Comment
The NPPF: is the thread even more golden?
First and foremost the reaffirmed focus on delivering a marked increase in housing is welcomed. This will help to address one of the most significant social sustainability issues affecting current and future generations.
First and foremost the reaffirmed focus on delivering a marked increase in housing is welcomed. This will help to address one of the most significant social sustainability issues affecting current and future generations.
If we could not only deliver more houses, but also deliver them in the most sustainable locations then we would take another major step forward in future proofing the pattern of development in England. However, the proposed NPPF revisions are not sufficient to ensure that all land is afforded the same consideration in terms of its sustainability credentials. It is a missed opportunity that the revised Framework does not acknowledge, for example, that building in the Green Belt may sometimes represent the most sustainable option.
There are positives and a few negatives which we have summarised:
Net gains across the three pillars of sustainable development
In accordance with the Government's recently released ’25 Year Environment Strategy’ we see numerous references to the planning system taking a strategic overview to deliver net gains across the three pillars of sustainable development.
A review of both documents would appear to suggest that the principle of achieving biodiversity net gains could be extended to cover wider natural capital benefits such as achieving an overall improvement in areas such as flood defence, transportation and recreational space to compensate any impacts of development where it is needed. This is an established concept that when applied could utilise tools such as SEA and EIA to seek these net gains at a local authority level where large scale development is, inevitably, resulting in some environmental impacts through economic growth or new development.
Health and wellbeing
It is good to see Health and Wellbeing issues given more prominence and this encourages further discussion with regards to the development of metrics to analyse and value the social benefits from projects and design interventions (read more about Health and Wellbeing here). Step forward Social Value and indeed this is already forming part of local authority assessments of benefits from regeneration and development where they control land and property assets. More on this in due course I am sure.
Increasing importance of air quality
An increase in the importance of local air quality is a necessary and welcome amendment and we are starting to see how this can positively shape our places and cities as we replace vehicles with walking and cycling routes. Our city buildings will also be taller as we seek greater densities and hence microclimate and daylight/ sunlight issues will need to be considered more thoroughly.
Sustainability and design
There is an interesting amendment to Paragraph 130 which recognises that great weight can be afforded to applications where designs promote high levels of sustainability. This brings interesting opportunities to explore further.
National Technical Standards
Finally, a continued and justified recognition of the significant role that the planning system can make in mitigating and adapting to climate change. A replacement of the Zero Carbon Standard with the National Technical Standards provides some clarity however experience confirms that this issue of local sustainability standards still remains very unclear particularly given that the national standards only really considered residential buildings. We also have the conundrum of the London Plan which is promoting its own sustainability standards (which are very welcome) and to which the market and our clients are responding positively. I suspect this issue will be debated again quite soon given the impending review of Building Regulations and once our relationship with EU policy has been confirmed.
Sustainability was described as the golden thread that runs through the Framework when the NPPF was first published in 2012. The revisions seek to retain and enhance this “golden thread” and we look forward to its implementation.
Further Turley commentary on the draft revised NPPF is available here. If you have any queries regarding the NPPF, please contact Colin Morrison.
14 March 2018