Another Acronym: NPPG (National Planning Practice Guidance)

Another day, another acronym in the world of planning.

Last week saw the launch of the National Planning Practice Guidance (NPPG) website. This new website was launched in response to the Taylor Review. The review set out that the government should bring together all planning guidance in one easy-to-navigate website. The principle being that by removing the plethora of often rather aged and out of date guidance with one up-to-date source the planning system would become more accessible and as a result speedier. 

Whilst we are always supportive of anything that cuts down the complexity of the planning system and encourages community’s engagement, this really does seem to go the other way.

The website represents a massive stripping back of the current guidance, whole documents are summarised into just a few paragraphs. For example, one of our primary areas of concern is the guidance on Tree Preservation Orders. This guidance has been cut from 96 pages to 14 paragraphs and 7 flow charts. By taking this approach, the more straightforward issues surrounding TPOs are answered clearly …yet it seems to miss more nuanced issues. For example, where is the guidance on the Secretary of State’s right to make TPOs? Or the occasions where LPA’s may find it appropriate to make a TPO prior to a planning application being made? It also fails to give any further direction on how LPA’s should incorporate trees into their strategic visions and how TPOs can be a tool for this. It is these more detailed yet key points that seem to be lost in the drive for simplicity and brevity. 

Guidance should put more meat on the bones of the National Planning Policy Framework (NPPF), presenting more detail to support Local Planning Authorities (LPAs) in drawing up their local plans and providing more information and explanation for local communities. The new guidance is so minimalist in its approach it seemingly only acts as signposting to the NPPF and legislation. Such an approach can only lead to more planning by appeal as the Planning Inspectorate and the Secretary of State are forced to make more decisions as LPA decisions will increasingly be seen as open to argument. 

We also have concerns about the usability of the website itself. It is very tricky to judge whether you have found everything there is to be found on topic, it is also very easy to get lost within the website, particularly when navigating between the NPPF and the NPPG. Another significant point is that there are no accompanying lists detailing the documents that are being replaced by each section. This makes the role of consultees even trickier in trying to judge not only what is there but what is not. 

The website is currently in its beta phase, meaning that during the consultation period (until 9 October 2013) the format of the website is likely to change, the content however will remain unaltered. Please do take the time to have a play with the new website and let DCLG have your comments using the electronic response form and/or by letter. We are working on the Trust’s official response at the moment – if you have anything to feed in, please do leave a comment below.

Victoria Bankes Price, Planning Adviser

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About Kaye Brennan

Senior Campaigner (Policy & Advocacy) for the Woodland Trust and Administrator, 'Woodland Matters' blog
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7 Responses to Another Acronym: NPPG (National Planning Practice Guidance)

  1. Paul Beevers says:

    I think it may be that the Government’s aims may be being misinterpreted but that said I am conscious that Government retains the right to over rule anything it doesn’t like. In other words it is saying that it is devolving responsibility to local communities but it isn’t prepared to accept local decisions it doesn’t like even if that means overruling a local democratic process. That said, note what the NPPF says on page 1 Introduction. “It sets out the Government’s requirements for the planning system only to the extent that it is relevant, proportionate and necessary to do so. It provides a framework within which local people and their accountable councils can produce their own distinctive local and neighbourhood plans, which reflect the needs and priorities of their communities.”
    In effect the Government is pushing local communities to produce their own Local and Neighbourhood Plans in which those communities say what they want. So for example I am trying to get 50 metre buffers included in our Local Plan as a minimum for ancient woodlands. There is a cultural and mind set change that needs to happen among residents and local authorities and this will take time and a lot of pain. One of the related issues I find is the absence of skill in the planning authority and often among the population. This means the issues are not highlighted adequately by residents, and Officers are resisting change because they are working to a mind set that says they must advise Councillors on the basis of now redundant thinking and inadequate local policies. Many Local Authorities including my own do not have a Local Plan and decisions are being taken all the time, and especially now, on a rush of development applications which are not underpinned by clear policy guidance in the Local Authority. Without appropriate policies being in place the LA is at the mercy of a Planning Inspector on Appeal. It seems to me that a really important task for conservation groups, perhaps working through WCL, is to target Local Authorities with advice on how to upgrade their own local policies to protect, enhance and expand the natural environment.

    • Victoria Bankes Price says:

      Hi Paul
      Many thanks for your comments, glad to hear you are pushing for ancient woodland buffering, that is an on-going battle for us! Sorry to hear you haven’t got a local plan, by constantly moving the goalposts the government is creating further uncertainty within the planning sector, causing local plan progress to slow down further.
      Also I learnt yesterday that document being open for comment (like this guidance) is very different to it being open to consultation. There are no rules and guidelines surrounding the comment process and there is no duty to consider responses. Like you say the Government want a very centralised version of localism!
      Victoria

  2. Pingback: Planning for Biodiversity – A Guide | Richard Wilson Ecology

  3. Victoria,

    I too have a number of concerns and have raised this with CIEEM. My primary concern is that the NPPG is ‘protected species centric’, amplified by the phrase “…only require ecological surveys where clearly justified, for example if they consider there is reasonable likelihood of a protected species being present and affected by development.”. There would also appear to be conflicting text within the new guidance. Reference to biodiversity and enhancement (i.e. non-protected species) but then comments that I have just quoted. This could easily lead users to solely consider European Protected Species or domestically protected species and disregard all other biodiversity. Furthermore, there is no reference to the just published British Standard on Biodiversity and the Code of Practice for Planning & Development, BS42020: 2013; nor the Biodiversity Planning Toolkit. Both of which should be essential, as well as very useful reading, for all who engage with the planning system.

    I would hope that the text, as for the draft National Planning Policy Framework document, can be strengthened as the current version, (in my opinion and from first appraisal), appears to be very weak, ambiguous and potentially open to abuse or mis-use.

    Richard

    • Victoria Bankes Price says:

      Hi Richard
      Good to hear from you after our chat about the NPPF, I hope you are well. You have raised some very interesting points which I shall certainly flag up in our response. Will you be circulating your response? It would certainly be useful to see it; I really do feel that we all need to stand together. Here’s hoping that if the strength of feeling is strong enough we can get it tightened up.
      Thanks
      Victoria

  4. alvecotewood says:

    They have also missed the issue of woodlands covered by a site-wide TPO, such as ours, which are being managed under a Forestry Commission management plan, with a felling licence granted to permit thinning and coppicing to improve habitat and promote healthy trees. Initially we had a lot of difficulty until the planning authority acknowledged that we didn’t need a TPO works application provided work we were doing was covered by the management plan and felling licence. Until then we had to seek authorisation for every bit of work on every tree. We are concerned that good woodland management will be compromised if we have to go back to the system of getting TPO works applications on every bit of work on every single tree. I should add that we are not a bunch of cowboys cutting down trees willy-nilly, or developers seeking to make profit, but are winners of the Royal Forestry Society Excellence in Forestry award for 2013 (Small Woodlands Category). What we have already done has had massive benefits to wildlife, habitat and the health of the trees. Having to apply for work on every tree, and get in a tree consultant to check things, would make it impossible for us to continue to manage the woodland, improve habitat, restore the coppice, and basically be obstructive and unworkable. They need to update this guidance.

    • Victoria Bankes Price says:

      Hi

      Its great to hear what good work you have been doing in your wood. You have made an excellent point about site-wide TPOs, we will certainly be incorporating that into our response. Please do put your point directly to the Department for Communities and Local Government, the more people who flag up the deficiencies in this guidance the better. If you could highlight any specific practical difficulties this guidance would raise for you all the better.

      Many thanks
      Victoria

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