Communities and Local Government CommitteeWritten evidence from Levett-Therivel Sustainability Consultants

This submission responds to the Committee’s question:

“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?”

This submission is endorsed by several other leading thinkers and practitioners, listed at the end.

Summary

The definition of “sustainable development” in the NPPF is inconsistent with international agreements, the UK’s sustainable development strategy, the academic literature and general usage. It misrepresents one of the two most important and distinctive features of sustainable development, namely the aim to advance human wellbeing understood in broader terms than just economic development. It ignores the other, namely the need to do this without compromising the interests of future generations, including by maintaining environmental support systems.

The “presumption in favour of sustainable development” as defined in the NPPF is no such thing. It is simply a presumption in favour of business-driven growth dressed up in misleading language. It is not “balanced” in any meaningful sense. It is all too “workable” in the sense that developers would be able to use it to get permission for bad developments which planning authorities could currently stop or make the developers improve.

Full Response

International and UK definitions of sustainable development

There is a notoriously huge number of definitions and interpretations of sustainable development in circulation, reflecting the wishes of many different organisations and interests to claim its support. Pedantic argument about definitions can easily be sterile and inconclusive. But this does not mean the concept is meaningless or can be stretched to cover anything. The edges may be fuzzy and disputed, but it is entirely clear what the central idea of sustainable development is. It is also entirely clear that the NPPF definition lies outside any reasonable interpretation of it, as we will aim to show in this submission.

Two international definitions are very widely quoted and invoked: the Brundtland Commission’s:

“development which meets the need of the present without compromising the ability of future generations to meet their own needs”

and the IUCN/UNEP/WWF’s “Caring for the Earth” formulation

“improving the quality of human life while living within the carrying capacity of supporting eco-systems”.

What is distinctive about both these definitions is that they combine an aspiration to make life better for people (“meeting the needs of the present”, “improving the quality of human life”) with recognition of a constraint—the need to avoid undermining the future, and specifically the limits of the capacity of natural ecosystems to act as life support systems, provide resources and assimilate wastes. The aspiration and constraint are to be reconciled and integrated, not traded off: the aim is to make life better without betraying the future, not to decide how much future damage we are willing to cause for our current convenience.

The UK sustainable development strategy does not state a definition of sustainable development but does highlight the following “purpose”:

“The goal of sustainable development is to enable all people throughout the world to satisfy their basic needs and enjoy a better quality of life, without compromising the quality of life of future generations”.

This is clearly the same idea as the two international definitions just quoted—indeed it amounts to an amalgamated paraphrase of them. The only element it does not explicitly refer to is “living within environmental limits”. However this is one of the strategy’s five “guiding principles”.

Meeting needs, quality of life

What these definitions mean in practice depends on what “meeting human needs” and/or “improving the quality of life” entail. They have to entail more than just economic growth: if they didn’t, sustainable development could have been defined simply in terms of delivering economic growth, saving a great deal of time and trouble researching and arguing over them. However the result of all this time and trouble is a very wide consensus that material prosperity is only one component of quality of life, with other components including good physical and mental health, good relations with family and friends, safety and security, freedom from fear and stress, pleasant, safe living environments, and freedom of conscience, faith and expression.

It is also now very widely acknowledged that economic growth is only a partial and unreliable measure even of material prosperity, because such matters as levels and distribution of employment and unemployment, economic security, poverty, work/life balance, social (im)mobility, access to education and the costs of necessities such as housing, worth and food relative to disposable incomes matter too. In wealthy, developed countries such as the UK, if there are still basic needs being unmet, this is more due to how the wealth—and means of generating it—is distributed than to a lack of overall economic growth. Considerable research on wellbeing and quality of life suggests that in developed economies such the UK further economic growth may not improve wellbeing and may even undermine it.

This complexity is acknowledged and reflected in the UK sustainable development strategy:

“The issue of wellbeing lies at the heart of sustainable development, and it remains important to develop appropriate wellbeing indicators. Many of our existing indicators cover issues that affect people’s wellbeing, for example employment, community participation, education, housing conditions, health, income, and the environment more generally. What is missing is a means of making sure that wellbeing issues are being tackled consistently, in the right way, and that we are genuinely making a difference to people’s lives. Some appreciation of this may in part be provided by extending our indicators to include such issues as mental health, access to sport and culture, green space, neighbourliness, which we will explore.”

Consistent with this, of the 11 “issues that affect people’s wellbeing” named in the strategy (seven already covered by indicators, four to be explored) only two are economic. One of these is “employment”. Only one, “income”, is directly related to growth.

How does the NPPF interpret sustainable development?

A whole section early in the NPPF is devoted to “delivering sustainable development”. We consider this in detail.

Para 9 quotes the Brundtland definition and paraphrases the UK strategy “purpose”.

Para 10 offers a new version of an old formulation that sustainable development involves economic, social and environmental aims. So far as their very general wording allows us to judge, the “social” and “environmental” indents are consistent with sustainable development principles as stated above. However the “economic” indent is at best irrelevant to sustainable development, and provides a reminder that one reason this once popular “three rings” or “three legs of the stool” interpretation of sustainable development has fallen out of favour in recent years is that it implies that the economy is an end in itself and not just a means to meet human needs.

Para 11 states that goals should be integrated and reconciled, which is a central tenet of sustainable development thinking (and indeed of good public policy generally), and para 12 states that the policies as a whole set out the Government’ view.

So far so harmless.

Paragraphs 13 and 14 are where things start to get sticky. We quote the key passage in full:

“13. The Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth. A positive planning system is essential because, without growth, a sustainable future cannot be achieved. Planning must operate to encourage growth and not act as an impediment. Therefore, significant weight should be placed on the need to support economic growth through the planning system.

14. At the heart of the planning system is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan making and decision taking. Local planning authorities should plan positively for new development, and approve all individual proposals wherever possible.”

By using “sustainable economic growth”, “growth”, “economic growth” “sustainable development” and “new development” interchangeably, and without defining any of them, this passage seeks to imply that they are all the same thing.

This systematically fails to understand—or perhaps deliberately tries to muddle – several important distinctions, which the definitions discussed above mark out, and which the extensive literature on sustainable development policy and implementation explains:

“Development” as in “sustainable development” means human progress, advancement, realisation of potential and search for fulfilment in a broad sense. Increases in material consumption and prosperity are at best only a part of this. It is questionable whether, in already prosperous economies such the Britain, further economic growth will in itself make any significant contribution to development in this sense. Indeed there is a considerable body of evidence and opinion that materialism and consumerism are now obstacles to it.

Economic growth is in any case a partial and unreliable measure even of material prosperity since it includes things which reduce prosperity (such as traffic accidents, oil spills, war) as well as excluding things which add to it (such as community cohesion, most artistic activities), and says nothing about how economic costs and benefits are distributed, which makes a big difference to how much welfare a given total amount of economic activity will achieve.

“Development” in this broad sense of human advancement is also quite different from what “development” means in the planning system, which is physical buildings and infrastructure. Using the desirability of the former as a justification of the latter is a like assuming that members of the nobility (earls, barons etc) have noble (in the sense of altruistic, generous etc) characters.

Thus the NPPF’s “presumption in favour of sustainable development” is no such thing. It is simply a presumption in favour of business-driven growth dressed up in misleading language.

How would the NPPF affect sustainable development?

Actions speak louder than words: it would not matter much if the NPPF defined sustainable development in an eccentric or defective way if its policies still promoted the real thing. Would they?

A great deal of policy in the NPPF is supportive of aspects of sustainable development. However it is generally weaker and vaguer than the regulations and guidance it is intended to replace: better than no national planning policy or guidance at all, but worse than what we currently have. (The NPPF’s Impact Assessment is misleading because it frequently compares the NPPF to nothing, rather than to the current position or to other possible reasonable alternative planning reforms, let alone the full “toolkit” of potential government interventions to motivate and incentivise good development.)

The NPPF does not even mention environmental limits, let alone discuss how this central concept of sustainable development should be recognised and applied through the planning system. At a more detailed level the NPPF removes current requirements and guidance on:

prioritising development of previously developed land, which helps to make best use of land, reduces the need to travel, and preserves the countryside;

maximum car parking spaces, which help to support the move to non-car travel with associated social and economic benefits, and to make neighbourhoods more liveable; and

noise exposure categories, which protect residents from noise.

The NPPF also weakens and provides much less detail than the existing PPG/PPSs on green infrastructure (which provides health and biodiversity benefits) and regional scale infrastructure (which prevents unacceptable impacts such as flooding and contaminated water).

However the most serious and alarming problem with the NPPF’s treatment of sustainable development is its prominent and repeated insistence, in language that can only be described as threatening, that economic growth must take priority over other objectives. For instance:

“the planning system does everything it can to support sustainable economic growth” (para 13)

“Planning must operate to encourage growth and not act as an impediment” (para 13)

“Local planning authorities should plan positively for new development, and approve all individual proposals wherever possible” (para 14)

“plans should be prepared on the basis that objectively assessed development needs should be met, unless the adverse impacts of doing so would significantly and demonstrably outweigh the benefits” (para 20) The NPPF does not define what is meant by “objectively assessed development need”. At least one government document – the National Policy Statement for energy – conflates “proving need” with “developer application for development consent”.

“To enable each local authority to proactively fulfil their planning role, and to actively promote sustainable development, local planning authorities need to ... : attach significant weight to the benefits of economic and housing growth” (para 54).

These statements give planning authorities a very strong steer only to apply the admirable aspirations set out in the “Planning for people” and “Planning for places” chapters of the NPPF to the extent that they are either backed by other, non-planning, laws and regulations such as statutory environmental designations, or will not hamper developers’ pursuit of private profit: in other words, only where they will not make any significant difference to what would have happened anyway. This would reduce the planning process to little more than a decorative ritual prelude to development where, when, and how developers want.

A missed opportunity to reconcile private and public goods

There is, as para 11 correctly notes, “no necessary contradiction between increased levels of development and protecting and enhancing the environment”. (Emphasis added.) It is in principle possible to reconcile the two. It is also in principle possible for economic growth to advance human development, and for physical construction to serve human development.

Reconciling these is what planning is for. In asserting that sustainable development means nothing more than economic growth and that planners should not hinder development, the NPPF seeks to suppress the main purpose and pivotal function of plans and planning authorities: to define, and apply, constraints, conditions and criteria to ensure, so far as possible, that the physical development of land which companies and households wish to bring forward for their own commercial and private reasons does improve the quality of life, meet human needs, safeguard the future and minimise environmental damage.

Conclusion

“Sustainable development” as defined in the NPPF cannot honestly be given this name. It reflects either remarkable ignorance of the most basic and simple ideas of sustainable development, or – we think more probably – a cynical attempt to distort and misrepresent the concept to provide spurious support for a pro business agenda. The NPPF’s combination of pressure for economic growth and weakening of counterbalancing controls would lead to thoroughly unsustainable development.

The NPPF’s reference to the presumption in favour of sustainable development (misdefined as growth) as a “golden thread running through both plan making and decision taking” reminds us of King Midas who learned too late that turning everything you touch into gold is a calamity not a blessing.

Levett-Therivel

Levett-Therivel Sustainability Consultants are leading specialists in planning and public policy for sustainable development. This submission draws on our partners’ experience including:

A series of detailed assessments, for the Sustainable Development Commission and others, of UK policies for sustainable development and their effectiveness.

Reports, analyses and guidance publications on the application of sustainability to policy areas including economic development, urban and rural policy, energy, transport, food farming and agriculture, sport, heritage and environmental health.

Developing, promulgating and applying tools and instruments for sustainability, notably Eco-Management and Audit for public bodies, Strategic Environmental Assessment, Sustainability Reporting, indicators and Quality of Life Capital.

Research for Government departments and others on wellbeing and its policy implications.

Producing Government guidance on sustainability appraisal in the planning system, carrying out numerous sustainability appraisals and other related appraisals of plans and strategies at all levels from national to local, and comparative assessments of how different plans and kinds of plan deal with sustainability.

Producing a plain language summary of Agenda 21 (the 600 page “blueprint for sustainable development” agreed at the 1992 Rio Earth Summit).

Researching and writing much of the UK local government guidance on sustainable development through the 1990s.

We have provided our contact details separately for data protection reasons as the Committee asks. However any search engine will easily find us and our work.

Other Signatories

This submission is also endorsed by the following individuals (names in bold type, listed alphabetically.) They sign in a personal capacity: organisational affiliations are stated only to illustrate signatories’ experience and expertise, and do not imply that the organisations endorse this submission.

Alan Bond, Senior Lecturer in Environmental Management, based in the School of Environmental Sciences, University of East Anglia, with over 20 years experience in environmental and sustainability assessment including:

Development of Guidance on scoping in environmental assessment for the Environment Agency.

Research for Government (Defra) related to application of strategic environmental assessment and sustainability assessment related to radioactive waste.

Training a large proportion of local authorities in England and Wales in Environmental Assessment in the 1990s.

Publication of articles and a forthcoming book on sustainability appraisal.

Research for a variety of health organisations and the Welsh Assembly Government on interfaces between health and planning.

Technical advice to Institute of Environmental Management and Assessment on environmental assessment since 2003.

Provision of health component of UNECE SEA Protocol Guidance.

Professor Andrew Dobson, Professor of Politics at Keele University.

Scott D. Johnson, BSc MSc AIEMA, sustainability consultant who coordinates sustainability appraisal and strategic environmental assessment practitioners for an international, multi-disciplinary consultancy. His clients include national Government agencies, national and regional utilities companies, local authorities and private developers. He conducts sustainability work in a wide range of sectors, including spatial/town planning, energy, nuclear, minerals, waste, passenger tranport and sea / rail freight transport.

Mark Southwood of Temple Group, a consultancy that carries out EIAs and SEAs including the SEA for HS2.

Jo Treweek and Orlando Venn of Treweek Environmental Consultants, who specialise in ecological aspects of environmental impact assessment at project and strategic levels as well as providing advice to businesses on biodiversity and ecosystem services. Much of our work is focused on identification of development solutions which are compatible with sustainable use of ecosystems. We work with engineers and planners to develop mitigation strategies which avoid impacts at source, maintain them within the limits of environmental capacity or offset them. Examples of our experience include:

Advice on biodiversity offsets to DEFRA.

Development of biodiversity targets for Regional Spatial Strategies.

Appropriate Assessment under the EU Habitats Directive.

Participation in IEMA’s EIA Quality Mark review process.

Research on assessment of impacts on ecosystem services with the World Resources Institute.

Technical inputs to the Business and Biodiversity Offset Program.

Elizabeth Wilson, BA MPhil MRTPI Reader in Environmental Planning Oxford Brookes University Elizabeth has experience in local government planning, and in research and teaching in the fields of spatial planning, environmental assessment, and climate change. Her research has included contributing to the EPSRC-funded Adaptation Strategies to Climate Change in Urban Environments (ASCCUE), to the Defra-funded review of Climate Change and the England Biodiversity Strategy, and to EU 6th Framework funded research Minimisation of and Adaptation to Climate Change Impacts on Biodiversity (MACIS).

She is the author, with Dr. Jake Piper, of Spatial Planning and Climate Change (Routledge, 2010).

Dr. Graham Wood, Reader in Environmental Assessment and Management at Oxford Brookes University, specialising in environmental decision-making, with an emphasis upon the use of information and the exercise of value judgements within planning. He has particular interests in the field of information analysis, evaluation, and communication for decision-making. He has 14 years of relevant research and consultancy experience for a range of clients including the Economic and Social Research Council, the Natural Environment Research Council, DEFRA, European Commission, European Investment Bank, Transco, Vodafone, and Associated British Ports.

September 2011

Prepared 20th December 2011