There’s been plenty of discussion about the proposed changes to the NPPF. Now the dust has settled we find ourselves in a mood of reflection. After taking a step back from the whole business we are feeling rather dismayed at national planning policy’s current trajectory.
Nostalgia for 2012
We’ll admit it. We’re feeling nostalgic about the days of Spring 2012, when NPPF first landed on our desks.
We remember reading it and feeling uplifted. We had a sense of optimism that this was going to make a difference.
It presented a coherent vision and acceptance that, yes, development must happen and it’s a good thing.
A national document that succinctly brought together the planning system’s economic, social and environmental roles, it set out a clear way forward for how to achieve sustainable development.
Sustainable development meant growth, and the alternative to growth was stagnation, so said Greg Clark in his ministerial foreword.
And it stayed that way for over six years, providing much needed stability in the system.
It was a document the industry could decipher, rely on and get behind.
The shapeshifting NPPF
After six years of consistency in our plan-making and decision-taking, we’ve had updates every year since 2018. That is, except 2020, though if the government hadn’t been distracted by a global pandemic, we’d have had changes that year too. The NPPF has certainly had to become very good at shapeshifting.
It seems so long ago now but it was the Conversative party that steered the ship in 2012 and it’s the Conservative party that’s now proposing this raft of changes. And yet the overall tone of the latest version is a far cry from the upbeat and coherent original version.
NPPF 2012 was positive in many ways, but it has failed to speed up plan preparation. These proposals are the government’s latest attempt to further strengthen plan making and localism.
But more fundamental than that, Conservative MPs today are clearly worried they’re not going to be in power after the next general election and this move plainly panders to their core voters in the conservative heartlands – the ‘haves’ – who vote on sensitive issues of housing and the Green Belt.
The ‘haves’ that already own their own house. That don’t want change and don’t buy into growth.
With every little word change the Conservatives are (short-sightedly) ducking the issue and potentially selling out the next generation.
So, what will actually change if the proposals make it into NPPF 2023?
If you want a point-by-point summary of the proposed changes, we recommend this excellent summary by Irwin Mitchell’s Nicola Gooch.
Or, you can read the track changes for yourself here.
But what does it all amount to?
Well, we think as drafted it will fail.
The bar for plan-making will go down, and the bar for decision-taking will go up. It will lead to more delay and stagnation.
Firstly, plan making.
Absurdly, Michael Gove no longer thinks plans will need to be justified in order to pass examination (paragraph 35).
The standard method for assessing housing need was never mandatory. But the draft NPPF changes tinker sufficiently with the mechanisms for calculating housing need and supply making it easier to adopt plans that don’t provide for people’s needs and make it less likely that plans will become ‘out of date’ due to a lack of housing supply.
It’s worrying because, of course, providing for people’s needs is one of the core objectives of the planning system.
It’s in every little word change too. Adding phrases like ‘as far as possible’ and ‘sufficient housing’ all water down the original thrust of the NPPF. It’s an effective rebrand of national planning. A change in emphasis that takes us from ‘pro-growth’ to ‘growth unless it’s too costly’. Costly in terms of votes.
And then there’s decision-taking.
The added focus on securing ‘beauty’, rather than the more objective test of high-quality design, will no doubt give rise to further debate and delay the decision-taking process.
Beauty is, after all, in the eye of the beholder, and what one person may think is an appropriate design for a block of affordable rental properties, another may well expect more, even if this would render a scheme unviable.
The proposed changes address intensification, stating that building at densities significantly out of character with an area is not acceptable. Yet in order to build, areas will have to change. Either we build up (giving rise to greater densities) or we build out (extending settlement boundaries and at the risk of impacting the Green Belt and other open land).
On the one hand it re-emphasises the preference for brownfield development and encourages housing number uplifts for urban areas, whilst on the other hand it will make it easier for schemes to be refused on intensification which affect character.
If we can’t deliver in urban areas where development has an impact on character, and we can’t deliver on Green Belt or other land at the edge of settlements – where can we build?
We can see where this is heading
We get it. Almost nobody wants to review Green Belt boundaries because it’s political suicide.
But the re-emphasis on protecting the Green Belt, the watering down of housing delivery and the anti-growth rhetoric in general will take the country down a dead-end path. It won’t lead to growth, and it won’t meet people’s needs.
The uncertainties and delay already affecting SME housebuilders navigating the planning system will be exacerbated by these retrograde proposed changes.
And, to top it off, there’s no added emphasis on the biggest existential problem facing us all – climate change. It’s a stark contrast to Scotland’s recently published National Planning Framework 4 which addresses climate change head on in the very first paragraph.
This is hardly the proactive, forward-looking and coherent document the NPPF used to be.
Where will that lead us? Where Greg Clark predicted it would, probably. Stagnation.
The NPPF is meant to set the vision and tone for local planning authorities to draw up their own plans and shape the future of our communities.
It’s meant to be all about sustainable growth and delivering essential infrastructure.
Now, we have a muddled concoction of amendments which gives a vastly different message. We’ve read every chop and change and feel deflated. But until we have a political system that listens to everyone’s needs, and a planning system where the whole of society feels able to – and does – engage and benefit, we’ll get documents like this that only serve the ‘haves’ not the ‘have nots’.
We wonder, what must new planners coming into the profession think?
Our national planning document should inspire planners up and down the country, reminding them of the positive impact they can have on communities and real people.
With an ever-burgeoning housing shortage, growing levels of homelessness, a climate crisis and a local planning system that is buckling under the pressure upon it, we need a national document that will steer us out of choppy waters and set the tone for ambitious and visionary planners to follow suit.
As drafted, the proposed 2023 NPPF won’t be up to the task.