(… continued from Compensation culture, part 3, posted on 24 Feb 2017).
I don’t believe that I am alone in regarding the National Planning Policy Framework (NPPF) as providing too little protection for our natural environment. Chief amongst my concerns is the “presumption in favour of sustainable development”, which the NPPF describes as “a golden thread running through both plan-making and decision-taking” (see footnote 1). We are told that “the purpose of the planning system is to contribute to the achievement of sustainable development”, and that the NPPF sets out “the Government’s view of what sustainable development in England means in practice for the planning system” (see footnote 2).
The NPPF helpfully reminds that the United Nations’ definition of sustainable development is “meeting the needs of the present without compromising the ability of future generations to meet their own needs” (see footnote 3). This appears to me to be a very tough requirement to satisfy, and I don’t see that the NPPF comes anywhere near measuring up to this.
Take, for example, the exception in the NPPF that I mentioned in part 3 that permits a developer to justify the destruction of irreplaceable natural assets on the basis that the “need for, and benefits of” his planned development will “clearly outweigh the loss” of that asset. This is, I feel, at least potentially an unsustainable activity because, clearly, future generations are being deprived of that natural asset: whether you regard that as compromising the ability of those future generations “to meet their own needs” depends on your own value judgement, but I would say that it does if we define “needs” as the things that sustain more than just a basic existence.
Despite the NPPF identifying “three dimensions to sustainable development” – economic, social and environmental (see footnote 4) – it is clear that it is economic growth that the Government wishes to encourage above, and even to the detriment of, the other two dimensions (see footnote 5):
“The Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth. Planning should operate to encourage and not act as an impediment to sustainable growth. Therefore significant weight should be placed on the need to support economic growth through the planning system.”
The implications could not be plainer: in our planning system the interests of the natural environment are subservient to economic interests.
Although the NPPF is important in setting the policy for determining decisions on planning applications, it does not, as is stated therein, “contain specific policies for nationally significant infrastructure projects for which particular considerations apply” (see footnote 6). In the case of Phase 1 of the HS2 project the determination of planning decisions was entrusted to two groups of parliamentarians working within Victorian procedures, and subsequent to an overwhelming vote of support for the project to be built in both their respective Houses. Notwithstanding, one would surely expect the decision making to follow broadly similar guidelines to those that are prescribed by the NPPF, if they were to be consistent with national planning policy.
Despite this I cannot recall, on any occasion, the question being asked in either of the HS2 Phase 1 select committees just how sustainable HS2 is, and whether it was likely to deliver sufficient benefit to the national economy to justify its undoubted negative impacts on the natural, and indeed social, environment. The reason for this, of course, is that the decision to go ahead with HS2 Phase 1 had already been made at Second Reading, so neither select committee considered this a question that fell within its remit. However, since the question does not appear to have been addressed in either second reading debate also, this fundamental aspect of the planning process has been, it would appear, effectively swept under the parliamentary carpet.
There is no excuse for neglecting to tackle this issue, since one of the tick-box exercises that HS2 Ltd completed in the early days of the project was a detailed Appraisal of Sustainability for Phase 1. This document includes a massive tabulation of appraisal data, assessed against a set of evaluation criteria (see footnote 7), but fails to assess what that data mean in terms of the overall sustainability of Phase 1. I addressed this shortcoming in a couple of blogs that I posted in the autumn of 2011 (see footnote 8), presenting some analysis of my own and reporting the expert opinion of the Principal Sustainability Officer of the London Borough of Hillingdon – a qualified planner with fifteen years experience within the environmental sector – that Phase 1 was, at the time that the analysis was made, “effectively an ‘unsustainable’ project in all but the economic categories” (see footnote 9). Since a number of eminent authorities (see footnote 10) have since challenged the soundness of the economic case, even that saving grace appears to be in doubt and there is considerable justification for the expert from Hillingdon’s categorisation of HS2 Phase 1 as “a significantly unsustainable scheme” (see footnote 11). It is his expert opinion that (see footnote 9):
“New infrastructure projects, even if they are considered essential for the national interest, are not exempt from being carried out in a sustainable way.”
(To be continued …)
- See paragraph 14 of the document National Planning Policy Framework, Department for Communities and Local Government, March 2012.
- See paragraph 6 of the National Planning Policy Framework.
- See the sidebar on page 2 of the National Planning Policy Framework. The source of the definition is Resolution 42/187 of the 96thplenary meeting of United Nations General Assembly, held in December 1987.
- See paragraph 7 of the National Planning Policy Framework.
- See paragraph 19 of the National Planning Policy Framework.
- See paragraph 3 of the National Planning Policy Framework.
- This tabulation may be found in the publication HS2 London to the West Midlands Appraisal of Sustainability, Main Report Volume 2 Plans and Appraisal Framework, Booz & Co and Temple for HS2 Ltd, February 2011.
- The two blogs are Scoring an own goal (posted 22 Sep 2011) and You weren’t supposed to read that (posted 26 Sep 2011).
- See paragraph 13.1 of Appendix 13 (Assessment of Sustainability Overview) to 51m Response to HS2 Consultation, Ian Thynne for the 51m consortium of Local Authorities, July 2011.
- Probably most significantly the House of Lords Economic Affairs Committee, see paragraphs 10 and 11 on page 7 of the publication The Economics of High Speed 2, 1st Report of Session 2014‒15, House of Lords Economic Affairs Committee, March 2015.
- See paragraph 13.6 of Assessment of Sustainability Overview.