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For housing fit for the future, let’s get these policies right

The Government is consulting on changes to the National Model Design Code and National Planning Policy Framework. Together, these documents will set the direction for the housing that we build in the near future. With hundreds of thousands of new homes needed, it’s vital that these two documents take transport properly into account: we must do much better at building housing around local amenities and sustainable transport.

Transport for New Homes has responded to the Government’s consultation, which closes on 27 March. We’ve summed up our views below. If you have views on housing and transport, please respond to the consultation here.

National Model Design Code

Jenny RaggettTransport for New Homes Project Coordinator Jenny Raggett writes…

Transport for New Homes is much concerned with the quality of new housing developments. We were therefore interested to read the proposed National Design Code and associated Guidance and can see much good material with respect to the design and layout has been incorporated. However, we believe that unless the National Design Code goes further and addresses the wider issues of location of development and its orientation around sustainable transport modes, its intentions regarding good design will often fail ‘in real life’.

The draft National Design Code looks at new development in terms of different ‘contexts’: ‘town/city centre’, ‘urban neighbourhood’, ‘suburbs’, ‘outer suburbs’, ‘local centres’, ‘villages rural settlements’ and ‘industrial areas, business, science or retail parks’.

Once the context has been established, there follows a discussion for each regarding movement, nature, built form, identity, public space and so on as applied to that context. In terms of ‘movement’ the guidance has sections on subjects such as connected streets, junctions and crossings, car parking, cycle parking, density, gardens and balconies, meeting places, local services and so on.

So far, all well and good. But Transport for New Homes, has found an important omission in the Design Code. The ‘context’ most commonly chosen to accommodate housing targets in Local Plans, are the greenfield urban extension and the garden village. Yet these have been left out of the National Design Code completely. The Code does not cover the urban extension or the garden village as a ‘context’.

Does this omission matter? We think it does because it will mean that many developments being progressed in Local Plans are likely to fail most of the guidance straightaway, because of their location and their car dependency. The fine words describing green and well-designed places with pleasant local centres, meeting places, gardens and so on, and even good public transport links, are great. But if you are building (a) in a place that cannot be connected to existing streets to an existing town (b) around a new road system because you travel nearly everywhere by car, then the rest of the Guidance is hardly likely to be implemented.

The problem is ‘double trouble’. On one hand it is the excessive influence of the car and the sheer amount of space devoted to roads, parking and driveways in housing that we have seen in the places we have visited, in turn means less greenery, often tiny gardens and little space for urban trees. On the other hand it is the lack of modern public transport alternatives to enable people to avoid having to travel everywhere by car, and the lack of local shops and community provision to walk to. These also become univiable in a place where people are encouraged to just drive out.

In conclusion then:

  • The National Design Code needs some kind of explanation about mistakes made in the past and how and why changes are needed.
  • The Code needs to be better supported by the NPPF when it comes to sustainable transport provision, parking and the layout of estates.
  • There needs to be more discussion about how the right location is important and that certain locations are unsuitable.
  • Urban extensions and garden villages are two contexts that are omitted and these need their own sections in the National Design Code Guidance.
  • There needs to be more made of the way that stations, busways, tramways and cycleways are key components in the section on movement, and need early consideration in terms of the overall and local layout and design of an area.

National Planning Policy Framework

Steve ChambersTransport for New Homes Sustainable Transport Campaigner Steve Chambers writes…

Rather grandly the National Planning Policy Framework (NPPF) is now proposed to include the 17 Global Goals for Sustainable Development. We note Goal 11: Sustainable Cities and Communities says “By 2030, provide access to safe, affordable, accessible and sustainable transport systems for all, improving road safety, notably by expanding public transport, with special attention to the needs of those in vulnerable situations, women, children, persons with disabilities and older persons”.

We know from our research that planning outcomes currently fall far short of these goals. In particular we have found that new housing developments are predominately car dependent and lacking in sustainable transport systems, such as good walk and cycle provision as well as public transport. The NPPF should give stronger weight to the necessity of these features to ensure that only development that is compliant with these goals receives consent.

We are concerned with what the proposed revision to the NPPF doesn’t say. It is a missed opportunity to bring land use and transport planning together at the local level. It emphasises “sustainable development” throughout, but nowhere is this defined. The UN goals are mentioned, but these cannot be readily interpreted at the local level.

It doesn’t acknowledge that transport is inextricable from spatial planning. Demand for travel is derived from the spatial arrangement of activities/facilities. It has no independent function. Transport must therefore be integrated with the land use planning process.

Chapter 9 (Sustainable Transport) has not been revised, and remains very weak. It is insufficient for transport issues to be merely “considered” (para 103). This section is therefore now inconsistent with the strengthened paragraph 11. The proposed revision does not include any requirement to prioritise development within the existing urban envelope, over and above greenfield sites or previously used sites that are remote from the urban envelope (for example, and especially, airfields, which are almost by definition remote from urban areas).

It does not explicitly require local planning authorities to designate land for development that is accessible by sustainable modes of travel, or to exclude land that is not. Most fundamentally, the absence of sustainable transport provision is not given as a reason for the refusal of planning applications.

The NPPF has been revised, it appears, mainly in response to the report from the Building Better, Building Beautiful Commission. Around half of all the proposed new words are in chapter 12 “Achieving well-designed places”. It is to be hoped that NPPF will be further revised in the short term, specifically to address the issue of integrated transport and spatial planning.

It claims that “the planning system should be genuinely plan-led” (page 8, para 15). We agree that it should be. However, the present planning system is to a great extent led by, or at least heavily influenced by developers and landowners, not by plans that have been carefully devised to meet sustainable development objectives. In particular, development sites are selected from those offered by the private sector, not from those that can meet public (and other sustainable) transport accessibility criteria.

You can find our full response here.

If you would like to respond to the consultation you can do so here before 11:45pm on 27 March 2021.

Main photo © Stephen Craven (cc-by-sa/2.0)

Fawley Power Station site

Sustainability Through the Looking Glass

Richard TamplinGuest blog by Richard Tamplin

”When I use a word,’ Humpty Dumpty said in rather a scornful tone, ‘it means just what I choose it to mean — neither more nor less.”

Of course, we all know what sustainability means – don’t we? It’s now almost 40 years since the United Nations, concerned by the rapidly deteriorating natural environment, established the World Commission on Environment and Development to devise a plan for achieving “sustainable development”. The Brundtland Report, named after its Chairman, defined the term as “development that meets the needs of the present without compromising the ability of future generations to meet their own needs.”

The United Kingdom signed up to the principles of the Brundtland Report by endorsing the Rio Declaration of 1993. And, when the National Planning Policy Framework (NPPF) was published in 2012, it announced, “The purpose of the planning system is to contribute to the achievement of sustainable development.” (para 6)

That being so, how it is possible to describe as sustainable development one of the latest proposed ‘garden villages’, to be built at the end of the A326 described locally as ‘the longest cul-de-sac in Europe’, over 18km from the closest train station and served by one bus per hour taking about an hour to reach any significant centre of employment? But that is how the two Local Plan Inspectors described the proposed allocation of land comprising the former Fawley Power Station for up to 1380 dwellings plus business uses when approving the New Forest District Local Plan in 2019.

Perhaps they were thinking of the proposed re-opening of the passenger service on the Fawley branch, which ceased in 1965; a good idea in principle. But today the line ends in the Exxon Refinery, an HSE Major Hazard, so on safety and security grounds impossible for a public passenger service. And if the line ends short at the former Hythe station, would occupiers of the “garden village” use the service? Fawley Waterside is to have a yacht basin and boat stack able to take up to 60m long superyachts, with neo-Georgian town houses or bijou cottages along green ‘droveways’ where ponies will wander freely, not to mention almost 4,000 parking spaces. (Artists’ images of the proposed development – complete with ponies – can be seen on the Fawley Waterside website.)

These occupiers will shop, dine and be entertained in the mega-centre of Southampton’s West Quay or in gastro pubs and restaurants in and around the New Forest. None of these is easy or convenient by public transport as users of Southampton station know. Worse, the existing but financially fragile Hythe to Southampton ferry is likely to close as Hampshire County Council would probably move its subsidy from the ferry to the branch passenger service. Already Hampshire have miraculously found money to ‘improve’ the A326, after denying for years there is any possibility of such funding.

Yet why do this when anyone familiar with this part of the New Forest knows that the everyday situation cries out for fewer cars, not more, when all roads are single carriageway, often single lane, and used, not only by walkers and cyclists, but also as of right by cattle, sheep, pigs and the well-known New Forest ponies, none of the latter having learned the Highway Code. Consequently, satnav predictions of 23-minute journeys between Fawley and Brockenhurst Station via Beaulieu are hopelessly over-optimistic, especially during summer holidays and in bad weather, when the journey may take an hour or more. On the A326 frequent road works and accidents cause similar long delays for commuter journeys to and from Southampton.

The answer to why this is now ‘sustainable development’ is to be found in the updated NPPF of April 2012 which introduced “The presumption in favour of sustainable development … which should be seen as a golden thread.” (para 14) On its face, this phrase appears to be a move closer to Brundtland and the Rio Declaration, but things are not how they appear in the looking glass world of Government. For plan-making this means that, “strategic policies should meet objectively assessed needs”, while for decision-taking it means, “approving development proposals that accord with the development plan without delay.”

This guidance was tightened in the NPPF 2018 to require “objectively assessed need” to be met as a minimum (my emphasis). Henceforward, sustainable development meant local plans must provide enough land for housing, irrespective of local circumstances. Yet the provision of land is a supply side issue, whereas need expresses the demand for homes and in a market economy must relate that demand to price. And to discover what “objectively assessed needs” means we must turn to Planning Practice Guidance, the on-line document of several hundred pages which can and does change frequently, with little or no notice, and without leaving a record of its earlier versions. This says the first step of the procedure for calculating the minimum local housing need is to identify the baseline using the household projection growth of 2014.

Why 2014? Because since then, despite biennial updates by the Office for National Statistics, the 2014 figures showed higher household growth than in any subsequent year, but Government has refused to recognise this changing situation. Therefore, projected housing needs for many local authorities to 2030 are now over-inflated by significant amounts and nowhere near that amount of housing land is required. This is particularly true in the South-East where ever-rising housing costs have choked off new household formation.

In the New Forest this absurd situation has led the District Council to seize any chance of land for housing, despite most of it in or adjoining the National Park, nature conservation sites of international importance, extensive safety protection zones or liable to serious flood risk due to climate change. The former Fawley Power Station site has all of these characteristics. However, as ‘brownfield’ land, it is a gift horse not to be turned away. But sustainable development it is not.

Guest blog by Richard Tamplin
Richard was inspired to go into planning when still at school after encountering Eric Lyons’ Span Developments in the early 1960s. Following a planning degree at Newcastle he worked for local authorities and for himself, taught planning, established an eco museum, and represented community groups. He became a Planning Inspector in 1986 and since retiring has sought to promote good planning as a public benefit.