The Lymington Society

 

Analysis of the Draft National Policy Planning Policy Framework

The Draft National Planning Policy Framework attempts to accommodate within a single document  aims which are essentially contradictory.   It ignores the biggest threat of all by incorporating it as an assumption;  namely, that the human population can go on growing, both in numbers and wealth, without limit and without consequences.   This subject appears to be off limits to politicians of all parties so there is no point in discussing it here, save again to remind ourselves of the words attributed to Aldous Huxley:  "facts do not cease to be facts, even when they are ignored"

The draft paper contains the word "sustainable" 104 times without ever giving a coherent definition of what it means.   The nearest it comes is in the Ministerial Foreword:

"The purpose of planning is to help achieve sustainable development.  .  .  Sustainable means ensuring that better lives for ourselves don’t mean worse lives for future generations  .  .  Development means growth.  .  .  We must house a rising population, which is living longer and wants to make new choices.   [what on earth does that mean?]     .  .  Sustainable development is about change for the better, and not only in our built environment."

The definition attempted in the body of the paper is no clearer:

For the planning system delivering sustainable development means:

• planning for prosperity (an economic role) – use the planning system to build a strong, responsive and competitive economy, by ensuring that sufficient land of the right type, and in the right places, is available to allow growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure

• planning for people (a social role) – use the planning system to promote strong, vibrant and healthy communities, by providing an increased supply of housing to meet the needs of present and future generations; and by creating a good quality built environment, with accessible local services that reflect the community’s needs and supports its health and well-being; and

• planning for places (an environmental role) – use the planning system to protect and enhance our natural, built and historic environment, to use natural resources prudently and to mitigate and adapt to climate change, including moving to a low-carbon economy.

These three components should be pursued in an integrated way, looking for solutions which deliver multiple goals. There is no necessary contradiction between increased levels of development and protecting and enhancing the environment, as long as development is planned and undertaken responsibly. [here lies the heart of the matter:  can the assertion in the previous sentence (my bold type) possibly be true for all times and all places?]   The planning system must play an active role in guiding development to sustainable solutions.

It ought to be obvious that to demolish or construct a road or a building requires energy, land and materials, most of which can not be replaced.   Buildings can be made more efficient to operate and maintain, but for the  present and the foreseeable future there is no way of making them which is "resource-neutral" over their lives.   The buzzword "sustainable", if it means anything, is no more than a fig leaf which makes a poor job of covering the inherent contradiction between the "rising population, which is living longer and wants to make new choices" and "growth" without limit in a country that is fast running out of space, energy and raw materials while the world's population continues to increase exponentially.   (Try to imagine the consequences for our world's resources and climate of a thousand million well-fed Chinese, and a similar number of inhabitants of the Indian sub-continent, each with two cars parked outside his house).   Growth can not continue indefinitely without cost, and in parts of this small island we are in sight of, or have already passed, the point at which continued growth will be bought only by eroding the quality of everyone's life.   (It has often been asserted that the world's population could fit into the Isle of Wight:   but nobody has ever explained how that would be consistent with the three basics of all life (food, shelter, reproduction) still less how it can be squared with indefinite growth).

It follows from the foregoing that unlimited growth and perpetual resource renewal (which is the meaning "sustainability" appears intended to convey) are can only be contained within a single policy by the use of ill-defined or abstract buzzwords such as "robust" (5 occurrences) and "deliver" (40 occurrences) which have increasingly supplanted clarity in the language of government as a way of allowing opposing views to be accommodated together.

In the real world, it is a fact that the population is increasing, that many people live in poor or sub-standard accommodation.   But as with roads, it is also a fact that the more houses are built, the greater will be the demand for yet more as the population continues to increase and with (it is intended)  increasing wealth, more people seek to acquire second and third homes and travel between them and places of work.   The energy, raw materials and transport needed for such a programme of demolition, construction and movement can not possibly be infinitely renewable.   The best any policy can hope to achieve is to limit the damage as much as possible, in the hope that a better solution will turn up before the world is stripped bare of resources.

Coming to our own district, and particularly town, we are in the unusual position of being entirely surrounded by sea,  National Park and Green Belt, all of which are either immovable or protected by the draft Framework.    Furthermore, the NFDC does have a local plan in the shape of its curiously named Core Strategy, which it seems some two thirds of the nation's local authorities do not:

Each local planning authority should produce a Local Plan for its area. This can be reviewed in whole or in part to respond flexibly to changing circumstances. Any additional development plan documents should only be used where clearly justified. Supplementary planning documents should only be necessary where their production can help to bring forward sustainable development at an accelerated rate, and must not be used to add to the financial burdens on development.

Without a definition of "sustainable" these words are ambiguous.   Would the Local Distinctiveness SPD survive them in a contest with a Planning Inspector?   There is no way of knowing, but the placing last of  "climate change mitigation and adaptation, protection and enhancement of the natural and historic environment, including landscape, and where relevant coastal management" in a list of strategic priorities to be "delivered" by Local Authorities is not encouraging.

In the important matter of housing, the document includes the following (the words in square brackets show how the casual adoption of buzzwords corrupts the language):

the planning system should aim to deliver [ie provide] a sufficient quantity, quality and range of housing consistent with the land use principles and other polices of this Framework.

Significantly increasing the supply of housing

To boost the supply of housing, local planning authorities should:

• use an evidence-base to ensure that their Local Plan meets the full requirements for market and affordable housing in the housing market area, including identifying key sites which are critical to the delivery [ie accomplishment] of the housing strategy over the plan period

• identify and maintain a rolling supply of specific deliverable [word redundant] sites sufficient to provide five years worth of housing against their housing requirements. The supply should include an additional allowance of at least 20 per cent to ensure choice and competition in the market for land

• identify a supply of specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15

• not make allowance for windfall sites in the first 10 years of supply, or in the rolling five-year supply, unless they can provide compelling evidence of genuine local circumstances that prevent specific sites being identified.   Any allowance should be realistic having regard to the Strategic Housing Land Availability Assessment, historic windfall delivery [meaning unclear, perhaps "opportunity"] rates and expected future trends

• illustrate the expected rate of housing delivery [ie construction] through a housing trajectory for the plan period and, for market housing, set out a housing implementation strategy describing how they will maintain delivery of [words redundant] a five-year supply of housing land to meet their housing target

• set out their own approach to housing density to reflect local circumstances; and

• identify and bring back into residential use empty housing and buildings in line with local housing and empty homes strategies and, where appropriate, acquire properties under compulsory purchase powers.

These paragraphs illustrate the difficulty of attempting to produce a single policy to apply equally to Lymington and Liverpool.   We ought to be concerned with providing affordable homes for those with a genuine need who are driven elsewhere by high prices, which are in turn the product of  finite town boundaries and the demand for second homes.   The draft policy has nothing to say on this enduring and intractable problem, which hardly exists in Liverpool

The above are just a few illustrations of the internal contradictions which pervade the Draft Framework as seen from a small provincial town.   The whole is overshadowed also by the move towards Localism, whose consequences remain for the moment unclear.

2 Oct 2011