National Planning Policy Framework

Writtten evidence from the Association of Directors of Environment, Economy, Planning & Transport (ADEPT)

 

The Association of Directors of Environment, Economy, Planning & Transport (ADEPT) represents local authority Strategic Directors who manage some of the most pressing issues facing the UK today. The expertise of ADEPT members and their vision is fundamental in the handling of issues that affect all our lives. Operating at the strategic tier of local government they are responsible for crucial transport, waste management, environment, planning, energy and economic development issues. ADEPT membership is drawn from all four corners of the United Kingdom.

 

ADEPT welcomes the opportunity to submit evidence to this Select Committee, having undertaken significant work on reform of planning in the past, including contributing to debate on the Planning and Compulsory Purchase Act 2004, and the Local Democracy, Economic Development and Construction Act 2009.

 

ADEPT recognises that the National Planning Policy Framework (NPPF) has received a lot of media coverage and many groups have provided initial views and picked up on technical issues.  Rather than focusing on technical issues, ADEPT wants to highlight a number of fundamental areas where it believes that further attention is needed including through the Select Committee process.  These include:

 

1.       Two-tier area workings.  Whilst the NPPF recognises that in The Capital there is a need for a strategic approach taking into account the intricacies of two-tier working, there is a policy disconnect with the rest of the Country.  It fails to understand and address the workings of two-tier areas and the roles of County Councils which relate to the planning system, particularly in relation to infrastructure planning and provision, supporting economic growth and creating sustainable communities.  An example of this is the vagueness in paragraph 45 on the issues which require a more strategic approach.  ADEPT believes that there are significant risks with not having a strategic overview of local directions.  The NPPF also fails to make a link with the statutory Local Economic Assessments, prepared by upper tier authorities, which could and should provide a valuable evidence basis for Local Plan and Neighbourhood Plans and the strategic infrastructure framework supported by ADEPT and others (see below). 

 

2.       Infrastructure.  A step change in growth and productivity is dependent on the infrastructure being in place to enable it to happen.  This includes the provision of fibre optic networks, roads, schools or other infrastructure.  It also requires a more than local approach.  Whilst this is acknowledged by the approach that Government is currently taking to the roll out of next generation broadband, it is not dealt with sufficiently in the NPPF.  A mechanism is needed to enable, and ensure, a strategic approach to infrastructure.  Also to ensure that this is developed, and determined, on a joint basis.  ADEPT proposes that this should involve a requirement to prepare a strategic infrastructure framework.   ADEPT supports amendments to the Bill which have been introduced in the House of Lords on this matter.

 

3.       Viability.  The view of ADEPT (and indeed many others) is that the NPPF takes a too narrow view of viability - focusing only from the developers perspective.  ADEPT believes that this is flawed as it fails to address viability from the public or community perspective should a development proposal place an unaffordable costs on the public purse.  It should not be the role of local communities to under-write the costs associated with the impact of development as this should be properly borne by developers.  Not all development can be viable at all times and it would be wrong to set viability criteria at the bottom of the economic cycle.

 

4.       Transition to a new system.  ADEPT believes that this needs to be carefully managed and Government needs to move quickly to avoid lengthy uncertainty.  The transition also needs to be properly resourced (including resources for local authorities).

September 2011