The Historic Towns Forum welcomes the chance to comment on the National Planning Policy Framework. While there is much in the NPPF that is uncontroversial, drawing heavily on existing policy, there are several unsatisfactory elements that the HTF is concerned about and feels need further clarity.
It is difficult to comment on the NPPF in isolation. So much will depend upon the status and content of supporting guidance which should ideally have been issued as part of the same consultation.
Generally the document is less clear than existing policy and is too open to interpretation. To enable economic development, investment and growth, which is the intention, the planning system needs to provide certainty. This is essential for creating investor confidence. It is likely therefore that the NPPF will have a negative impact on investor confidence.
HTF’s Director, Noël James, commented that ‘there is an imperative need for Government to understand the relationship between the quality of the built environment (old and new) and an area’s ability to attract investment. It is essential that the planning system provides the certainty and level of quality assurance necessary to create conditions for entrepreneurial activity. The worry is that the NPPF could actually undermine the ability of many areas to attract jobs and investment. In addition it should be written to apply to all of the country, not just higher growth areas like the south-east.’
‘Town and country planning should be a single activity. Our urban and rural settlements are mutually dependent. National planning policies must strengthen the bonds between communities and not become a means of exclusion.’
The HTF feels that much higher priority should be given to the importance of design and heritage protection. The role of both in securing growth and regeneration, physical and economic, should be given greater priority. HTF feels it necessary to highlight the inherent sustainability of historic towns versus the real conundrum implicit in the term sustainable development as the draft guidance would see it applied. More clarity is required here.
The historic environment is a proven driver of economic prosperity. The distinctive character of our historic towns and cities reflect the investment of individuals, businesses and communities over centuries. These places continue to attract investment because they are successful. People choose to live in, work in, and visit them. Businesses will invest where they find custom. It is important that the NPPF recognises that the historic environment is a means with which to promote growth and entrepreneurship, and that this should be allowed and legislated for in a way that protects and incorporates the historic environment, and not in a way that damages it or the inward and external investment it continues to attract.
HTF, in partnership with Bath Preservation Trust, will be holding a practical half-day workshop on 30 September to help you shape your responses. This will be led by CLG and other experts in the field. Find out more and book your place.