In part one of this long read, Public Policy Officer Laura Mason covered some of the problems we see in the proposed new NPPF. In part two Laura focuses on the positive policy changes.
Putting brownfield first
Over the last few years, we’ve seen a step change in planning policy to really focus on unlocking brownfield sites. This is very welcome; regenerating brownfield not only eases pressure on greenfield sites, it often creates high quality housing on sites that have blighted a landscape for years.
By introducing new brownfield registers and a permission in principle, the government hopes to accelerate the number of homes built on these complex sites. We’re really pleased to see the revised NPPF gives ‘substantial weight’ to using ‘suitable brownfield land’ and recognises their complexity – i.e. councils potentially needing to address issues of contamination or instability.
There is a whole new chapter in the revised NPPF about making effective use of land, which emphasises that the default approach to meeting housing need isn’t just about allocating more land, but also about smarter use of existing land.
This can be achieved through higher density developments, reallocating land and converting retail or employment land to housing. The inclusion of this chapter within the NPPF seems to encourage Local Authorities to maximise every inch of their previously developed land, where this hasn’t become valuable wildlife habitat, and we support that ambition.
Protecting green spaces
It’s thought that Octavia Hill first coined the term ‘green belt’ when she was campaigning to save London’s green space in 1875. At the Trust, we have a long tradition of protecting green spaces that remains at the heart of our ethos as an organisation.
It’s important to remember the function of the Green Belt is to maintain a degree of open space between settlements. It performs a vital role in our most urbanised areas. The Trust looks after more than one in every hundred hectares of our Green Belt, and we take our custodial duty very seriously.
We welcome the strengthening of Green Belt policy, with Local Authorities needing to show they have considered all other options before amending their Green Belt boundaries for development. This includes making use of their brownfield sites and underutilised land, optimising the density of their developments, and ensuring neighbouring Local Authorities are unable to accommodate excess capacity before considering encroaching into Green Belt land.
We were also glad to hear the Prime Minister recognise that ‘the answer to our housing crisis does not lie in tearing up the Green Belt’.
Delivering a net gain for nature
It was good to see that the new NPPF reflects some of the commitments made in the 25 Year Environment Plan. We’re glad to see early evidence of cross-government working to deliver some of the Plan’s commitments.
The proposed new NPPF references the pledge to ensure new development provides a ‘net gain’ for nature, and we look forward to a more fulsome consultation on that shortly.
We have been following Natural England’s progress in creating a better metric to quantify potential gains from development, and were glad to see this could include a cultural element. This would allow gains in terms of open green space and creating a sense of place to be included.
Providing we continue to mitigate and avoid harm to nature wherever possible in development, the net gain principle could prove a valuable tool in the future.
The NPPF language also reflects the ambition within the 25 Year Environment Plan to scale up the country’s efforts to restore nature. The small change in wording that requires Local Authorities to ‘plan for the enhancement of natural capital at a catchment or landscape scale across local authority boundaries’ and ‘take a strategic approach to maintaining and strengthening networks of habitats and green infrastructure’ represents a big change in ambition.
This could be a challenge for many Local Authorities, but it is a necessary change to achieve the ‘bigger, better, more joined up’ habitats envisaged by the Government’s Natural Environment White Paper.
Safeguarding our most special places
The addition of one single line has provided a powerful statement of support for some of our most special places. Areas of Outstanding Natural Beauty (AONBs) and National Parks in the past have been subject to inappropriate development because the protections in place were not being properly applied.
The revised NPPF states that ‘the scale and extent of development within these designated areas should be limited’. We hope this will give additional protection to these important landscapes. However, we don’t want to see protections for these important areas inadvertently undermined. We’ll be calling for Ministers to re-insert the line that emphasises National Parks and AONBs have ‘the highest status of protection in relation to landscape and scenic beauty’. We’ll be backing proposals to allow the National Parks to pool their developer contributions too, which we believe will help unlock more affordable housing and infrastructure.
Heritage Coast is also given new recognition, emphasising that development should be ‘consistent with the special character of the area and the importance of its conservation’. We agree. The irreplaceable nature of ancient woodland is now accepted, and development should be refused in all but the most exceptional circumstances.
We are particularly pleased to see the greater emphasis placed on World Heritage Sites, and acknowledgment that they have Outstanding Universal Value (OUV). This includes reference to both natural and cultural significance, which is very welcome and should ensure this can be taken into consideration.
We look after two World Heritage Sites and parts of another nine, so we understand how important it is that development within them is limited and respects their unique characters.
So, in conclusion, the proposed new NPPF isn’t perfect but we can see that a lot of effort has gone into the new draft. In a nutshell we believe that whilst it could deliver greater environmental protections in some areas, it could also result in more inappropriate development on undesignated open countryside.
We’ll be submitting our full response to the Ministry of Housing, Communities and Local Government by the deadline of 10th May. You can have your say too by engaging with the consultation on their website.
Laura Mason, Public Policy Officer, National Trust
For more information about the National Trust’s approach to planning, take a look at our website.