6 Monitoring the NPPF
93. We have been hindered in our efforts to assess
how well the NPPF is operating by the absence of reliable, up-to-date
data. We were struck by two particular examples. First, we have
described how the Minister was unable to provide us with any data
about the amount of retail development taking place out of town.[240]
This led Ian Anderson from the British Council of Shopping
Centres to express concern that there were not "the data
to determine quite the success or otherwise of the NPPF".[241]
He noted that DCLG did collect data on town centre and out-of-town
development "pretty much up to 2009", but that there
had not been any update since then.[242]
Second, we heard that the latest available data about the proportion
of homes built on brownfield sites come from 2011.[243]
Neil Sinden from the Campaign to Protect Rural England told us
that DCLG was now "far less active in getting returns from
local authorities about how much brownfield land they have within
their areas".[244]
This is particularly concerning given the Government recently
made a major policy announcement about brownfield land.[245]
94. The Minister, Brandon Lewis, explained DCLG's
policy on the collection of data. He said that he was "very
conscious about us not getting into a situation where […]
we were collecting an awful lot of data from local government,
much of which was not particularly useful for anybody and was
not being used for anything productive".[246]
In a letter to the Committee, however, he said that the Government
would be consulting on how to make sure data collected by local
authorities in their Strategic Housing Land Availability Assessments
was made available "in a clear, easily accessible and uniform
way".[247] In
a subsequent letter, Mr Lewis confirmed that the consultation
would cover "how to ensure there is clear and transparent
information about the availability of brownfield land going forward".[248]
We welcome the Government's decision to consult on making land
availability data more accessible. Data about the future availability
of land are not, however, enough on their own. We also need to
understand where development in recent years has taken place.
In particular, the absence of recent data about town centre and
out-of-town development and the proportion of homes built on brownfield
land is making it difficult to assess how successful the Government's
policies have been and how they may need to change. This creates
a risk that the Government will be making future policy decisions
'in the dark'.
95. The Government's proposed consultation offers
an opportunity to look more widely at how the NPPF might be monitored.
We received a memorandum, jointly written by a number of individuals
and organisations with an interest in planning, urging us to recommend
"the creation of a framework to evaluate the operation and
impact of the NPPF in terms of outcomes over a longer term".[249]
It added that "it would be instructive to analyse what data
and information is currently available, and where there are important
gaps in data and evidence".[250]
We agree that it would be helpful to have clear data with which
to assess the operation of the NPPF. We have seen clearly during
this inquiry the strength of feeling the NPPF generates; it is
important that the outcomes of the NPPF are judged on the basis
of evidence, not perceptions. We do, however, share the Minister's
concern about placing undue burdens on local authorities to submit
data to the Government and do not want to create an overly-bureaucratic
framework. What would be helpful would be to have a small set
of data monitoring a small number of key outcomes-including, amongst
other things, the success of the town centre first and brownfield
first policies, and the volume and location of new house building.
We recommend that the Government expand its consultation on
land availability data to cover a set of data that can be used
to monitor the overall effectiveness of the NPPF. It should set
out what it sees as the principal aims of the NPPF, and for each
of these aims propose a small data set to be collected from local
authorities and collated nationally. Once a clear set of data
has been agreed upon, it should be updated annually.
240 See para 0. Back
241
Q365 Back
242
Q366 Back
243
See para 72. Back
244
Q615 Back
245
See para 0. Back
246
Q836 Back
247
Department for Communities and Local Government (NPP 342) Back
248
Department for Communities and Local Government (NPP 351) Back
249
NPP 195. The signatories to the letter were Adrian Penfold, Chair,
British Property Federation Planning Committee, Andrew Whittaker,
Planning Director, Home Builders' Federation, Cllr Mike Jones,
Chair, Environment and Housing Board, Local Government Association,
Prof Paul Cheshire, London School of Economics, Mike Kiely, President,
Planning Officers' Society, Ann-Marie Connolly, Public Health
England, Faraz Baber, Royal Institution of Chartered Surveyors,
Simon Marsh, Head of Planning Policy, Royal Society for the Protection
of Birds, Trudi Elliott, Chief Executive, Royal Town Planning
Institute and Dr Hugh Ellis, Head of Policy, Town and Country
Planning Association. Back
250
NPP 195 Back
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