- Parts of the NPPF could be clarified, either by making the document longer or cross referencing to other things
- Importance of local plans and a presumption in favour of sustainable development consistent with the plan (I always assumed that was the intention of the draft)
- Transition should allow a little more time for LAs to get their act together and current planning guidance to continue to apply until new guidance in place (something we suggested in our recent assessment)
- Clarify what is meant by affordable housing
- NPPF is placeless, allow local variation where there is evidence to support this
- Local authorities to set own targets for brownfield first (again, something we called for in our recent assessment)
- The committee's suggestion that NPPF makes the economic dimension appear predominant. For too long the planning system has essentially ignored the economic dimension. It says a lot that NPPF tries to partially redress this balance and is immediately accused of going too far.
- The unwritten assumption underlying the select committee report that the problem with the planning system is the process rather than huge constraints imposed on the use of greenfield sites. In keeping with this implicit assumption, the select committee wants to strengthen brownfield targets and reinforce town centre first. These are exactly the policies that tie us to our existing urban footprint and create many of the problems we experience in adjusting to the structural changes occurring in the UK.
- The continued insistence that constraining us to our existing urban footprint is somehow costless. The committee claims to have 'found no conclusive research, however, that planning policy or guidance is a particular constraint on economic development'. This is misleading because it relies on a very narrow definition of 'economic development' (oh the irony). As SERC has documented, there is evidence that the UK planning system:
- Increases house prices (with a regressive impact on low to middle income families)
- Increases housing market volatility
- Increases office rents
- Lowers retail productivity
- Lowers employment in small independent retailers
- May not properly assess the true social costs of brownfield versus greenfield development.
I certainly accept that this evidence is not 'conclusive', but neither is it irrelevant. Taking proper account of it should be central to striking the right balance between the costs and benefits of our planning system. The fact that the committee chooses to ignore it and focus instead on reforming the NPPF to perpetuate the status quo - at least in terms of outcomes, if not process - is a deeply depressing reminder of just how biased is the debate on the future of our planning system.