National Planning Policy Framework

Written evidence from Alan Butland

Summary:

I do not believe that the NPPF gives sufficient guidance or gives local communities

sufficient power over planning decisions in matters relating to culture, the arts and theatres. Without national guidance, at a local level, planners may overlook the

contribution theatres and the performing arts make to the wellbeing and vibrancy of communities within their local plans.

The NPPF is silent on culture. My concern is that Inspectors will not consider the

need for specific policies on culture, the arts and theatres in local plans, as they do currently.

Theatres are vulnerable facilities and as the presumption will be in favour of those uses that are covered within the NPPF, no matter how valued they are by the local community. Their protection and use will only be properly considered and protected if there is guidance on culture within the NPPF, which will give culture the same status as other uses.

The definition of ‘sustainable development’ contained in the document needs to be clearer

on culture. The presumption in favour of sustainable development is not balanced or workable.

The ‘United Cities and Local Governments’ (UCLG) approved in 2010 a policy statement recognising culture as the fourth pillar of sustainable development, next to economic growth, social inclusion and environmental balance.

At present leisure, sport and heritage are explicitly recognised within the draft NPPF. Culture, the arts and theatres are not. The reduction of policy guidance, particularly in relation to PPS4 in the new NPPF has meant that there is a lack of clarity surrounding culture, the arts and theatres and the role they play in achieving balanced sustainable development.

The core planning principles are not clearly and appropriately expressed.

Culture is a core planning principle. It keeps the spirit of places alive, is essential to our wellbeing and currently has its own policies distinct from leisure and sport in existing local planning policies and other national and regional plans. Culture must be included in the NPPF.

The relationship between the NPPF to other national statements of planning-related

policy is not sufficiently clear. PPS4 states that the main uses to which the town centre policies in the PPS apply are for ‘arts, culture and tourism development (including theatres, museums, galleries and concert halls, hotels and conference facilities).’ The same strength of this policy is not carried forward into the NPPF.

The NPPF does not integrate national planning policy in respect of the Government’s commitment to culture and the arts and the sectors supported by the Department for Culture, Media and Sport (DCMS). The DCMS works with the Department of Health on ways that the arts can help improve wellbeing in the UK. Yet culture is not referred to within the NPPF under health and wellbeing. The DCMS works with DCLG on using the arts to regenerate local communities and recognises the important contribution that the arts make to the UK economy but there is no consideration of policies to support culture’s contribution to economic development within the NPPF.

The NPPF, together with the ‘duty to cooperate’ does not provide a sufficient basis for larger-than-local strategic planning on culture.

Theatre buildings not-in-theatre-use are at the greatest risk. I have recently moved to the north of England and am already concerned at the number of theatre buildings, which are facing closure and demolition.

Without concise NPPF policies that establish culture’s contribution to sustainable development I fear the loss of theatre buildings in towns which already have little else in the way of cultural facilities.

Good strategic spatial planning is vital to national interests. There is a case for inclusion of culture in the NPPF. Planning for culture is indeed of national interest.

The NPPF is not sufficiently evidence-based.

Alan Butland

September 2011

Communities and Local Government Select Committee

Inquiry into the National Planning Policy Framework

Response from Alan Butland, Theatre Researcher

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?

1) I do not believe that the NPPF gives sufficient guidance or gives local

communities sufficient power over planning decisions in matters relating to culture, the arts and theatres.

2) The NPPF stresses the contribution planning can make to the economy, community wellbeing and the environment. But it does not make any specific reference to the contribution that culture, the arts and theatres make to ensuring that communities thrive.

3) The failure to make explicit mention of culture means that the NPPF’s treatment of the types of provision which are championed by the DCMS is unequal. Cultural facilities such as theatres, galleries, libraries, museums and archives have been viewed in the past by the planning system as public services, education facilities and community provision. The prominence and clarity given to sport and the historic environment in the draft NPPF and the failure to explicitly mention and define culture means that in relation to the DCMS sector the definition of sustainable development used in the framework is unbalanced.

4) My major concern, therefore, is that at a local level, planners may overlook the need to consider the contribution theatres and the performing arts make to the vibrancy of communities and local centres within their local plan. An arts facility (for example, one supporting young people in productive cultural activities that deters them from crime) that does not fall easily into existing use classes or a theatre which is not statutory listed, could be demolished to make way for shops, offices and housing, leisure or sports facilities. Campaigners could try to argue a case for the building as an ‘asset of community

value’ (which will come in with the new Localism Bill), but this would be a hard argument to make as within the local plan there will be no protection for such facilities.

5) Furthermore, because the NPPF does not define cultural uses as explicitly promoting sustainable development, other uses that the NPPF does promote will have a far stronger policy basis upon which to argue their case.

6) At an Inspectorate level, as the NPPF is silent on culture> My fear is that Inspectors will not insist on specific policy for culture, the arts and theatres in local plans.

7) Theatres are vulnerable facilities and as the presumption will be in favour of those uses that are covered within the NPPF, no matter how valued they are by the local community, their protection and use can only be properly considered and protected if there is guidance on culture within the NPPF which will give culture the same status as other uses.

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?

8) While the definition of ‘sustainable development’ contained in the document is appropriate, the presumption in favour of sustainable development is not balanced or workable. Although the definition of sustainable development in the draft NPPF includes, for example‘…the need to create a good quality built environment with accessible local services that reflect the community’s needs and supports its health and wellbeing’ [para 10, bullet 3] I believe there is a need to strengthen the guidance by making explicit reference to culture at appropriate points in the text.

9) At present leisure, sport and heritage are explicitly recognised in the draft NPPF. Culture, the arts and theatres are not. The reduction of policy guidance, particularly in relation to PPS4 in the new NPPF has meant that there is a lack of clarity surrounding culture, the arts and theatres, and the role they play in achieving balanced sustainable development. This is particularly the case for theatres which are sui generis.

10) Across the world, local authorities recognise that culture is the fourth pillar of sustainable development, next to economic growth, social inclusion and environmental balance. The ‘United Cities and Local Governments’ (UCLG), which represent over 1000 cities across 95 countries, and includes the Local Government Group in England, approved in 2010 a policy statement recognising this,

Are the ‘core planning principles’ clearly and appropriately expressed?

11) The core planning principles are not clearly and appropriately expressed; bullet 9 should include reference to ‘…taking account of and supporting local strategies for cultural provision’, as part of attempts to improve health and well being.

12) Culture needs to be considered as a core planning principle. Culture keeps the spirit of places alive and is essential to our wellbeing. It enhances and improves the places in which we live and the quality of the lives of communities. The performing arts, in the broadest sense, contribute to people's happiness and wellbeing. Theatre’s ability to entertain, engage and involve is beyond doubt. Theatres also enable young people to demonstrate their skills and potential, and together with external partners help

develop diverse programmes of arts activity that support individuals to develop an understanding of their responsibilities in society and moral compass regardless of background and personal circumstance.

13) Performing arts projects uniquely placed to provide sustainable benefits across society. The need for national policy on planning to include culture is, in my view, essential if we are to achieve sustainable communities and enable them to expand and develop.

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?

14) No, the relationship between the NPPF to other national statements of planning-related policy is not sufficiently clear. The chapter within the NPPF on ‘Business and Economic Development’ incorporates the current policies within Planning Policy Statement 4: Planning for Sustainable Economic Growth (PPS4). PPS4 importantly makes a distinction between leisure, and arts and culture. However the NPPF has lost all the references to culture, the arts and theatres. PPS4 contains important policies that help to promote and protect theatres in towns and cities.

15) At paragraph 7.4 (page 3) PPS4 states that the main uses to which the town centre policies in the PPS apply are for ‘arts, culture and tourism development (including theatres, museums, galleries and concert halls, hotels and conference facilities).’ More explicitly, Policy EC4.2 (page 10) states: ‘Local planning authorities should manage the evening and night-time economy in centres.’ Policies should: ‘encourage a diverse range of complementary evening and night-time uses which appeal to a wide range of age and social groups, making provision, where appropriate, for leisure, cultural and tourism

activities such as cinemas, theatres, restaurants, public houses, bars, nightclubs and cafes’.

16) In Kingston upon Thames I was involved with promoting Purple Flag. The Rose theatre was at the heart of this project locally. Purple Flag has been designed as an objective assessment that will help improve town and city centres at night. Most significantly it is designed to provide recognition that the centre is managing its night time experience and thus help overcome any negative public perceptions that may exist. Purple Flag provides the opportunity for successful centres to present themselves in their true colours and in a positive light to town centre users, including operators, residents, tourists and visitors. It is therefore a core policy for community support and should be further encouraged and promoted. It is through culture that we facilitate social interaction and inclusive communities.

17) The NPPF does not integrate national planning policy in respect of the Government’s commitment to culture and the arts and the sectors supported by the Department for Culture, Media and Sport (DCMS). The DCMS works closely with other Government departments and agencies to make sure that there is an appropriate level of support available for the creative industries. As stated in the Arts Council England’s 2011 paper on

‘Supporting growth in the arts economy’, ‘…our best arts and cultural infrastructure (the most open theatres, connected media centres and interdisciplinary art spaces) have become the ‘spikes’ and ‘intersections’ for creative exchange, operating at once as places (and digital spaces) of creative business transaction, inspirational cultural experience, education, and cross-sector innovation’. Yet the NPPF provides no policies on culture that match the DCMS’s ambitions.

18) The DCMS works with Department for Communities and Local Government on using the arts to regenerate local communities and recognises the important contribution that the arts make to the UK economy. It identifies issues that limit economic and artistic growth and works with the industry to overcome them. But there is no consideration of policies to support culture’s contribution to economic development within the NPPF.

Does the NPPF, together with the ‘duty to cooperate’, provide a sufficient basis for larger-than-local strategic planning?

19) The NPPF, together with the ‘duty to cooperate’ does not provide a sufficient basis for larger-than-local strategic planning on culture. Without any reference to culture,

the arts or theatres in the NPPF it is not explicit that the duty-to-cooperate would cover these sectors, particularly where the future of national and regional theatre provision was at stake. Cuts in local government will impact upon their capacity to cooperate

with community groups who are seeking assurance that theatre provision with national, regional or local significance is included in neighbourhood and local plans.

20) Theatre buildings not-in-theatre-use are at the greatest risk. I have recently moved to the north of England and am already concerned at the number of theatre buildings, which are facing closure and demolition by local authorities that feel unwilling or unable to maintain them. The Palace Theatre in Nelson was demolished in 2009, while North Tyneside Council spent a considerable sum demolishing the Borough Theatre, Wallsend in 2010, and redeveloping it for commercial and residential uses, despite the efforts of local residents to save the building for cultural use.

21) Clear and concise NPPF policies are essential to establish culture’s contribution to sustainable development. Without them I fear the loss of theatre buildings in towns which already have little else in the way of cultural facilities. The Opera House in Workington is the latest example where a local group is campaigning to see the theatre re-opened as an arts facility. The former theatre already has permission for demolition for a commercial development.

22) A strategic approach to good spatial planning is vital to national interests. There is a strong case for inclusion of culture in the NPPF, since planning for culture is in the national interest.

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

23) The NPPF is NOT sufficiently evidence-based. It omits, and needs to clearly

reflect, existing government policy supporting and promoting culture and the arts, as well as business development, the environment and community infrastructure.