Tuesday, 27 March 2012

NPPF? Plus ça change ...

Some of the details may be different, but my overall reaction to the NPPF is essentially unchanged. From my reaction to the draft in July last year:

"Setting aside the details, I think that the draft gets some big issues right, some wrong. Minor caveats aside, I support the presumption in favour of sustainable development. It cannot possibly be right that local bureaucrats and politicians get to say yes or no to development on a case-by-case basis. Instead, the presumption means that they have to say yes to things that are consistent with their local plan. Many other countries successfully run systems that are (at least) this permissive. But if, as this government does, you believe in localism then you have to give people a strong say in the development of their local plan to make the 'presumption' consistent with localism. The draft framework does this and again, caveats aside, I think this is a good idea. Finally, the government recognise that local authorities will need to be given incentives to agree to new development and have introduced a range of measures to provide these incentives. Whether these incentives will be large enough in practice is still open to debate, but I support the general principle.

So much for the positives, what about the things it gets wrong? I think a fundamental problem is that the planning framework is backward not forward looking. We have a growing population and changing industrial structure and yet the draft framework works to limit us to living and working within an urban footprint that we inherited from the 1940s (if not before). This is particularly evident in terms of policy towards the Greenbelt. Towns expand in to cities by building on countryside and merging with outlying towns and villages. We are told that the Greenbelt policy is specifically intended to prevent this. In other words, the urban system we have now is what we have to work with. This severly hampers the ability of our set of cities to adjust to fundamental structural changes. It assumes that growing cities can expand by recycling old land, but many of the places that have strong growth potential are not existing cities, but larger towns. In short it makes the planning system about redevelopment more than new development. I understand the politics behind this (c.f. the natural trust) but the restrictions come at a cost in terms of economic growth.

The other area where the framework is more backward than forward looking is in its approach to retail. Specifically, the government has decided to place a strong emphasis on town centre first policies. As regular readers will now, evidence suggests that these restrictions imposes substantial costs on households in terms of higher shopping bills. They also have the unintended consequence of creating more clone towns (as chains forced downtown drive out smaller retailers). Sequential needs tests then further limit competition with adverse impacts on employment and the cost of living. As with restrictions on Greenbelt development, these restrictions are also based on a 'zero sum' assumption - if we restrict out of town development than we will automatically get town centre development. But 20 years from now isn't it likely that the internet will fundamentally change the way we shop? Why shouldn't these restrictions on out of town developments hasten the move towards online shopping? Indeed, it is clear that this is already playing a role in what is happening in the high street. Overall, town centre first policies have costs as well as benefits and are based on a (possibly) outdated retail model. As I said, this feels more backward than forward looking and, once again, makes the planning system about redevelopment more than new development."

If anything, the revised version has slightly reinforced the bad (with it's focus on brownfield first) at the expense of the good. But to this reader that was already quite strongly enshrined in the draft (even if the hysterical reactions from some countryside campaigners would make you think otherwise). And at least national brownfield targets have not been reintroduced with LAs now given the power to set those locally instead (something which SERC pushed in its assessment of the NPPF).

Given the politics of all this, expect to see strong claims of great influence and radical changes - but on first pass (for this reader) it's a case of the more things change, the more they stay the same.