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The National Planning Policy Framework

On the 27th March 2012, in England, the National Planning Policy Framework (NPPF) replaced the Planning Policy Statement 25 (PPS25) 'Development and Flood Risk'. The principles of the policy remain the same, the processes have been simplified and streamlined, but views remain mixed.

Does it go far enough in protecting ‘green’ England? Does it ensure that flood risk assessments are carried out?

Is Climate change sufficiently factored in? Can sustainability benefits really outweigh flood risk?

The NPPF will not apply in Wales. In Wales, Planning Policy Wales sets out Government policy on the subject.

“Today's statement from the coalition government is disappointing and a lost opportunity with the pursuit of growth failing to account for the very real value that the UK's countryside and natural capital provides. There are some improvements on the original draft NPPF; it is good to see local authorities getting longer to prepare for these changes, a definition of sustainable development that includes the principles from the 2005 SD Strategy and the removal of the "default yes" clause."

"Ultimately though, there is still no strong, clear guidance to local authorities on how they can use the sustainable development policy in the NPPF and apply it to their

circumstances. What was needed was a better policy framework to make sustainable development a day to day exercise and a practical reality. Instead, what we have reinforces the status quo; the same old problems will again rise to the surface."

"It will take a year or so, when applications under the new framework start to become reality, before we can truly judge the full impact of these changes. However, our fear is that this system is simply not robust enough to protect our rural and open spaces from irreparable and costly damage."

Emmalene Gottwald, senior planning advisor

“I have to congratulate the Minister for listening to some of our concerns. He has used the right definition of sustainable development and this sends out a clear signal to developers that economic benefit must be balanced with social and environmental benefit.

“Now is not the time to take our eyes off the ball though. The framework is just for guidance and can be implemented with flexibility. There is plenty of opportunity as we go through this transition period for unscrupulous development to look for loopholes.”

The NPPF is in principle good on protection for Sites of Special Scientific Interest (SSSIs) and ‘priority habitat', much of which will be without specific designation.


'There are a number of important changes that have been made to the draft, responding to concerns that we and others raised. These include:

• the primacy of the plan is confirmed, ensuring that development must be consistent with the plan • a better definition of sustainable development, based on the 2005 sustainable development strategy • the insertion of references to the use of brownfield land and the need to promote town centres

• removal of the incendiary default ‘yes’ to development where there is no plan • reference to the ‘intrinsic character and beauty of the countryside’, recognising the importance of countryside outside designated areas

• confirmation that existing plans will remain in force while the new NPPF is introduced, and that there will be a one-year transition for the preparation of new plans

'All these changes improve the document and give it a better tone and balance.

'Now the serious business of planning begins. The country needs huge effort at a local level to get plans in place that properly reflect the integration of social, economic and environmental goals, and protect places people value.

'The National Trust, along with many other organisations and people, will play our part and watch to see how it works in practice.

Dame Fiona Reynolds, Director-General

It mentions locally designated sites, but potentially values them low quite low. There is some encouraging text on ecological networks – the wildlife linkages between nature reserves and the wider environment – but nothing that is binding for Local Authorities. Mr Spray added: “There are still missed opportunities. Wetlands bring real benefits for people, in flood prevention, water treatment and recreation, particularly in this time of drought and increased flood risk. The NPPF could have been a progressive document for the 21st century, but it doesn’t capture and promote these benefits through the planning system in a way that they can be recognised and championed by Local Authorities.”

WWT Chief Executive Martin Spray

In responding to the draft consultation,

the Agency welcomed many aspects including flood risk and coastal change, climate change mitigation and the natural environment being identified as amongst the strategic priorities for Local Plans. • We believe the NPPF should state clearly that delivering environmental outcomes is an objective of the planning system with equal status to economic development. • We believe the NPPF should state how the planning system should help to encourage the prudent use of natural resources, particularly water resources, and protect and enhance water

quality. • We are concerned that an unintended consequence of applying the presumption in favour of sustainable

development could be that, until Local Plans are updated and in place, some developments could be approved that have a negative impact on the natural environment. • To avoid uncertainty and delay in the planning system, we would strongly support a commitment to producing advice on policy aspects of the NPPF and the implementation of the Localism Bill. We would also recommend that transitional arrangements are put in place until such advice is developed.

“While making the planning system more user-friendly is key to unlocking

investment in infrastructure, energy, water and transport networks often sit above the local level requiring a high degree of cooperation from neighbouring authorities. We remain concerned that the ‘Duty to Cooperate’ is insufficient to overcome incentives for local authorities to prioritise very local

Policy News

plans without full regard for how developments might impact on neighbouring localities. This must be monitored closely to ensure that in the drive to empower local authorities we do not make it even more difficult to deliver the infrastructure that all parties have agreed we so urgently need if we are to create jobs, raise skills and generate growth.”

Director General Nick Baveystock

"Including a strong definition of sustainable development in the new planning guidelines is an important step forward, but this is undermined by confusing and contradictory information in the rest of the document.

"Ministers must make it crystal clear that the new planning system will encourage the low-carbon infrastructure and affordable homes our nation needs - and prevent poor quality developments that waste water and increases our reliance on expensive fossil fuels.

"But the devil is in the detail - Friends of the Earth legal experts will be watching closely to ensure local people, future generations and our wildlife are properly protected."

Policy and Campaigns Director Craig Bennett

Association of Draianage Authorities The final version of the NPPF has seen some significant changes, in relation to flood risk,

that ADA called for in its consultation response to the draft document.

Primarily that Lead Local Flood Authorities and IDB’s are named alongside the Environment Agency as flood risk management bodies from whom Local Plans should take account of advice from. Also that a separate Technical Guidance be produced which sets out in greater detail the assessment of flood risk and how this should be taken into account. “The true impacts of the NPPF will take a number of years to be felt as developments are built and their impact on their local surroundings, drainage, and flood risk becomes evident.”

The NFF were relieved to see the new document and felt that it gives much greater confidence on the treatment of development-

related flooding. There is an all-new Technical Guidance document which keeps all the key elements of the now scrapped PPS25. “It’s good to see Government listening to the sound argument put forward by the NFF.”

Charles Tucker , Chairman

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