Planning guidance beta site: a preliminary response
Planning guidance beta site
Initial response from Alister Scott BA PhD MRTPI Professor of Environment and Spatial Panning.
Birmingham School of the Built Environment, Birmingham City University, firstname.lastname@example.org
The new national guidance is welcome and much needed despite initial statements by government
when the NPPF was launched. The reduction of 1000s of pages of planning guidance to 52 was an
ambitious idea but clearly was found wanting as brevity led to considerable blurring and confusion.
The following is a brief response to the guidance that I have selectively read.
Structure and Layout.
The structuring of the guidance is crucial to getting engagement. I like the use of questions to help
structure and signpost the guidance within sections. The use of hyperlinks is helpful but at present
there are, in some sections, far too many questions “thrown in” without regard to any
prioritisation, sequencing or linkage. I would like to see all questions in a sidebar which allows users
to see all the guidance in that topic area without having to scroll. The scrolling is a definite turn off
and poor given web page development.
I think the questions need reducing to those that are key in an area and there needs to be less
blitzing of the reader with links. Whilst a good idea there are far too many here and it is an easy cop
out to link rather than to capture the key message from the link you want to give. In many cases
whole documents are too broad. I believe just signposting documents to go to is not as helpful as
providing links to other associated questions (from other areas of guidance). The loss of the
interconnectedness of key planning issues is a real risk here. The structure could allow for some
very dangerous cherry picking. The compartmentalisation of different areas even within sections is
actually quite misleading in my view.
The beauty of the previous PPS/PPG notes (yes there were some!) was that they provided a
narrative for a given subject area. I feel the new guidance should try to tell the story using the
headings in the NPPF but then use the questions to maximise the relevance to key concerns. At
present it reads like a dictionary of terms.
The topic areas are interesting but I would like to see topics with more generic focus; so for example
where is rural planning and development guidance; it sits uncomfortably in several sections with no
clarity. The lack of clear guidance for rural areas will hinder effective delivery of rural polices which
is a legacy problem for UK planning. Interestingly, green belts do not feature either as a stand-alone
area for guidance and I think they should. I also think that permitted development should be a
stand-alone section too. The government has made a considerable number of changes (conversion
of business to residential, extensions to houses and conversion of agricultural buildings) here and
guidance should be issued as to how to deal with this.
Given the centrality of sustainable development (SD) to the NPPF there is an urgent need to
properly define what SD is. The guidance document liberally uses the term throughout yet nowhere
is there a clear and operational definition. The NPPF helpfully states that it is based on all the 200+
paragraphs but given the way that in the absence of an approved plan developments can be
approved if they are sustainable, surely it demands an upfront and explicit section that answers the
question what is SD?
The guidance at present seems to encapsulate some guidance but also reads primarily as a
dictionary of terms with information overload on areas which actually does not constitute guidance.
I think there is a need to filter out some of this padding and focus more on producing clear and
concise guidance. The NPPF championed brevity. I see no sensible reason why the guidance should
not be concise as well. So for example in the SEA section it is defined twice and there is a lot of
developmental material saying on at least 4 occasions it is about delivering SD. Interestingly for me I
would like to have seen the need to have SEA done on a parallel track with a local plan process
rather than afterwards as is common practice.
I would argue that the government might consider using exemplars from practice that illustrate
where the topic has been done well in practice. The best guidance comes from real-life examples
and this would bring a breath of fresh air too what is text dominated document.
I have read the following sections : Neighbourhood Plans, Natural Environment; SEA and rural
My feeling is that I felt swamped with material and wanted the guidance to help identify the key
issues. The weakest for me was the Duty to Cooperate which actually plays a crucial role in the plan
process and yet which firmly puts the onus on authorities to identify their own strategic priorities.
The lessons from our research work point to the need to have a consistent approach to the co-
operation model. The current DTC tends to have local authorities working together on key issues of
housing and transport but rarely extends to catchment scales so as to meet part of the natural
Environment objectives. The DTC is vital for planning and I would favour a more prescriptive model
here that integrates. The failure to include LEPS and LNPs in this process as of right is a missed
So for example in Redditch there are currently proposals for 10,000 houses at stake. Redditch has
little room for development in its own boundaries so has been joint working with Bromsgrove
planners to identify space in Bromsgrove in the greenbelt. However, there is confusion over whether
a housing allocation can be made in green belt in a neighbouring authority. This is a common
planning issue and yet there is no guidance on this matter which in effect could allow well thought
out plans using the duty to cooperate to fail. The guidance therefore needs to be more aware of the
legal challenges that can occur and needs to address this.
The rural housing section is poor and confusing and indeed does have ambiguity and contradiction
throughout. The continual usage of sustainability as being synonymous with more growth is
worrying. There is a need to focus on context, layout and environmental and infrastructural limits.
The natural environment section did not make the connection with the environment as an asset
for development. I felt most worryingly the paragraph 109 on ecosystem services stuck to the
myopic economic valuation lens for translation into policy rather than expose the reader to the
Defra principles of the ecosystem approach.
Taking a more holistic approach to policy‐making and delivery, with the focus on maintaining
healthy ecosystems and ecosystem services
Ensuring that the value of ecosystem services, are fully reflected in decision‐making
Ensuring that environmental limits are respected in the context of sustainable development,
taking into account ecosystem functioning
Taking decisions at the appropriate spatial scale, while recognising the cumulative impacts of
Promoting adaptive management of the natural environment to respond to changing
pressures, including climate change
Identifying and involving all relevant stakeholders in the decision and plan making process
1. Really important to have guidance to support the NPPF which is not sufficient to strand on
its own two feet.
2. There is a need to have generic headings within which a guidance narrative is written. At
present some of these are missing : SD; Permitted Development; Rural Planning and
3. Produce guidance with questions visible for whole section.
4. One point that is not mentioned; to what extent can the guidance be open source to allow
experience to inform on-going review and update