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NPPF: the Victorian Society’s response

The Victorian Society is urging the Government to include a practical and clearly understood definition of sustainable development in the new National Planning Policy Framework.

A word cloud of Greg Clark's forward to the draft NPPF

The Government wants to change existing planning rules in order to prioritise sustainable development and ensure that more homes are built and jobs created, but the draft NPPF [National Planning Policy Framework] has been the subject of considerable controversy; with critics claiming there is no evidence that relaxing development rules would help the economy and accusations that the 52-page NPPF is a developers' charter.

The Victorian Society's Conservation Advisers refer to Government planning policy on an almost daily basis in order to inform the expert advice the Society gives to local authorities, and the changes proposed in the draft NPPF are of some considerable concern.

The Victorian Society and the Joint Committee of the National Amenity Societies have taken an active role in the consultation process and have proposed the following changes:

  • At the heart of the document is an over-riding 'presumption in favour of sustainable development'. And yet 'sustainable development' is not properly defined within the NPPF. We would like it to be made clear that sustainable development should not be considered in exclusively economic terms. It must also include protection and enhancement of the natural and historic environment.  
  • We would like an assurance that giving weight to the value of truly outstanding or innovative design will not override the need to protect heritage assets from substantial loss or harm.
  • In the section on climate change the Society has highlighted that care is required when considering works to improve the energy efficiency of buildings of traditional construction which need to 'breathe'. It should be clear in the NPPF that upgrading works should not be detrimental to the significance of heritage buildings or Conservation Areas.
  • The Government says it wants to retain the strength of protection offered by the current PPS5, but we are concerned that the draft doesn't achieve this. The NPPF loses the presumption in favour of conservation, amounting to a serious reduction in protection. Sustainable development and conservation can and should co-exist and the NPPF should be modified to reflect this.
  • The historic environment section of the document is very brief and we think it is vital that guidance notes to support the new framework are in place as the same time at the new NPPF, or very shortly afterwards. Such supplementary guidance must be clear and comprehensive if it is to be useful, and must have official endorsement if it is to be taken seriously; at a minimum it should be supported by the DCMS, DCLG and English Heritage.
  • We would like to see the NPPF make a clear reference to minor harm to heritage assets, as well as substantial harm, as repeated developments each causing less than substantial harm may have a very detrimental cumulative effect. There needs to be a presumption in favour of the conservation of the historic environment, which is itself a sustainable activity, but not one recognised in the document.
  • We believe more emphasis should be placed on encouraging councils to meet their statutory duty to review areas for eligibility as Conservation Areas, and to seek designation where sufficient character and interest exist. The NPPF is oddly negative about Conservation Areas, implying that the unworthy designation of areas has been a common problem, but we are not aware of any evidence to support this. Councils should also be encouraged to remove permitted development rights from a Conservation Area (an Article 4 direction), where the character of an area would otherwise be harmed.





Monday 17 October, 2011

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