable Economy

   Building a strong, stable and sustainable economy which provides prosperity and opportunities for all, and in which environmental and social costs fall on those who impose them (polluter pays), and efficient resource use is incentivised.

Using Sound Science Responsibly

   Ensuring policy is developed and implemented on the basis of strong scientific evidence, whilst taking into account scientific uncertainty (through the precautionary principle) as well as public attitudes and values.

Promoting Good Governance

   Actively promoting effective, participative systems of governance in all levels of society – engaging people’s creativity, energy, and diversity.

We would also draw attention to DEFRA’s statement that “Any trade-offs [between these principles] should be explicit and transparent”.

Living Streets is concerned that the presumption in favour of development, as currently phrased, will work to undermine rather than to promote sustainable development by any credible definition of the term. In particular, we are concerned that this will effectively negate provisions elsewhere in the document for the promotion of sustainable transport, the protection of open spaces and the creation of quality, well-designed places, and will undermine the ability of communities to shape the areas in which they live and work.

Are the “core planning principles” clearly and appropriately expressed?

Living Streets would advocate that several of the core principles go further, as detailed in our consultation response. However, the principle that the default answer to development should be “yes” (as well as implying that the default answer is currently “no”, which RTPI figures have shown to be untrue) further undermines the credibility of the document’s commitment to “sustainable development”. Economically, socially and environmentally sustainable development is a positive outcome that should be the key aspiration for local planning authorities, developers and other stakeholders, rather than a catch-all term for any and all physical development. This point does not relate to any credible “sustainable development principles” and is likely to undermine the other core principles unless radically revised.”

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

The NPPF should strive for closer integration with health and transport policy in particular in order to provide a framework for healthy, well-connected places where active travel is the norm. It should be unafraid to signpost established, key documents such as Manual for Streets and Manual for Streets 2 in order to ensure their prominence without lengthening the document.

Are the policies contained in the NPPF sufficiently evidence-based?

Some policies are not sufficiently evidence-based. A key example is the stipulation that “development should not be prevented or refused on transport grounds unless the residual impacts of development are severe, and the need to encourage increased delivery of homes and sustainable economic development should be taken into account”. This will increase pressure on infrastructure, increase carbon emissions and pollution, worsen the negative social and health-related effects of car use and undermine the ability of local decision-makers to ensure that residents and workers are able to travel sustainably. However, the Government has put forward only anecdotal evidence that the current system has seen a significant number of genuinely sustainable schemes being wrongly refused on transport grounds.

The onus is on Government to make proper evidence available, particularly as on the converse side of the argument a large body of robust evidence exists, for example on the impact of congestion and inadequate transport infrastructure on businesses. The Eddington Transport Study (2006) quotes a 2004 British Chamber of Commerce (BCC) survey in which “three quarters of businesses said that transport delays had caused them to incur increased operating costs in the form of penalties for late deliveries, overtime costs, missed meetings affecting contract negotiations and lower productivity”,i as well as lost person-hours. These problems have continued to escalate: the BCC reported in 2008 that over 85% of businesses considered congestion to be a problem that has a material impact on their livelihoods.ii The costs per year, as estimated by businesses, of problems with the UK’s transport infrastructure stood at £17,350 per business on average in 2008iii and had gone up to £19,080iv by the time of a comparable BCC survey in 2010, an increase of 10%. Throughout these surveys, a lack of alternatives to the car has increasingly been reported by businesses as a key reason for congestion. Effectively removing a lack of sustainable access as a factor in refusing a scheme, as the document as drafted seeks to do, will see this problem worsen further.

Living Streets would be pleased to engage further with the inquiry process.

9 September 2011


i British Chambers of Commerce. 2004. Getting Business Moving. Quoted in HM Treasury and Department for Transport, 2006. The Eddington Transport Study, p 92 para 2.77.

ii British Chambers of Commerce. 2008. The Congestion Question, p 10. Available

iii British Chambers of Commerce. 2008. The Congestion Question, p 22. Available

iv British Chambers of Commerce. 2010. Reconnecting Britain: A Business Infrastructure Survey, p 12. Available

Prepared 20th December 2011