In the Sunday Times this weekend Charles Clover called the ‘presumption in favour of sustainable development’ ‘a con’ and branded Government ministers hypocrites who ‘don’t yet grasp the likely consequences for the English countryside of their own policies’. He also highlighted the lack of evidence that the planning system is holding back growth…
The idea that ministers might be cynically attacking the planning system in order to give themselves political cover for a failure of growth in the economy is surely wide of the mark?
My call again is for a rational debate. It is sad to see people like Jackie Sadek name calling the National Trust and their allies in the Times today.
It is hard to defend the authors (or perhaps committee of editors) of the critical paragraphs in the draft National Planning Policy Framework though. Having recognised, indeed praised, the internationally accepted definition of sustainable development ‘development that meets the needs of the present without compromising the ability of future generations to meet their own needs’ in a seductive opening paragraph they then go on to redefine it for the purposes of planning.
It is this redefinition that much of the fuss is about.
The redefinition describes sustainable development, among other things, as ‘ensuring that sufficient land of the right type, and in the right places, is available to allow growth’ and ‘providing an increased supply of housing’. Then at every turn the document talks about the planning system doing ‘everything it can to support sustainable economic growth’ (interesting use of the word sustainable) and ‘significant weight should be placed on the need to support economic growth through the planning system’.
This is clearly not a definition of sustainable development and so the NPPF is immediately open to criticism.
For the critics the next blow is that planning authorities are told to ‘plan positively for new development, and approve all individual proposals wherever possible unless the adverse impacts of allowing development would significantly and demonstrably outweigh the benefits.’ There is no weighing in the balance of the pros and cons of development here.
And then the final straw for the critics is the dictat that ‘In the absence of an up-to-date and consistent plan, planning applications should be determined in accord with this Framework, including its presumption in favour of sustainable development’.
The lack of up to date local plans is well known but what is less well known is that under the NPPF many local authorities will be forced into having local plans that are very high level and in practice similar to today’s core strategies and alligned with the NPPF. The detail will be left for neighbourhood plans, very few of which are likely to see the light of day any time soon.
Resolving this debate is going to be difficult. The starting point might be to recognise that changing the planning system is not going to kick start the economy. This is a debate about the long term future and the type of country we want to live in, not about next quarter’s GDP.
There are some in Government who are seeking to completely neutralise the planning system. They do not recognise the possibility that markets can do harm, or at least they think government regulation does more harm. Others in Government believe in the Brundtland definition of sustainable development and in government having a role in achieving it.
These polar opposite positions are probably not going to be capable of compromise but my guess is that if the voting public are faced with a choice between property developers and the National Trust, they will choose the Trust.
But there are many permutations. One of the weaker sections of the NPPF, the one on ‘development management’ (by which they mean the management of the planning system – is it so impossible to remove spin from policy making?), should be its strongest. There is a fair bit of consensus that the system, if not broke, is certainly creaking badly.
As an aside there is also a statement in the NPPF that ‘A positive planning system is essential because, without growth, a sustainable future cannot be achieved’. I know a number of people who would argue this point though I doubt they could yet achieve popular support.
We have an opportunity here to have a great debate, political, philosophical and practical about the country we want our children to live in and how to achieve it. It would be a shame to waste that opportunity.
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The Chris Brown Blog 
The easiest way of improving the level of debate would be to ban the use of the words sustainable and sustainability. The NPPF would be a lot clearer and we would all know what meant if it talked of, for example, a ‘low-carbon economy’, ‘low-carbon growth’, “healthy communities”, ” financially-viable development” or “improving/reducing biodiversity”.
But I guess that is not going to happen. So if we are going to talk about sustainable development then the Brundtland definition of sustainable development is a recognised one and a good starting point. There is value in cross-referencing it to the definition of a sustainable community agreed in December 2005 under the UK Presidency of the European Union by ministers and representatives from member states and European institutions. This was a development of the Egan wheel and was based on the definition in “Securing the Future: the UK Government sustainable development strategy” (March 2005). It defined Sustainable Communities as:
“places where people want to live and work, now and in the future. They meet the diverse needs of existing and future residents, are sensitive to their environment, and contribute to a high quality of life. They are safe and inclusive, well planned, built and run, and offer equality of opportunity and good services for all.”
The sustainable communities embody the principles of sustainable development by:
* balancing and integrating the social, economic and environmental components of their community
* meeting the needs of existing and future generations
* respecting the needs of other communities in the wider region or internationally also to make their communities sustainable.
There might be some good debate about, and even some agreement on, what the words mean at an abstract level. But what is needed is some practical advice on what it all means when dealing with a planning application. For a presumption in favour of sustainable development also implies a presumption against unsustainable development.
So a starting point for discussion is the three aspects to any development and how they each impact on the four pillars of economic development, social development, environmental protection and cultural diversity – with all being met, not that one (eg economic development) can trump the others:
* Its location
* The building (design, materials and construction)
* How it is going to be used (including who will use it)
The NPPF needs to make it clear that for a development to be sustainable it must be sustainable on all three aspects.
For example, a building may have an excellent BREEAM rating and be zero carbon, but if its location means the only realistic way of getting to it is by car then it is not sustainable. Similarly, a development may be in a city centre next to a train station but if it is uses rainforest hardwoods, has air conditioning, no green roof and the only way upstairs is by electric lift then it is not sustainable. Neither is a gated luxury residential development that turns its back on the communities it is located in
It also raises the question of whether some uses are inherently unsustainable. The NPPF already identifies peat extraction as one such use (page 28), but are there others?
Given the Climate Change Act 2008 sets legally binding target of at least an 80% cut in greenhouse gas emissions by 2050, with a reduction in emissions of at least 34% by 2020 (against a 1990 baseline) then any development that doesn’t lead to a reduction in greenhouse gas emissions (let alone any that actually lead to an increase in emisions) is going to be unsustainable.
So will the NPPF lead to the end of develoments that encourage greater car use? Is this the end of car-dependent out of centre supermarkets, multiplex cinemas and business parks by motorway junctions.
Is this what the government intended?
Very neat and ironic conclusion – I think if you look at the language around traffic impacts of development, the threshold for acceptable impacts is set very low. The car is accepted de facto as the chief means of transport in most of the country and therefore its emissions accepted as a price of development. There is no clear intention to limit development to public transport hubs.
That is why tying the definition of sustainable development to the aims of the Climate Change Act would be so powerful. But that is why it is left undefined. The voting public still want the out of town facilities. But the rising price of oil will make these destinations less affordable than town centres in future.
As an medium term investor, I think I would prefer Chiswick Park to Stockley Park, Stratford to Lakeside. And funders are now more cautious than ever. So wicked private finance may have a longer term view than the NPPF.