Communities and Local Government CommitteeWritten evidence from Rochford District Council

Rochford District Council is concerned with how sustainable development is defined within the draft National Planning Policy Framework (NPPF), for the reasons set out below.

The definition of sustainable development within the draft NPPF appears to deviate from the long accepted definition set out in the Report of the Brundtland Commission published in 1987. Whilst accepting that the term is somewhat vague and open to interpretation, the Brundtland definition that sustainable development is concerned with meeting the needs of the present without compromising the ability of future generations to meet their own needs, is generally accepted as reflecting an appropriate balance between environment, social and economic factors. However, the definition within the NPPF appears to place greater weight on economic issues, abandoning this balance.

The definition within the NPPF appears to favour additional development ad infinitum—specifically through the incorporation of “increasing housing supply” within the definition. Instead “providing sufficient accommodation to meet the needs of present and future generations” would be a more appropriate definition and would also account for the fact that not all sections of the community’s accommodation needs can be met through housing.

As a coastal District, Rochford is significantly constrained in terms of the environmental sensitivity of the area. Much of the land mass to the east of the District has European designations including Sites of Special Scientific Interest, Ramsar sites, Special Protection Areas and Special Areas of Conservation. Amongst other significant designations such as Ancient Woodland and Special Landscape areas, the District is also predominantly Green Belt.

Whilst individual developments may not directly impact on such designations, there is concern over the cumulative effects, including indirect impact from multiple developments within proximity to environmentally sensitive areas.

This definition of sustainable development, combined with proposed national planning policy which places a presumption in favour of planning applications which meet this definition, raises concerns for the long-term future impact on Districts such as Rochford, and the cumulative impact of future development that it promotes within areas home, or in close proximity, to environmentally sensitive areas.

Given the above, and the fact that the NPPF clearly states that economic growth should be given significant weight when making decisions, this poses a considerable challenge for areas such as Rochford which are heavily constrained by environmental and landscape designations but appreciate the need to balance this against meeting housing need and supporting local economic growth.

The definition as worded within the NPPF means that local authorities will find it very difficult to strike the appropriate balance between economic, social and environmental development to best meet local needs.

The NPPF definition of sustainable development and the presumption in favour of sustainable development generates a potential contradiction with the Natural Environment White Paper. It does not fully take into account the economic value of the natural environment and the contribution it can make towards sustainable economic growth. Although the NPPF is referred to in the White Paper, stating that it has been “made clear that our top priority for the NPPF will be to support long-term sustainable economic growth, with a new presumption in favour of sustainable development. The NPPF will provide communities with the tools they need to achieve an improved and healthy natural environment as part of sustainable growth, taking account of the objectives set out in this White Paper.” (page 22), it is not considered to take a positive enough approach to environmental considerations to reflect the objectives of the White Paper. The White Paper acknowledges that “Economic growth and the natural environment are mutually compatible. Sustainable economic growth relies on services provided by the natural environment, often referred to as ‘ecosystem services’.” (page 4). The Government does, however, recognise the importance of the natural environment and the valuable direct and indirect functions that it can provide (such as food and climate regulation respectively).

The intention is to move towards a green economy where the value of the natural environment is appropriately accounted for, and it is acknowledged that “Too many of the benefits we derive from nature are not properly valued …When nature is undervalued, bad choices can be made.” (page 4). The Government also aspires to make this “the first generation to leave the natural environment of England in a better state than it inherited.” (page 3), generally through moving from net biodiversity loss to a net gain and improving the connectivity of habitats. There is concern that the definition of sustainable development within the NPPF will undermine this objective.

September 2011

Prepared 20th December 2011