National Planning Policy Framework

Written evidence from Paul Appleby CEng FCIBSE FRSA

Executive Summary

This memorandum sets out my view on the Draft National Planning Policy Framework published in July 2011 in response to the joint inquires by the CLG and Environmental Audit Committees. The following views specifically focus on issues relating to sustainable development:

· Economic growth should not be used as an indicator of sustainable development, giving the impression that local authorities should use this as their main measure for assessing planning applications.

· There will be a burden on local authorities to have the skills and resources required to weigh up the benefits of each planning application against adverse impacts.

· Most developments have both socio-economic benefits and adverse environmental impacts.

· The NPPF allows ‘as a last resort’ compensation to be paid for a development that significantly harms biodiversity.

· The wording relating to flood risk is not as strong as that in the 2011 National Flood and Coastal Erosion Risk Management Strategy for England.

· Some of the types of development that could be allowed in the Green Belt, such as limited affordable housing, engineering operations and renewable technologies, are worrying.

1.0 Introduction

1.1 As a freelance consultant I specialise in the sustainable design of buildings and providing advice to design and masterplanning teams on all aspects of sustainability. I graduated with a first class honours degree in Environmental Engineering in 1975 since when I have worked as a mechanical services design engineer, a lecturer and researcher, setting up my own consultancy in 1988. This became Building Health Consultants Ltd, which remains today as part of URS Scott Wilson. In 2000 I establish the Building Sustainability Unit at URS, from which I retired at the end of 2008.

1.2 I have some 60 publications to my name including the book Integrated Sustainable Design of Buildings which was published in January of this year by Earthscan. It is a comprehensive guide to sustainable design, masterplanning and construction, designed for a global marketplace, but with a particular focus on the UK.

2.0 Sustainable development

2.1 I am concerned about the way the Draft NPPF interprets the definition of sustainable development. Although referring to the classic definition from the 1987 Brundtland report it goes on to state that ‘without growth, a sustainable future cannot be achieved’. So in essence the presumption is in favour of economic growth as an indicator for sustainable development. This argument is then used to justify the requirement that local planning authorities should ‘approve all individual proposals where possible..... unless the adverse impacts of allowing development would significantly and demonstrably outweigh the benefits’. The risk is that, without a prescriptive approach to setting out what constitutes adverse impacts, there will be a considerable reliance on the skills and judgement of the planning officers in weighing up the adverse impacts against the benefits.

2.2 Whilst most well planned and designed developments will bring both social and economic benefits, It could be argued that all development damages the environment in some way, either through the carbon emissions and use of non-renewable resources required for construction and operation or through damage to ecosystems, waterways, air quality etc. Even so-called zero carbon buildings will have carbon and greenhouse gas emissions associated with plug-in devices, construction and demolition, whilst almost all development will result in increased traffic movements, water use, waste processing, ecological damage and the like.

2.3 The National Ecosystems Assessment carried out between 2009 and 2011 reports that some 30% of ‘ecosystem services’ from the natural environment have declined in the last 60 years, whilst others are in a reduced or degraded state. There will be pressure on the countryside from the construction of 10 million new homes projected over the next 40 years. Although the NPPF incorporates much about protecting biodiversity it allows ‘as a last resort’ compensation to be paid for a development that significantly harms biodiversity.

2.4 The Draft NPPF also addresses flood risk by requiring developers to ‘avoid inappropriate development in areas at risk of flooding by directing development away from areas at highest risk or where development is necessary, making it safe without increasing flood risk elsewhere.’ Tellingly this is not as strong as the wording in the 2011 National Flood and Coastal Erosion Risk Management Strategy for England which states that ‘it is essential that spatial planning ensures that new developments take flood and coastal erosion risk fully into account, and are safe from, do not increase, and where possible reduce risk over their lifetimes.’

2.5 I am surprised by the number of circumstances there are for which permission may be given for development in the Green Belt, including ‘limited affordable housing for local community needs under policies set out in the Local Plan’, ‘engineering operations’ and ‘renewable energy projects’ that demonstrate ‘wider environmental benefits’. The latter could include just about any wind farm, solar farm or biomass power station and associated infrastructure.

Paul Appleby
8 September 2011