Planning policy: Next steps from the NPPF consultation

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Joseph Lewis

Recap: What did the NPPF proposals include?

Proposed changes to the NPPF are expansive and cover a vast range of topics. The consultation documents give a full picture of all the changes, though there are a number of key themes that help to put the changes in perspective:

Accessibility: A shift towards a more accessible and understandable framework for national planning policy, including the broad restructuring of the NPPF into a series of linked policies, focused on specific topics.
Consistency: Increased consistency and coherence from the national level downwards, with the goal of establishing policies on general planning matters that apply everywhere. This includes better recognition of where other processes interact with planning, acknowledging that other regulatory regimes will not always fully address pollution. While coherence is important, these proposals often come in the form of reduced discretion for local authorities, seeking to bring local approaches more in line with one another.
Certainty: Rebalancing of the NPPF towards a ‘rules-based’ approach with the intention of increasing the certainty around decision making. Again, this often comes in the form of reduced discretion. There are also several instances where ambiguity remains, which may be addressed in the move from the consultation proposals to a final revision.
Versatility: Specific changes across the policy chapters of the revised NPPF, which cover: plan making; decision making; sustainable development; climate change; delivering a higher quantity of homes; economic development; the vitality of town centres; communications; clean energy and water; sustainable mineral use; effective land use; protecting green belt; well-designed places; sustainable transport; healthy communities; measures on pollution, public protection and security; flood risk and coastal change; and conserving and enhancing the natural and historic environment.

Overall, the changes are consistent with the recent approach to policy from the Government: more focus on consistent top-down solutions that speed up the process of developments. That approach comes with risks, particularly given the stark differences between places around the country, which often face different environmental challenges, such as local air quality conditions.

Now that the consultation period has ended, the Government will consider whether to make the revisions as proposed or subject them to further edits. With countless changes covered by over 200 consultation questions, this process may take some time. However, given the strong drive to expedite action through the planning system, a final outcome to these changes is expected later this year.

To learn more about the full details of the proposals, read the proposed changes to the NPPF. For more information about how environmental professionals are responding, see our response to the consultation. You can also find out more about the Government’s approach to local authorities in our analysis on the Devolution Bill and local authority restructuring.

How have the experts responded?

“The Government has rightly made clear that the purpose of the planning system is to contribute to the achievement of sustainable development, by managing the use and development of land in the long-term public interest. As the professional body for environmental scientists, we endorse this purpose and will support our members to realise this ambition, working with Government and other professions to do the same.”
- Gary Kass, Chair of the IES External Policy Advisory Committee

“Different places have different needs. Local authorities need the power to innovate and the flexibility to act. In the proposals, local authorities are losing a number of levers and tools that allow them to apply scrutiny, take innovative approaches, and secure a balanced approach to social, economic, and environmental outcomes. The NPPF must empower communities to pursue ambitious environmental action.”
- Official written submission of the IES to the NPPF consultation

“Proposed changes to the NPPF could jeopardise the early involvement of Contaminated Land Officers, who help to identify constraints, risks, and mitigation requirements at the earliest possible stage. While NCLOG runs educational events and produces some guidance, there is also a clear need for nationally endorsed, publicly available guidance on land contamination as well as practical, accessible guidance for local authorities and planning authorities on PFAS contamination.”
- Ellie Savage, Coordinator of the National Contaminated Land Officers’ Group

What does it mean for environmental experts? How can we support change?

The IES supports the Government’s objective to create a planning system that promotes sustainable development while tackling social and economic challenges, like the housing crisis, as well as environmental challenges, like climate change.

That objective will be essential to achieving a future with thriving people, a healthy economy, and a flourishing environment.

To help deliver that vision through the NPPF, the IES responded to the consultation, highlighting areas to improve the proposals:

We supported a transformative approach, which we believe many of the proposed changes contributed towards. Several changes make meaningful contributions towards a more strategic and holistic approach to planning.
In particular, we strongly supported the approach to pollution risk taken in policy P3, the broad approach to future planning in policy TR6, and the approach to cross-boundary cooperation in policies PM10 and PM11.
We raised concerns that the removal of several smaller discretionary levers could add up to a significant reduction in the flexibility of local authorities to take innovative and ambitious approaches that might make more sense locally, have the ability to promote growth, and which may be essential to meeting national targets.
We also raised concerns about the approach to air pollution, where national targets are used in parts of the proposed NPPF as proxies for the wider objective of improving air quality and human health. We believe this will lead to unintended consequences and unnecessary risks to human health and the environment.
Where the proposals make positive progress, we also identified further opportunities to strengthen those proposals and create a more coherent approach overall. One key opportunity is the inclusion of soil health in several parts of the NPPF and supporting policies.

To find out more about what we said, read our response to the NPPF consultation.

We also supported one of our Communities, the National Contaminated Land Officers’ Group (NCLOG) to submit its own response, focusing on issues around contaminated land. The IES believes in strengthening voices across the sector, so we also supported a letter from the Environmental Policy Forum (EPF), which raised concerns from other disciplines about the approach taken in some of the proposals.

Making the case for a better approach to the planning system will require a long-term conversation with policy makers and the public. It is possible to achieve a country with thriving people, a healthy economy, and a flourishing environment, so the voice of environmental scientists is vital.

As the NPPF proposals are considered and eventually implemented, the challenge for environmental professionals will be to ensure they are delivered well. Where avenues for ambitious approaches are lost in pursuit of a more consistent approach, professionals need to be ready to identify opportunities to maximise social and environmental co-benefits.

What next?

As planning policy continues to develop over the coming months, the role of environmental expertise will be essential to ensuring that the goal of sustainable development is reflected in practice.

Local authorities need access to expertise and sound guidance that enables innovative answers, so professionals have a crucial responsibility to provide case studies and ensure their own practice embodies an ethically-ambitious approach to planning and the environment.

The IES is the home for environmental expertise. We work to put science at the heart of policy conversations, especially on critical issues like planning, where so much is still at stake.

Get involved: if you want to support the work of the IES to stand up for science and nature, become an affiliate, or if you’re an environmental professional, join the IES.

Read more about the NPPF consultation in the IES response and the response from the National Contaminated Land Officers’ Group (NCLOG)
Join our Environmental Policy Implementation Community (EPIC) to support effective local policy, or join NCLOG if you work locally with contaminated land
Sign up for our new training course on ‘Understanding environmental policy’ to take your first steps towards engaging with the complex policy landscape
Learn more about recent policy developments in our briefings on clean air, water policy and land and nature policy
Find out more by reading the latest articles from Essential Environment, including insights on the Water White Paper and our analysis on the Planning Act and what it means for environmental experts

If you want to learn more about environmental policy or the training we offer for members, please contact Joseph Lewis, Head of Policy (joseph@the-ies.org).