Hierarchy of Priorities in the National Planning Policy Framework?
Reading the National Planning Policy Framework in detail has given me a number of themes that I want to develop, although be aware I do tend to have a cynical and sceptical view of such documents. In this blog I will look at the structure of the key areas of the document and the potential hierarchy of priorities that they provide. Media interest in he document has, maybe predictably, died down after the initial rush of organisations announcing their broad contentment with the framework. As I mention in a previous blog, this contentment may be the result of each group reading into the term ‘sustainable development’ exactly what it wants to.The presumption of sustainable development is one of the key and motivating themes of the framework. The Ministerial foreword even states that
‘a presumption in favour of sustainable development is the basis for every plan, and every decision.’
A little earlier within the same foreword sustainable development is defined as being about positive growth, about making economic, environmental and social progress for this and future generations. On page 2, Achieving sustainable development, the three dimensions to sustainable development are listed as economic, social and environmental (ordering changed from the Ministerial statement already!) This ordering of roles, dimensions, call them whatever you want, is stuck to consistently throughout the framework, although all three should be pursued simultaneously (page 3 first mentions this). By paragraph 9 on page 3 the ordering becomes more specific with job creation, people’s living conditions and high quality homes being specifically mentioned. (net gains for nature are identified as well but seem to be couched in terms of value as in the Natural Environment White Paper, The Natural Choice: Securing the Value of Nature, 2011).
Getting into core planning principles (paragraph 5) and paragraph 17 pushes proactively driving sustainable economic development by which is meant delivery of homes, business and industrial units, infrastructure, particularly taking into account ‘market signals’ (although if this is as crude as ‘price’ is unclear). Paragraphs 19-21 again emphases the government commitment to delivering sustainable economic growth (in a section titled ‘Delivering sustainable development). Paragraphs 23-27 highlight the need to develop town centres economically, whilst point 28 is concerned with rural economic development. High quality home supply (paragraphs 47-55), good design (paragraphs 56-68) and healthy communities (paragraphs 69-78) are all discussed before protection of Green Belt Land (paragraphs 79-92). Section 10 ‘Meeting the challenge of climate change, flooding and coastal change’ begins on page 21 and discusses low carbon futures but paragraph 98 states that when determining planning applications, local planning authorities should:
'not require applicants for energy development to demonstrate the overall need fro renewable or low carbon energy….. approve the application if its impacts are (or can be made) acceptable.’
Not sure what acceptable is defined as in this context or is it rather the varying contexts of the local conditions? If the latter then this makes the framework very much based on context and the decision-making process within local contexts. Localism at its best or the potential for spatial inequalities in decision-making?
Paragraph 152 suggests that there should be net gains in all three dimensions of sustainable development implying that losses in some are acceptable if gains can be proven. What criteria will be applied to show this?
Within the ‘Plan-making’ section, paragraph 156 again provides a list of strategic priorities that runs: housing and jobs, provision of retail, leisure and other commercial developments, provision of infrastructure (listing specifically for what), provision of health, security, community and cultural infrastructure and lastly climate change mitigation and adaptation as well as enhancement of natural and historic environment. The evidence base for decision-making (paragraphs 159-172) lists specifically housing, business, infrastructure, minerals, defence and then environment.
Why have I gone through this in detail? When reading such a framework one of the key things is the impression you get from the prioritisation of factors or variables. Within the framework, housing, jobs, business and infrastructure are nearly always considered before environment. Is this just an arbitrary decision? Does it reflect an implicit hierarchy of priorities for planning decisions based no the framework? You could argue that I have been selective in my reading of the framework and read far too much into the ordering but then again when it comes down to local decision-making aren’t the various stakeholders involved going to go through the framework in such detail and select the points and emphasis most crucial to their viewpoints? Remember paragraph 176 about safeguards – they should be clearly justified to the applicant (not the other way around!) and options for keeping such costs to a minimum fully explored so that development is not inhibited unnecessarily – there are so many debateable terms to define here I do wonder about implementation.