Evidence in the National Planning Policy Framework

There is a section in the National Planning Policy Framework that deals with ‘Using a proportionate evidence base’ (paragraphs 159-177). This is designed to help planners make decisions concerning housing, business, infrastructure, minerals, security and the environment (the subsections identified). In my opinion it is essential to have an evidence base to produce valid and justifiable decisions in the planning process and the aim to have such decisions based on ‘adequate’ up-to-date and relevant evidence’ is highly laudable. Issues may arise, however, with the exact meaning of some of these terms. The term ‘adequate’ is essential – there will never be complete information or evidence upon which to make a decision. Planners, just like scientists, have to use the evidence that is available to them. There may be some scope to create information through local surveys and focus groups but for the rapid planning that the framework is pushing the scope for this may be limited. It is what is accepted as 'adeqaute' that could be debated.

The framework does provide pointers as to the type of information or evidence required. For housing, a Strategic Housing Market Assessment is required – a model of housing needs (and like any models assumptions will be needed to make it work). For most of the subsections a key piece of evidence is the current state of the area – for example, what minerals and where, what floor space exists and how much is needed into the future and where. Developing databases and producing up-to-date geographic information systems (GISs) of all this information is essential to the planning process even if that means collaboration and discussion with organisations such as health organisations (paragraph 171) that already have the appropriate information to hand. Form my viewpoint as a geographer this all seems a great idea and one that could provide employment for geography graduates skilled at thinking spatially and at collecting and analysing spatially tagged (or spatially co-ordinated) information.

The cynic in me wants to ask some other questions though. What will count as ‘relevant’ evidence? Does evidence produced by researchers funded by interested stakeholders count? Can communities research an issue and provide their own evidence? If ‘independent’ research or evidence counts who defines the term ‘independent’? Which stakeholders can afford to fund research that produces ‘independent’ evidence? Does this type of definition of evidence mean some stakeholders have more say in being able to provide ‘relevant’ evidence than other stakeholders? The decision about what is proportionate seems to imply that someone, somewhere in the planning process can say ‘that’s enough’ and make a decision based on what they consider to be relevant evidence. You may also have noticed above that I used the terms ‘information’ and ‘evidence’ interchangeably – they are not the same thing but could be conflated. I could collect information about the location of houses in an area but the way that information is used as evidence of the need for more housing or as evidence of pressure on infrastructure is an entirely different thing. Evidence implies a degree of interpretation, of using information to support or refute a viewpoint or idea. Information does not mean this or rather not necessarily as why would I collect information on housing in the first place if not to put forward or support a viewpoint?

Neighbourhoods and communities: 'Locals' in the National Planning Policy Framework

Neighbourhoods and communities feature strongly in the National Planning Policy Framework. As part of the core planning principles (page 5), plan-making and decision-taking should:


‘take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it:’

Town centres come in for particular discussion forming a whole section (paragraphs 23-27) concerned with improving their vitality. Likewise, section 8 on ‘Promoting healthy communities’ reads as an important opportunity for communities and neighbourhoods to engage in developing secure and accessible places. The continued emphasis on local authorities to engage with communities in the planning process via the Community Right to Build Order right at the start of the process also sounds extremely positive.

There are two key questions that need to be asked about this move towards ‘localism’. Who are the neighbourhoods and communities and how do they actually achieve any influence? The first question is always a tricky one – what are communities and how do you recognise them or more importantly for planning how can they become officially recognised? Are communities and place the same? Does the community need to form about a specific issue or theme? Does the community need to be ‘local’ and match the same spatial extent as parish or local authority boundaries? The continued use of the terms ‘neighbourhood and communities’ with local authorities tends to suggest that the framework see communities as spatially limited and defined and coinciding, luckily, with the planning areas of the local authorities. Similarly, the framework seems to imply that communities are relatively small (no size is given) as they will discuss ‘local’ issues with the planners. This issue of scale is vital and could be a sticking point in planning. How many individuals do you need to have a viable community that the planners will listen to? Do you all have to live in the same location as if concern for a specific habitat needs to be limited to people that live in a specific area? Henry Hemming in his recent book ‘Together’ makes the point that many modern communities are virtual or extra-local or both. How do these fit into the planning process?

Even assuming that the ‘community’ can be identified and its representatives selected rather than just being people with the time and resources to be active on local issues (not that I am denigrating those that are as every issue needs dedicated individuals to lead it), how can they influence planning policy? This is dealt with in the ‘Plan-making’ section of the framework. Paragraph 155 calls for ‘early and meaningful engagement and collaboration with neighbourhoods, local organisations and business. The section on neighbourhood plans begins at paragraph 183 and by paragraph 184 makes it clear that:

‘the ambition of the neighbourhood should be aligned with the strategic needs and priorities of the wider local area. Neighbourhood plans must be in general conformity with the strategic policies of the Local Plan…Neighbourhood plans should reflect these policies and neighbourhoods should positively plan to support them. Neighbourhood plans and orders should not promote less development than set out in the Local Plan or undermine its strategic policies’.

Now I am happy to be corrected but this implies to me that neighbourhoods and communities can not alter anything that contradicts the Local Plan and the interest of the wider local area (whatever that means). Anything locals propose has to fit into these wider strategic plans. Not sure where that leaves localism?




Henry Hemming' book Together

Presumption of Sustainability?

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.

World Views and Sustainable Development

The National Planning Policy Framework document is a great piece of political compromise at the heart of which is the term ‘sustainable development’, a term of great creative ambiguity – it means whatever you want it to. The interpretation you put onto the term partly depends on your world view, specifically what you think of the environment and how fragile or robust it is.

In the figure the bottom right hand corner represents individuals who think the environment is very fragile, maybe even in a delicate balance which we humans can easily upset to produce catastrophic and irreversible changes. Move to the top right corner and this represents individuals who think the environment is fragile but not so fragile that we can not change things a bit, within acceptable limits. Once these limits are exceeded then problems will occur but as long as we work within these limits there should be no problem. Move to the bottom left and you have individuals who believe that the environment is pretty robust, it tends to survive whatever we do to it, so if there are limits they are quite a long, long, long way off. Whilst the top left represents individuals who just go with the flow accepting it doesn’t really matter what they think they can not do anything about the environment anyway.

A simple caricature I know but does this get at the nub of the problem with the term ‘sustainable development’ . Each world view can make sense of the phrase in its own terms. An individualist can view the environment as being able to cope with a lot of change and so can focus on the ‘development’ part of the phrase, whilst an egalitarian will focus on the ‘sustainable’ part of the phrase as they are concerned with not disrupting the balance of the environment. A local authority might view itself as hierarchist, ensuring that change happens but within well defined and scientific proven limits.

Problem is do we know what the limits are? The original definition of ‘sustainable development’ in the Brundtland Commission report in 1987 recognised that there were limits to sustainable development but these limits were not fixed.

‘The concept of sustainable development does imply limits – not absolute limits but limitations imposed by the present state of technology and social organisation on environmental resources and by the ability of the biosphere to absorb the effects of human activities’. (World Commission on Environment and Development, Our Common Future, page 8, 1987).

According to the figure some people will be concerned to find these limits, others will assume that the limits are so far away it doesn’t affect them and what they do. Partly your attitude or world view will depend on how you see yourself in society. The vertical axis is labelled ‘Grid’, this is concerned with how far you see your choices defined by society. Very individualistic individuals will see themselves as completely unconstrained and so able to do whatever they like. Following the rules and procedures to the letter puts you high up on the axis. The horizontal axis is labelled ‘Group’, this refers to the level of cohesion or solidarity there is amongst a group. Low group cohesion will tend to produce individuals who act for themselves, whilst high group cohesion will produce individuals with a sense of responsible to the group. Where would you place all the potential stakeholders involved in using and implementing the National Planning Policy Framework? Where would you put yourself? Do you think that affects how you understand ‘sustainable development’?

Schwarz and Thompson (1990) discuss the above type of figure in relation to environmental issues (amongst other things) in Divided We Stand: Redefining Politics, Technology and Social Class (1990)



Whilst Mary Douglas originally developed these figures in her analysis of cultural theory.



The Brundtland Commission reported in 'Our Common Future' in 1987

Sustaining Vagueness: Planning and Sustainable Development

Sustainable Development is the central pillar of the new National Planning Policy Framework. Judging from the positive various commentaries from business leaders, planners, conservation organisations and just about anyone else asked on recent news programmes, everyone is happy with this focus. Groups normally at loggerheads with each other seem content that the new document suits their purposes. How can this be?
The document itself does not really help much in explaining this strange contentment. The Ministerial foreword states that ‘Sustainable means ensuring that better lives for ourselves don’t mean worse lives for future generations’, whilst ‘Development means growth’ and ‘Sustainable development is about change for the better…’ Any clearer now about what the term means?
On page two the five guiding principles of sustainable development found within the UK Sustainable Development Strategy Securing the Future are reiterated. They are ‘living within the planet’s environmental limits; ensuring a strong, healthy and just society; achieving a sustainable economy; promoting good governance; and using sound science responsibly’. Any clearer now?

Paragraph 7 on the same page states that there are three dimensions to sustainable development: economic, social and environmental. The economic role focuses on building a strong, responsive and competitive economy which will ensure that land of the right type in the right places if available at the right time to support growth and innovation. The social role is to support strong, vibrant and healthy communities by providing housing to support the needs of the current and future generations. Is it a bit clearer now – is that what you thought sustainable development meant?
I will look at the planning document in more detail in another blog but one of the key problems and the reason why everyone seems so happy is that the term ‘sustainable development’ is so vague and flexible that everyone reads into the term what they want to. An excellent article by Robert Kates, Thomas Parris and Anthony Leiserowitz (2005) discusses this problem in detail. Since the initial brief definition by the Brundtland Commission in 1987, the term sustainable development has become hijacked, interpreted, reinterpreted and so imprecise that anyone or any group dealing with the environment can shape the term to mean whatever they hope it means. The Brundtland Commission defined sustainable development as: ‘ability to make development sustainable – to ensure that it meets the needs of the present without compromising the ability of future generations to meet their own needs’.

This definition has what Kates et al. call a ‘creative ambiguity’, a great term for vagueness. Kates et al., identify that there are three distinct things that can be developed within the term; people, economy and society. Each has a different time scale associated with its development and each places a different emphasis, depending on who is talking, on the ‘sustainable’ part or ’development’ part of 'sustianbel development'.

Kates et al. also suggest that ‘sustainable development’ can be defined in terms of what each group seeks to achieve. There are goals – what we seek to achieve. There are indicators – what we use to measure the achievement of these goals. There are the values that underlie these goals and then there is what we actually do, the practice of sustainable development. I may be naïve but my guess is that business groups and environmental organisations may share the term ‘sustainable development’ but the goals and values that drive them are different as are the indicators they would use to assess the success of sustainable development. The use of such a creatively ambiguous term as ‘sustainable development’ may be politically useful to achieve consensus but will become a minefield for implementation.


Some useful texts on sustianble development are below:




The origin of the term can be found in the Brundtland Commission report 'Our Common Future':