Bearing in mind the NPPF waxes lyrical about the presumption in favour of sustainable development, and the ‘golden thread’ of sustainability that runs through planning, it might appear crass to question what is meant by sustainable development. But I’ll do it anyway.
Last year I was preparing for an appeal. I was reading through various planning committee reports and reviewing the well meaning, but ad-hoc analysis undertaken by the respective planning officers. They were inconsistent. They were unsubstantiated. They were absolutely open to scrutiny. I looked at my own analysis. I felt it was robust and capable of defence under cross-examination, but I was conscious that along with the planning inspector that would ultimately determine the appeal, all of the professional planners involved in the process would be applying their own interpretation to what is meant by the term sustainable development, and in turn, the presumption to be applied to the same. God help any members of the community looking on from the gallery.
One might initially say, so what? Well to my mind, it matters a great deal. The NPPF sets out to increase the pace and volume of development, albeit with the laudable caveat that it should be the right kind of development – sustainable development. The NPPF identifies the three strands of sustainable development – economic, social, and environmental, and references to these categories, and sustainable development in general, courses through the NPPF. But ultimately, it doesn’t say what it is, or at what point (or level) the presumption is triggered. Is it about carbon neutral development? Is it about being close to public transport? Can you be sustainable if you satisfy one of these credentials but not the other two?
Once the dust had settled on my appeal, I got to thinking. What if there was a criteria to sit alongside the NPPF that all practitioners, stakeholders, and the public at large could use as a yardstick to appraise planning proposals (development plan submissions and applications alike)? Would it be so difficult to, say, rate the economic, social, and environmental components of a scheme, to bind the complex and extensive planning submission documents into a single rating system, and to then provide a blended overall outcome?
I’m pleased to say that I was not alone in thinking that this could be a good thing. With the wise counsel of Nick Raynsford, the former Labour Housing Minister, Iceni are in the process of setting up a Sustainable Development Commission, the purpose of which will be to scrutinise those elements, their applicability and the weight of significance, to be applied to planning proposals. We are presently formalising the membership of the Commission, but at the time of writing we already have the commitment of a number of eminent people, who are well known in their day-jobs, and have generously agreed to spend their own time scrutinising and developing our initial ideas. These include Shaun Spiers (Chief Executive, CPRE), Sue Smith (Joint Chief Executive, Cherwell District Council and South Northamptonshire Council), Stephen Ashworth (Partner, Dentons) and Janet Askew (RTPI President, 2015). We are looking to finalise the involvement of two developers (one with a specific interest in housing), and a planning inspector, which will provide an excellent cross-section of interests in planning and development.
What would I like to see come out of this process? Ideally, for all practitioners to be in a position to apply the same, easily understood criteria to all projects, so that there is consistency in decision making, and a real understanding of what constitutes sustainable development. Time will tell as to whether we can achieve this, but Iceni will certainly be leading from the front, and will apply a weighting system to the projects we work on – what we have dubbed a Sustainable Development Scorecard – to guide our clients into delivering the best possible proposals, that can equally provide the best possible community outcomes from the same.
Large numbers in our society still have very little understanding of who funds the improvements in transport infrastructure, health, education, community facilities and affordable housing, to name but a few. I think a Scorecard – and the principles underpinning it – can help to present these facts in a lucid fashion. Equally, I think we do need a tool that local planning authorities and communities can apply to hold developers – and development – to account. Providing investment in a new water treatment works and flood protection should be worthy of recognition, and may well secure a credit along the way to justifying the sustainable development credentials of a scheme. Equally, the erosion of important agricultural land has the potential to mark down a proposal. A Scorecard system would allow supporters and objectors alike to rate the credentials of any given project.
It’s important to say that Iceni are not seeking to claim ownership of Sustainable Development. The objective is borne out of the NPPF, and our proposals for a Scorecard will be signposted at all stages back to the NPPF. Others may look to devise an alternative criteria, or seek to apply a more detailed layering to the analysis, which would be a positive outcome of this process, and one to be welcomed.
As a final comment, I sincerely hope the outputs of the Commission – and how Iceni would apply a Scorecard – will be a tool that is accessible to all, and not simply sustainability consultants on the margins of projects. Planning is not rocket-science, but it is all-consuming; it affects all of our lives, and we all have a point of view. The major benefit of the NPPF is that it has made planning policy easy to find, and in the main (objectively assessed need discussions aside) relatively easy to understand. That is a very solid objective, and sustainable development, being a fundamental objective of the NPPF, needs to be kept firmly in the centre ground of planning and decision making.