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NPPF - Our view

Richborough Estates recently submitted a written response to the Department of Communities and Local Government concerning the draft National Planning Policy Framework (NPPF) and this is a summary of the submission – however if you wish to view the entire document, please click on the link at the bottom of the page.


The Government is to be applauded for attempting to simplify National planning policy which has become too complex and burdensome. The present system results in unnecessary delays in the production of Local Plans and in determining planning applications and the whole process is far too inflexible due to the amount of policy and guidance.

Unfortunately a simplified system still requires the policy to be clear, precise and consistent and it is therefore regrettable that the Draft NPPF does not deliver on these important objectives.  Throughout the document, phrases are too loose and open to interpretation whilst a lot of the advice seems disjointed and inconsistent.

Certainly the restoration of a presumption in favour of development is extremely welcome and notwithstanding much of the criticism from certain parts of the media and environmental lobby groups, it is critical that this presumption should be retained. The use of the term sustainable development is understandable but unless the NPPF is able to satisfactorily define in clear terms how sustainability is to be measured, it will simply confuse the objective and dilute its effectiveness.

The other principal concern of the NPPF is that it lacks the necessary spatial vision within which strategic growth needs are to be considered and delivered. Whilst the Government's commitment to localism and to involve communities more in decision making and plan preparation is entirely supported, it cannot be to the detriment of strategic thinking where growth needs that require cross boundary cooperation are concerned. The NPPF as drafted does not provide a coherent framework within which the necessary level of strategic planning can be carried out and enforced.

Instead the golden thread that is said to run through the NPPF to deliver growth will not be fulfilled.  Accordingly it is vital that the NPPF is redrafted to remove vague and conflicting phrases, to resolve the lack of clarity as to how sustainable development is to be measured and to balance the Government's desire to embrace its localism agenda with the vital need to ensure that important strategic plan making and decision taking can be delivered and enforced.

Download NPPF - Our written submission