Planning matters blog

Draft NPPF: more emphasis on healthy and safe communities

Helen Ashby-Ridgway 28 Mar 2018

Whilst the connection between the quality of the built environment and health outcomes has long been established, in 2012 the NPPF introduced a step change in the breadth of factors that we as place-makers should be considering as part of the planning process. Gone were the days of ‘health’ policy being limited to the delivery of a health centre, or ensuring a site can be accessed by a footpath. The NPPF recognised that the health of communities can be affected by decisions across a range of land uses, from spaces that encourage social interaction to the provision of schools, and from the delivery of social, recreational and cultural facilities to the active use of public areas. Whilst no definition of health is included in the current NPPF, the thrust of chapter 8, ‘Promoting healthy Communities’, reflects the World Health Organization’s well-recognised definition: “a state of complete physical, mental and social well-being and not merely the absence of disease or infirmity”.

Chapter 8 of the consultation draft NPPF retains this broad approach but of greatest significance, the chapter includes added emphasis on the promotion of safe communities. Overall there is a clear aim for policies and decisions to achieve healthy, inclusive and safe places. To this end, the chapter continues to promote social interaction and the creation of safe and accessible places where crime and disorder - and the fear of crime - do not undermine community cohesion. However, there is also a new paragraph on enabling and supporting healthy lifestyles through the provision, for example, of safe and accessible green infrastructure, sports facilities, local shops, access to healthier food, allotments and layouts that encourage walking cycling.

By far the most significant proposed change in this chapter (and one that reinforces its new title) is the introduction of a paragraph to promote public safety and to take into account wider security and defence requirements (paragraph 96). The proposals are unfortunately responding to our modern reality that attacks do occur (thankfully relatively rarely in the UK). Whilst back in July 2017 the Chief Planner reminded local planning authorities of the role the planning system plays in ensuring appropriate measures are in place in relation to counter-terrorism and crime prevention security, national policy has been restricted to general paragraphs on crime in Chapter 8. The draft NPPF is now more explicit and introduces two elements to the proposed policy:

anticipating and addressing all plausible malicious threats and natural hazards, especially in locations where large numbers of people are expected to congregate; and,
recognising and supporting development required for operational defence and security purposes, and ensuring that operational sites are not affected adversely by the impact of other development proposed in the area.

In terms of the first element, the draft NPPF helpfully provides examples (but not an exhaustive list) of relevant locations as a footnote (Footnote 32). There are some of these developments that are more obvious for assessment (e.g. sports facilities and places of worship) but the need to assess restaurants is perhaps less so. However, the examples reflect the sectors identified in the Crowded Places Guidance (2017) published by the National Counter Terrorism Security Office and highlights that having better security for all these areas makes it harder for terrorists to plan and carry out attacks as well as reducing the risk of other threats such as organised crime.

Click here for larger version

For crime prevention reasons, we are already familiar with the careful choice of what information (such as internal layouts) to include on submitted plans, but these proposed assessments will require more in-depth consideration and analysis. Applicants and their consultant teams will need to work closely with local police, counter-terrorism security advisors and local authority emergency planning teams as part of the pre-application stages of a project. Having worked on a similar statement in the past, confidentiality is key; many of these discussions are likely to take place behind closed doors and the final assessments will be published in confidential reports. The Crowded Places Guidance is an excellent starting point for developers and their design teams.

Turning to the remainder of the chapter, the other main proposed change relates to estate regeneration (paragraph 94). It states that planning policies and decisions should consider the social and economic benefits of estate regeneration (which can include better homes, improvements to neighbourhoods, new community facilities, training and employment and more). The draft Framework also states that local planning authorities should use their planning powers to help deliver estate regeneration to a high standard. It’s clear that the Government links estate regeneration to improved health outcomes. However, the need for close engagement with the community is arguably not one of the Government’s priorities – a notable difference when compared with the London Mayor’s recent consultation on resident ballots, and draft paragraph 153 which introduces the need to consider community views on the acceptability of wind energy development.

In discussing national planning policy on health, it is noted that the draft revised NPPF does not introduce any new requirement for Health Impact Assessments (HIA) to accompany planning applications. However, from experience we know that local planning authorities are increasingly issuing guidance on creating healthy communities and making HIAs an application validation requirement for a range of development proposals. In the context of extreme fiscal challenges, the NHS, Public Health England, local authority teams and government departments continue to look at prevention measures across all policy areas. As such, it is expected that the number of local planning authorities that require the health implications of proposed developments to be assessed at application stage will rise further, as more post-NPPF plans are adopted.

Overall, promoting healthy communities is staying very much on the Government’s planning agenda but with a new focus on national security and defence, beyond what has been seen before.

See our other blogs in this series:

National Planning Policy Framework review: what to expect?

Draft revised National Planning Policy Framework: a change in narrative

NPPF consultation proposals – what could they mean for town centres?

NPPF consultations – what could they mean for designers?

Draft NPPF: heritage policy is conserved…

Draft NPPF: implications for aviation?

Draft NPPF: Business as usual?

Lichfields will publish further analysis of the consultation on the revised NPPF and its implications. Click here to subscribe for updates.

Image credit: Deptford Market Yard

Heritage in the North East: can it be the solution rather than a problem?

Isobel Jackson 27 Mar 2018

Historic buildings and sites are often seen as a burden, with high levels of risk and financial liability attached. But, in the North East, could they create opportunities and solutions, rather than problems?

Lichfields recently completed a pioneering study for Historic England looking at the economic, environmental and social returns offered by historic sites in London which have been declared as ‘at risk’. The study found that investing in such heritage assets can result in numerous benefits which go far beyond just the conservation of historic fabric, such as successful place making and regeneration, job creation, the enhancement of social facilities and vastly altered local perceptions.

The development industry in the North East is focussed on delivering the homes we need to address the housing crisis, creating jobs and promoting economic growth. But the economic context in which we are working is quite different from that of our colleagues in London. Is it possible for us to be able to use heritage assets in the same way, to realise wider economic and social benefits, and with heritage as the catalyst rather than the goal?

Is it a different picture?

Historic England compiles a register of designated heritage assets which are ‘at risk’ on an annual basis. Nationally, it includes scheduled monuments, listed buildings at Grades I and II*, places of worship listed at any grade, registered parks and gardens, registered battlefields, protected wreck sites and conservation areas. In London, the list is more extensive as it also covers Grade II listed buildings.

The graph below compares the types of heritage assets on the register in London and the North East. Most of the ‘at risk’ heritage assets in London (67%) are Grade II listed buildings, a figure which is to be expected given that 90% of listed buildings (both nationally and in London) have this grade. In the North East, scheduled monuments represent 58% of all ‘at risk’ assets, by far the majority; this category includes cairns, the remains of settlements, mining legacy features and rock art. These are features where the solution to their heritage-related needs is unlikely to be in the form of the new uses and occupation like other types of buildings and structures.

Figure 1 Proportion of assets on Heritage at Risk Register in each category

Source: Historic England with Lichfields analysis

Closer similarities between London and the North East appear when Grade II listed buildings and scheduled monuments are omitted from both areas (see the graph below), while just focusing on assets in urban areas in the North East also shows a similar picture of Heritage at Risk to London.

Figure 2 Proportion of assets on Heritage at Risk Register in each category shown

Source: Historic England with Lichfields analysis

This data shows that, given the parallels that can be drawn between the London and North East heritage at risk registers, there is potential for some of the benefits identified within the London report to be similarly achieved in the North East.

It also raises the question of whether Grade II listed buildings should be included on registers outside London, given the number which are probably at risk. Perhaps when considering how best to use heritage as a catalyst for economic growth, development and regeneration, a looser definition of ‘at risk’ should be applied, not just focussing just on those assets included on the Historic England register but any heritage asset - designated or undesignated - which could fall within the definition of ‘at risk’ and which, with investment, could deliver wider benefits.

Opportunities for the development industry

The map below shows a correlation between assets on the North East Heritage at Risk Register and deprivation in urban areas. The picture in more rural areas, such as Northumberland and Durham, is less clear. There may be several reasons for this pattern, including that output areas are larger in size and, as a result, areas of high and low deprivation may be averaged out. Also, most assets ‘at risk’ in rural areas are scheduled monuments which are generally at risk not because of lack of investment but due to other threats, such as agricultural practices. What is clear though is that particularly in urban areas in the North East, there is great potential for the regeneration and wider social benefits recognised in the London report to be achieved.

Some of the best opportunities for regeneration and wider social benefits may occur either when grant funding is available to close the viability gap between costs and the end value or financial return or, perhaps more importantly, when other benefits of investment, such as delivering economic, social or environmental improvements in line with ambitions for particular areas, can be prioritised over initial financial returns. For assets in public sector ownership, the requirement that land should not be disposed of for less than ‘best consideration’ is potentially a complicating factor and could result in missed opportunities if proposals for reuse and associated development are not explained well in relation to their consistency with planning policy, the asset’s current state of repair and its future existence and other potential non-financial and wider regeneration benefits and positive impacts.

Discussions with key individuals in the development and heritage sectors in the North East has also highlighted that to secure private investment, and perhaps reduce the need for grant funding which itself can be off-putting to developers, there is also a need for more to be done to ‘de-risk’ a heritage asset by providing greater certainty to future investors about the features which are most important and where there may, or may not, be scope for change. There is a clear role here for Historic England’s Enhanced Listing service, and/ or a detailed development brief, supported by a heritage assessment, to understand the special interest and development potential of the asset.

There are also potentially important roles for cross-funding and enabling development, which could help meet wider development needs and, through Section 106 contributions, support the conservation of heritage assets which would otherwise not receive investment without grant support. In such cases, heritage at risk may open up new sites for development which would have otherwise not been policy-compliant.

The historic environment in the North East, and in particular Heritage at Risk, presents an undervalued and underused opportunity to stimulate economic growth and help meet development needs, while also delivering wider social and environmental benefits.

Future work

The London Heritage at Risk study has identified a number of benefits of investing in Heritage at Risk and there is good reason to think that, despite the differences between London and the North East, the findings will hold true for other urban areas.

A number of potential solutions and opportunities presented by Heritage at Risk in the North East have been identified within this blog; a better understanding of the opportunities presented by investment in these heritage assets is of course still required, especially due to the different economic contexts and disparities between land values and investment returns in the regions compared with London. But the importance of the wider social and environmental benefits arising from such investment should not be understated or underestimated when compared with economic outputs which are easier to quantify. A tool to assess, quantify and share these would clearly be of huge benefit. Watch this space…!

Engaging in the 3rd and 4th dimensions

Mark Kilgallon 20 Mar 2018

To quote my colleague Dominic Smith in his recent blog about the Language of Public Consultation:

Consultation and engagement with local communities plays an ever increasing role in the planning system and the preparation of planning applications

As part of Lichfields’ graphic design team, I produce quality consultation materials for face to face and digital events every day.

The use of high quality technical drawings and 3D renders of a proposed scheme helps to bring a scheme to life. However, they can be difficult to interpret for those who aren’t used to reading them. It’s therefore important that we explore other ways of engaging with stakeholders and communities to ‘put them at the heart’ of the scheme they are reviewing. Here are some ways in which this can be done:

3D printing

Historically, whilst extremely helpful, cost and time have been barriers to supplying hand-made scale models for consultation use. In recent years, the growth in 3D printing (which has been compared to the second industrial revolution) has seen a rise in businesses using 3D printing as a tool to produce models easier, faster and cheaper. See my blog 3D Printing in construction, health and manufacturing for further detail. Scale models give you the freedom to walk around a project, pick up individual elements and to view it from any angle. By using 3D printing, models are now far easier to produce accurately and economically to engage more widely in the planning process.

Considering the size and materials

The variation of materials that can be used to create objects in 3D printers are as wide and varied as the objects they can produce. As such it is very difficult to state set costs as there are a number of variables. Plastics are by far the most commonly used material for smaller objects but more robust materials such as metals are used when the object is larger. I have created the below animation which summarises the considerations for sizes and materials. While this blog has focused on creating more solid, architectural models, 3D printers can also be used to print organic materials such as food or even replacement organs or bodyparts.

VR & AR – The virtual is now an affordable reality.

There are two ways to access the virtual world.

There is the ‘Ready Player One’ method (or Virtual Reality – VR) which was at first developed for the gaming industry and involves putting on a pair of goggles to give you an immersive 360 degree experience inhabiting that world. VR production company ReWind was an early adopter of VR as a public consultation tool back in 2015 by using it to create a virtual tour of Furze Croft in Weybridge, a property that boasted former residents Tom Jones, John Terry and Elton John. Attendees of the Masterpiece Fair in London experienced a 360 degree VR tour of the building.

The second format is Augmented Reality (AR),which, rather than inhabiting a virtual world, allows the virtual image to be overlaid on top of the normal world by looking through a virtual window. The most famous version of this tech to date is Pokemon Go (ask your children!).

Lichfields is at the forefront of creating high quality materials for use at public consultation and engagement events. However, a developments’ benefits lie beyond statistics. These new technologies have the potential to impact hugely on the property industry and in the case of AR to also make the consultation process more accessible by reaching those unable to attend an event in person. In addition to exploring new technologies, we provide a full event design and digital service to our clients. I, for one, am excited to see where these technologies take us.

Draft NPPF: business as usual?

Ciaran Gunne-Jones 16 Mar 2018

The National Planning Policy Framework (NPPF), consulted on in 2011 and published in 2012, came as the UK economy was emerging from the deepest recession in a generation. Today, that period of recession continues to cast a long shadow in terms of impact on the public finances and productivity levels, and is now complicated by the economic uncertainties created by Brexit. In his Spring Statement earlier this week, the Chancellor Philip Hammond summed up that there is “light at the end of the tunnel”, but the latest Office for Budget Responsibility (OBR) forecasts point to a prolonged period of somewhat sluggish growth ahead (see Lichfields’ analysis).

In that context, the Government has chosen to make limited substantive change in terms of directing planning policy for the economy and business through its recently published draft NPPF. An “economic objective” remains the first overarching objective of the planning system (paragraph 8, point a). However, the wording has been broadened to expressly refer to the need to, “support growth, innovation and improved productivity” (emphasis added). Productivity is a concept rarely explored in any great detail in plan-making or decision-taking, but the added emphasis seems appropriate given the national imperative on the issue.

In line with the draft NPPF’s new structure, economic considerations (including the rural economy) now have their own chapter (6). In the current NPPF, “building a strong, competitive economy” is the first element of delivering sustainable development – tellingly, it now follows the chapter on delivering a sufficient supply of homes. In terms of content, however, the wording of the draft chapter looks familiar when compared to paragraphs 18-22 of the current NPPF. In line with the wider amendments to the current NPPF, the text has been reduced and simplified.

The widely-cited line that the planning system should do, “everything it can to support sustainable economic growth” (paragraph 21 of the current NPPF) disappears, but the general direction – and note the further reference to productivity – remains clear:

“Significant weight should be placed on the need to support economic growth and productivity, taking into account local business needs and wider opportunities for development.” (paragraph 82)

Also notable is the specific reference to the Government’s Industrial Strategy White Paper. This is not surprising, and is sensible; as written in an earlier blog, Government very much sees the Strategy as cutting across all areas of policy-making. In the same vein, planning policies should now have regard to Local Industrial Strategies (paragraph 83, point a). The Industrial Strategy, and how it is manifested locally, is therefore set to become more influential in plan-making and a potential material consideration. Local authorities and sub-regions will therefore want to be proactive in bringing forward Local Industrial Strategies not only to help realise growth opportunities in their area but also given the weight they might carry in making future planning decisions.

On employment land more specifically, the NPPF currently states that, “planning policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose” (paragraph 22). This no longer appears in the economy chapter, but now features in expanded form in chapter 11 on “making effective use of land”. The sentiment is largely the same but the test has been sharpened: regular reviews of allocations are required and, even prior to plan reviews, applications for alternative uses should be supported where unmet needs for development could be provided for. Furthermore, in “areas of high housing demand”, the use of existing employment (and retail) land for homes is supported where this does not “undermine key economic sectors or sites”.

Taken overall, the draft NPPF looks very much like ‘business as usual’ when it comes to planning for the economy – there’s little in the way of new detail or prescription. As they start to come forward, Local Industrial Strategies will need to give consideration to how local plans can help deliver wider economic objectives, particularly improving productivity. The Government appears to view employment land as something of a sacrificial lamb in the quest to meet housing needs (in contrast with the much stronger policies to protect employment land proposed in the draft London Plan, as detailed in recent research by Lichfields). It’s also less clear how well the approach proposed nationally sits with the Government’s clearly stated intentions to support economic growth and productivity.

Ultimately, local authorities will need up-to-date and more comprehensive evidence to inform their judgments about the need for, and relative importance of, the employment land in their areas, particularly in the face of added pressure for release to other uses. Economic evidence looks set to remain key to planning decision-taking.