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An Evaluation of the National Planning Documents of England, Scotland, and Wales

A 2,587-word report for ENVS459 Implementing and Managing Change. It compares and contrasts the aims, objectives, timeframe, primary focuses, and prospects for success of the national planning documents of England, Scotland, and Wales. The report earned a 75, a distinction. Written in March 2017.

1. Executive Summary

This report evaluates the three national planning policy documents for England, Scotland and Wales. In order, the documents are: The National Planning Policy Framework (NPPF), the Third National Planning Framework (NPF) and the Wales Spatial Plan (WSP) 2008 Update. For each document, the report details the (1) aims and objectives, (2) timeframe covered by the document, (3) primary focuses and (4) and prospects for achieving the stated objectives.

The Aims and Objectives of the NPPF are to promote speedier, local decisions in favour of sustainable development. The NPF and WSP both describe spatial strategies: the NPF to support developers and communities to achieve sustainable economic growth and the WSP to guide long-term strategic decisions and coordinate public and private sector investments.

The Timeframe for each document varies. The NPPF neither sets a date for achieving sustainable development nor provides a timeline for updating the document. In contrast, the NPF and WSP set visions for the next 20-30 years, and are supposed to undergo regular updates. Earlier NPFs have lasted five years, while the current WSP was supposed to last five but is in its ninth. All three countries are currently updating the documents.

Growth is among the Primary Focuses for each plan. The NPPF describes what sustainable development means for various topics (e.g., the green belt and town centres). Environmental topics in the NPPF have the most written about them, but a focus on growth underpins them and the rest. The NPF devotes more attention to truly sustainable growth, by emphasising investments in existing city-regions, renewable energy and conservation. Unlike the NPF, the WSP pays equal attention to each region, whether urban or rural. However, because Wales has more rural regions, more content is on reviving rural areas.

The Prospects are not universally positive. The NPPF has not greatly simplified English planning and may not have increased local decision-making. The document seems to be supporting development, although not necessarily sustainably. Many key developments are advancing in Scotland, but slow planning decisions may be curtailing growth. The Scottish Government is also readying to abandon the city-region approach in the next NPF. Limited evidence suggests the WSP has encouraged more collaboration among local authorities, but the plan is obsolete and the Government never published the monitoring reports it promised. Wales is also planning to prioritise city-regions in the next national planning document.

 

2. England’s National Planning Policy Framework

2.1 Aims and Objectives

The 65-page NPPF was unveiled in March 2012 to replace over 1,000 pages of national planning policy (Department for Communities and Local Government (DCLG), 2012). Aside from simplifying policy, the document aimed to accelerate planning decisions by creating a ‘presumption in favour of sustainable development’, i.e., unless the ‘adverse impacts of doing so would significantly and demonstrably outweigh the benefits’, planning officers would need to approve all proposals that aligned with current local plans (DCLG, 2012, p.4). The emphasis on local plans is important. Government endorsed greater local decision-making—in tandem with the Localism Act that ended regional planning, so long as local plans are consistent with the NPPF (DCLG, 2012). In theory, these speedier, local decisions should foster sustainable development.

The NPPF defines sustainable development as ‘ensuring that better lives for ourselves don’t mean worse lives for future generations’ and development as ‘growth’ (DCLG, 2012, p.i). In addition, the NPPF details three dimensions to sustainable development: economic, social and environmental. Economic means that ‘sufficient land’ and necessary infrastructure is available ‘to support growth and innovation’ (DCLG, 2012, p.2). Social means meeting the need for affordable housing and ensuring a ‘high quality built environment’ with ‘accessible local services’ (DCLG, 2012, p.2). Environmental refers to ‘protecting and enhancing our natural, built and historic environment… improv[ing] biodiversity, us[ing] natural resources prudently, minimis[ing] waste and pollution, and mitigat[ing] and adapt[ing] to climate change’ (DCLG, 2012, p.2).

2.2 Timeframe

The NPPF does not set a date for achieving sustainable development, but the document took effect in March 2013 (DCLG, 2012). Nearly three years later, Government released a consultation to propose changes to the NPPF (DCLG, 2015). The updated NPPF was due in 2016, but Government missed a pair of deadlines and a more recent white paper envisions additional changes to its housing section (Carpenter, 2016) (DCLG, 2017).

2.3 Primary Focuses

The NPPF has three main sections: Achieving Sustainable Development, Plan-Making and Decision-Taking. Achieving Sustainable Development receives the most attention, with 35 pages, compared to 8 and 3 pages for Plan-Making and Decision-Taking, respectively. Within Achieving Sustainable Development is a similarly titled subsection—Delivering Sustainable Development, which is further subdivided into 13 sections about specific topics (e.g., climate change). These 13 topics occupy over 30 pages. The word count for each topic suggests the weight ascribed to the three sustainable development dimensions (see Table 2.3.1).

Table 2.3.1 Delivering Sustainable Development: Topics, Sustainable Development Dimension and Word Counts

 

 

 

 

 

 

 

 

 

 

 

This table shows the word count for each of the 13 topics in the Delivery and Sustainable Development section of the NPPF, as categorised by sustainable development dimension (i.e., environmental, social and economic).

Somewhat surprisingly, a considerable portion of the NPPF is dedicated to discussing sustainable development in the context of environmental issues. However, that does not mean that the NPPF is an environmentalist’s dream, as the emphasis remains on growth, with development mentioned 386 times—an average of nearly 6 times per page—compared to 95 mentions for environment or environmental, 39 for conservation and 35 for natural. In addition, the only specific targets listed in the 13 sections are for new homes and minerals extraction. Ironically, the latter is ‘not inappropriate’ development for green belt land (due to limited opportunities for extraction), while renewable energy projects are deemed inappropriate (DCLG, 2012, p.21).

2.4 Prospects for Achieving the Stated Objectives

After five years, the NPPF has not simplified English planning. Identifying sites for housing is one area that has created delays and confusion. For example, Nathaniel Lichfield & Partners (2015), a planning consultancy, found that the plan-making process was taking longer following release of the NPPF, largely due to difficulties associated with identifying housing sites. Courts have also had to resolve ambiguity, with one judge noting that ‘the process of simplification has in certain cases led to a diminution in clarity’, particularly in how local authorities should ‘boost significantly the supply of housing’ as required by the NPPF (St Albans v Hunston Properties Ltd, 2013) (DCLG, 2012).

Although the NPPF aims to increase localism, the document again appears to fall short. In January 2016, the Commons Communities and Local Government Committee reported that 44% of local authorities had not finalised their local plans (Edgar, 2016a). Unless percentage has decreased dramatically, many communities are not shaping their future, because the NPPF is the primary arbiter of planning decisions when local plans are out-of-date (DCLG, 2012). A current plan is also not synonymous with local control. For example, the Campaign to Protect Rural England (2015) surveyed over 50 local plans and concluded that because the NPPF requires local authorities to ‘base their plans on aspiration rather than need’, it forces planners to accept schemes in otherwise protected land when housing targets are not met. Although the organisation has an interest in curtailing certain development, the requirement to identify sites for new housing remains a key challenge for local authorities that, if given total control, might seek less development.

This pressure to approve housing schemes is one area where development, with little regard for sustainability, appears to be the chief aim. Although not all green belt land is valuable ecologically, it serves as an important barrier to car-orientated and unsustainable sprawl. However, a survey by the Local Government Information Unit, a think tank sponsored by 150+ local authorities, found that 60% of councillors believed that the NPPF would enable housing developments on green belt land in their councils within the next five years (Public Sector Executive, 2017). In addition, the Royal Town Planning Institute (2016) found that half of the housing schemes in 12 city-regions involved over 450 units, 54% were in greenfield sites and only 13% were walkable to a train. These are not ingredients for sustainability. The pressure to build has grown as millions of people are still seeking homes (The Guardian, 2016).

The Government has acknowledged many of these shortcomings, which are driving the process to update the NPPF (DCLG, 2015). Whether the new document can correct them remains to be seen.

 

3. Scotland’s Third National Planning Framework

3.1 Aims and Objectives

The Scottish Government published the Third NPF in 2014 to advance ‘sustainable economic growth’ through spatial planning (Scottish Government, 2014, p.iii). The NPF does not define sustainable economic growth, but the Government Economic Strategy, of which the NPF is called ‘the spatial expression’, states that it means making the right investments (e.g., in renewable energy), promoting innovation, being inclusive of both people and regions and having an international focus (Scottish Government, 2015, p.10) (Scottish Government, 2014, p.iii). The NPF addresses these issues from a planning perspective to ‘create high quality, diverse and sustainable places’ (Scottish Government, 2014, p.iii-4). As a spatial plan, the NPF outlines a strategy for specific areas, identifying—in a level of detail unseen in the NPPF—the types of investments and changes that the Government will invest in or support.

3.2 Timeframe

The NPF is a long-term planning document, describing ‘how Scotland should evolve over the next 20 to 30 years’, as updated regularly to reflect changing conditions (Scottish Government, 2014, p.iii). The Government intends the third NPF to last five years, replacing it with the next iteration by 2019 (Scottish Government, 2014). This schedule would align with the five year lifecycles for the first and second NPFs (Smith, 2016).

3.3 Primary Focuses

The NPF specifies four priorities, with each describing the type of place that the Government aims to create, and a set of 14 national developments that link to each priority (see Table 3.3.1). The first priority, A Successful, Sustainable Place, receives the lion’s share of attention—at 34 pages—and is primarily about economic growth and regeneration. Although the section addresses all parts of the country, the NPF states that cities ‘are the main driver of the economy’ (Scottish Government, 2014, p.6). The Government reinforces that assertion by devoting nearly half the pages in the section to cities in general and specific actions for seven city-regions. In contrast, coastal and island communities get only five pages, with three for rural areas. As further evidence, the words city or cities appear 182 times throughout the document, compared to 101 for town(s) and 5 for village.

Table 3.3.1 Overview of the Main Sections of the Third NPF

 

 

 

 

 

 

 

This table lists the five main sections of the third NPF, describes their content and provides their page count.

The NPF also emphasises environmental preservation and conservation. For example, the document designates nearly 20% of Scotland as wild land, which greatly restricts development, and seeks to restore peat and woodlands (Scottish Government, 2014) (Roberts, 2014). To further preserve existing green spaces and promote sustainable transport choices, the NPF encourages concentrating growth in town centres, especially on brownfield sites (Scottish Government, 2014).

The NPF also targets an ‘80% reduction in greenhouse gas emissions by 2050’ (Scottish Government, 2014, p.30). To do so, the NPF would increase walking, cycling and public transport; build homes in ‘sustainable places’ and invest heavily in renewables (Scottish Government, 2014, pp.29). Cities would improve energy efficiency, rural areas would feature onshore wind and coastal areas and islands would be hubs of tidal, wind and wave power (Scottish Government, 2014). In addition to investing in renewable energy, the Government also intends to ‘make best use of existing infrastructure and service capacity’ (e.g., for new developments), while dedicating funding to passenger rail, rail freight and more (Scottish Government, 2014, p.7).

3.4 Prospects for Achieving the Stated Objectives

Overall the NPF presents a clear vision for Scotland to grow sustainably, including an extensive use of case studies with concrete examples of investments that are furthering its priorities. For example, the national developments section provides details for each project, 30 key actions aligned with each priority and a timeline with measurable targets through 2020. Many of these major projects are moving forward, with recent announcements for a £350million expansion of Aberdeen Harbour, a new power plant in the Grangemouth investment zone and a rails-to-trails project in central Scotland (Ship-Technology, 2016) (Scottish Construction Now, 2016a) (Fisher, 2016). Unfortunately, not all signs are positive.

Despite plans to regenerate town centres, Neil Gray (2015), a planning partner with Rapleys LLP, noted that they have continued to decline ‘as shiny new retail parks extend their offerings’. If widespread, this growth pattern would greatly undercut plans to conserve greenspaces and reduce carbon emissions. In addition, a survey by the Scottish Property Federation and GL Hearn found that ‘Scotland’s planning system is only delivering half as many major application decisions per resident in Edinburgh and Glasgow’ compared to cities in England, which may mean the document has failed to provide greater clarity to developers (Scottish Construction Now, 2016b). However, the blame may not lie with the NPF. Fraser (2016b) notes that Scottish planning budgets have been reduced by 20% over the last 5 years.

The most damning indictment is that, as with England, the Scottish Government appears unhappy with the results. About a year after the third NPF was released, Government convened a panel to investigate the planning system. In January 2016, the panel called for eliminating strategic development plans, setting regional housing targets, establishing a national infrastructure agency and more (Edgar, 2016b). Eliminating strategic development plans (i.e., plans for city-regions), would be a radical departure from the level of detail provided in the third NPF and akin to moves in England to eliminate regional planning. Setting explicit housing targets—an issue that received limited attention in the NPF, would also follow the English model. In January 2017, the Scottish Government formally proposed most of the panel’s recommendations (Wood, 2017).

 

4. Wales Spatial Plan 2008 Update

4.1 Aims and Objectives

The WSP 2008 Update aims to coordinate public, private and third sector investment activity within Wales. The plan sets the ‘broad strategic direction’ for the country and serves as the ‘overarching framework and integration tool’ (Welsh Assembly, 2008, pp.iii-iv). In addition, the document specifies five particular roles: to (1) encourage planning across administrative boundaries, (2) ensure decisions consider sustainable development, (3) ‘set the context for local and community planning’, (4) influence spending by the Government and (5) provide a ‘clear evidence base’ for action (Welsh Assembly, 2008, p.3). Local plans ‘must have regard to’ the WSP, although the requirement is weaker than in the NPPF.

4.2 Timeframe

The Welsh Government first issued a spatial plan in 2004, which it subsequently updated in 2008. Although the WSP states that it establishes a ‘broad 20 year agenda’, the 2008 update was only supposed to address ‘the challenges for the next 5 years’ (Welsh Assembly, pp. 3, 7). Wales is overdue for a new plan, a fact recognised in the Planning (Wales) Act of 2015, which requires a National Development Framework to replace the WSP by spring 2018 (Morris, 2015).

4.3 Primary Focuses

The WSP is closer to the Scottish NPF than the English NPPF, dedicating 85 pages to plans for 6 regions with deliberately soft boundaries. For each region, the WSP considers five themes: Building Sustainable Communities, Promoting a Sustainable Economy, Achieving Sustainable Accessibility (i.e., IT and transport), Valuing the Environment and Respecting Distinctiveness (e.g., language). Unlike the NPF which reserves most discussion for its city-regions, the regions around Cardiff and Swansea do not receive more attention than its rural regions.

Likely due to geography and the issues they face, rural areas are a particular focus for the WSP. For example, settlement(s) and rural are mentioned 142 and 119 times, respectively, compared to 69 for town(s), and 55 for city and cities. Adding mentions of Cardiff and Swansea does not bridge the gap. This focus is unsurprising, as ‘Wales does not have a big metropolis’ and most of the country is rural and sparsely populated (Welsh Assembly, 2008, p.22). Within rural areas, particular issues include improving access to transport, creating more diverse economic opportunities, overcoming poverty, accommodating an aging population and conserving natural assets (Welsh Assembly, 2008).

Aside from a general rural focus, the WSP prioritises economic growth. Some of the most common words used in the plan are economic and economy with 305 mentions, development with 250 mentions, skill(s), i.e., building employable skills, with 123 mentions; employment with 113 mentions and growth and growth with 106 mentions. Recurring challenges are deprivation, isolation, out migration of young workers and in migration of middle age/retirees (Welsh Assembly, 2008). The WSP would address them by identifying investments in the regions that are ‘improving accessibility on key road and rail corridors’, creating job opportunities by attracting ‘businesses in high value manufacturing and service sectors’ and building broadband connections (Welsh Assembly, 2008, p. 53, 73).

4.4 Prospects for Achieving the Stated Objectives

The WSP is well-organised with information on each priority, region and achievements and challenges since the 2004 plan. Unfortunately, the WSP is out-of-date and has not received the same attention as the NPF and NPPF. For example, the WSP notes that the Government would release an annual report each year to monitor progress, but, unfortunately, no such reports appear to have been released (Welsh Assembly, 2008). The Swansea Bay and Western Valleys Business Panel also intended to monitor progress toward achieving the goals of the plan, but no website or more recent information about the panel’s activities are available (Crawshaw, 2009).

On one aim—encouraging planning across administrative boundaries, the WSP has had mixed results. Haughton, et al. (2010) concluded that ‘a high level of generality’ in the WSP ‘allows consensus and the appearance of integrated decision-making, but this in effect simply transfers the decision-making process over difficult issues to other areas’. One planner interviewed by Haughton, et al. (2010) noted that because the WSP is at a high-level, it was not a barrier to their work because ‘at that level it allows you to do virtually anything you want’. More encouragingly, Heley (2012) found that most of the 35 local government stakeholders he interviewed reported that they were more willing to engage with peers from other areas on shared issues. Whether similar collaboration is ongoing is not known as more recent studies are not available.

Unfortunately, the scant news about the plan, coupled with the apparent disinterest of the Welsh Government to refer to and/or update the plan more regularly, suggests that the WSP may not have been a significant policy document. In addition, plans for a national development framework may mark a departure from the spatial planning approach in the WSP.

 

 

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