NPPF - National Planning Policy Framework

NPPF – National Planning Policy Framework

Action for Market Towns response to the draft National Planning Policy Framework (NPPF)

AMT welcomed the opportunity to respond to the draft National Planning Policy Framework (NPPF).

AMT put together a response to the draft NPPF on behalf of its members. Our Policy Manager, Alison Eardley, has summarised AMT’s position and concerns with the NPPF (below).

Read a summary and download AMT’s full response to the NPPF consultation here

Find out more about the NPPF and Neighbourhood Planning

Go to AMT’s Neighbourhood Planning page
Communities and Local Government (CLG) NPPF consultation homepage
Download an easy-to-read summary of the NPPF from CLG
Download the draft NPPF text from the CLG website

Summary of AMT position

A key ambition of the NPPF is to reduce overly bureaucratic, top-down policy that has, in the past, remained largely remote from the communities it affects.

The slimming down of the existing Planning Policy Statements and Guidance Notes deserves merit as it should make it less unwieldy, more user-friendly and accessible, especially to non-specialist groups.

AMT is concerned, however, that some of the statements in the draft have become too broad and are often conflicting (for example, ‘Supporting the Rural Economy’ and ‘Town Centres’), thus leaving them open to interpretation which in turn could lead to unsustainable development or a non-uniform approach across different areas.

Clearly any supporting guidance to be published alongside the NPPF will be critical in this respect.

Community concerns

From a community perspective, emerging policies around Neighbourhood Planning serve to position communities in the front seat in terms of determining spatial and land-use policy for their neighbourhoods.

There are three concerns here:

that some communities may not have the ambition or resources to enable them to take advantage of Neighbourhood Planning, leaving them at the mercy (and ‘in agreement with’ through lack of any Neighbourhood Plan) of potentially unsuitable development because of the NPPF.

that of those communities who are producing a Neighbourhood Plan/ Neighbourhood Development Order, certain among them may be disadvantaged by not having the capacity or knowledge to fully understand or interpret the NPPF policy, given the resources available to them, in comparison with the skills and financial resources available to developers.

that community Neighbourhood Plans may take some time to develop and developers will strike before the community is ready.

Neighbourhood Plans should be developed in line with local plans and national policy. While it can deviate, evidence must be collated which will be subject to external examination.

Clearly some communities will be better equipped than others to compile this evidence which raises questions on the ‘unintended consequences’ of a seemingly positive national policy on different sectors of the country.

The key will be to ensure that when planning policies are up for consideration in local and neighbourhood plans, full and proper consultation responses are made, that draw on all the evidence.

Sustainable development?

The presumption in favour of sustainable development has certainly stirred debate.

As it stands, the draft NPPF places a greater emphasis on the economic pillar of sustainability, perhaps understandably given the current economic climate.

At AMT, we are committed to the concept of understanding the economic, environmental and social aspects of development, in order that these can be weighed against each other to formulate an informed decision in terms of how to develop. In addition, any agreed developments should themselves be undertaken in a sustainable way.

A wider explanation, aimed at communities, of the economic, social and environmental value that development can bring to local people would be welcomed to help them weigh up the considerations and make informed decisions about development and its impacts.

AMT is concerned, however, that the interpretation of ‘sustainable’ as focusing on economic development may be misinterpreted and hence potentially misused. We need to ensure that unscrupulous developers cannot use the presumption to avoid presenting plans that are well-constructed and abide by appropriate standards.

We also must ensure that developers cannot just bamboozle a community into approving a plan that is against the community’s interests. The planning process should become more, and not less, democratic.

AMT welcomes the new Local Green Space designation as a tool for communities to utilise within their Local or Neighbourhood Plan as a way to protect any locally significant green spaces, and especially designated areas such as green belts and SSSIs.

Housing and the NPPF

The need for additional housing provision is a key consideration fuelling the NPPF.

AMT believes that the NPPF needs to convey the importance of considering it alongside other issues such as employment, transport, shops, amenities and support services of various kinds.

This means concentrating housing on those places where it can be supported by existing infrastructure and services or where it can generate improvements in, or provision of, facilities that are declining or currently unavailable.

We would also like to see more emphasis on the recovery and recycling of brownfield sites.

The bottom line for communities

Communities may be vulnerable to unsuitable development if they do not have a Neighbourhood Plan in place.

When a significant development is proposed in a community that does not yet have an agreed neighbourhood or local plan, AMT would like the development to be subject to a referendum in the affected community.