Communities and Local Government CommitteeWritten evidence from Colin Johns

Summary

The draft NPPF does not provide sufficient and clear guidance

The definition of “sustainable development” is not adequate and does not emphasis the vital importance of the careful management of land use

The policies contained in the NPPF are not sufficiently evidenced-based or the evidence base is not explained.

Guidance

As is outlined in Planning Policy Statement 1—Planning for Sustainable Development, planning exists to ensure that decisions on future land use and activity are undertaken in the public interest. The draft NPPF does not present this essential message but instead places too much emphasis on the promotion of development as a short-term means of seeking a way out of the present economic crisis.

The value of clear and concise Planning Policy and Guidance is that it provides a framework for decision making that is of benefit to all that are involved in the process. The draft NPPF seems to be predicated on its brevity but in so doing loses a valuable opportunity to create certainty in the development process. Certainty creates confidence and this should be that aim of the NPPF.

Sustainable Development

The definition of "sustainable development" in the context of planning for the future is too vague and too much open to interpretation and in this respect the attention of the Committee is drawn to the valuable work undertaken in the production of the Foresight Land Use Futures Project Report (2010) published by the Government Office for Science.1 This report highlights the importance of land use and the need for an integrated perspective. To quote the report:

“Land and its many uses provides the bedrock of the country and the foundation for our well being, prosperity and national identity. The pervasive effects of change in land use and management underline the need to take the broadest possible perspective in developing future policies and strategies on land. While much has been achieved over recent decades there is a strong case to do more.”

The report goes on to confirm what has long been recognised that land is one of our greatest assets. How it is used and managed affects everyone's prosperity and quality of life. The productive capacity of land underpins the whole economy through its provision of food, timber and other goods, and through its use for housing, business, transport, energy, recreation and tourism. Land also plays a crucial role in providing services that are vital for the physical well being of the population such as clean water and healthy soils. With some of the most beautiful and historic landscapes in the world, it underpins our national identity and cultural heritage.

It is against this comprehensive and far reaching analysis that the draft National Planning Policy Framework needs to be judged. The five principles of sustainable development quoted in the Foresight Report (Figure 1.1 page 46) are more coherent and relevant and should be used to inform the NPPF. A careful reading of the aims of the NPPF against the comprehensive analysis within the Foresight Report is essential.

The definition of sustainable development in the draft NPPF is incomplete. It is fundamental to effective planning that providing for the needs of the present does not jeopardise the future and this means that decisions should not always follow the market. Planning decisions are for the most part irrevocable. Substantial investment in infrastructure and in major projects cannot be reversed without huge cost, which indicates that decision-making must be based on sound principles. The presumption in favour of sustainable development can only be valid where a comprehensive definition of sustainable is both stated and understood.

Evidence Base

There is little sign that the policies contained in the draft NPPF are in any way evidence based. There is a strong presumption in favour of development simply on the basis that it is said that it will provide much needed economic growth in the short term. This is not a sensible way for the country to proceed because there are numerous examples of development that has taken place to meet immediate needs, or to achieve high profits, that make no long-term contribution to the well-being of society. The general tone of the NPPF is heading in the same direction.

The essential component missing from the NPPF is putting it in the wider long-term sustainable context. In a country with limited availability of land and with a large population, it is simply not realistic to rely on the promotion of development to achieve the county's needs and aspirations unless placed within a proper context. There should, first of all, be the identification of key assets and how they should be protected together with a recognition that decisions are of vital long-term importance. A proper assessment of existing problems and opportunities and a full examination of long-term potential should provide the starting point for the scale and pace of change.

September 2011

Reference

1 Foresight Land Use Futures Report (2010)Final Project Report by the Government Office for Science LondonURN 10?631

Prepared 20th December 2011