The recent publication of the draft revised National Planning Policy Framework and other supporting documents signal a number of changes to plan-making.  Jonathan Pearson asks what it means for Sustainability Appraisal (SA) of local plans.

The Government established the Local Plans Expert Group (LPEG) in 2015 to consider how to improve local plan making.  Among the LPEG recommendations was a call for the process of SA of local plans to be scaled back, primarily by deleting the advice that SA is an iterative process and that it needs to consider reasonable alternatives.  Instead, it was recommended that a single stage of SA be carried out, assessing how a local plan represents sustainable development against the requirements of the NPPF.

The Government’s response to the LPEG report accepted that the plan-making system is in need of reform.  The proposals for reform were published in 2017 in the Housing White Paper, in the consultation document Planning for the right homes in the right places, and in the planning and housing market-related proposals of Budget 2017.

Notably, those proposals did not include reform of the SA process, perhaps because of the mixed reception that the LPEG recommendations on SA received during the consultation.  The draft revised NPPF is designed to implement the Government’s reforms, so it is not surprising that changes to the SA process are absent; instead, the focus is very much on improving the supply of homes.

However, there are some potential implications in the NPPF amendments, for example in relation to identifying the ‘reasonable alternatives’ that will be assessed.  The current NPPF includes examples of policies which provide a specific reason for restricting development but this is proposed to be changed to a defined list.  The new list (footnote to paragraph 11(d)) expands on the existing examples to include ‘irreplaceable habitats including Ancient Woodland’ and ‘aged or veteran trees’.  This list provides a logical starting point for flagging up development site options that are subject to ‘showstopper’ constraints and that can therefore be excluded from the SA as ‘unreasonable’, although other suitability considerations (for example flood risk) and issues of achievability and deliverability will continue to be relevant.

In summary, the proposed revisions to the NPPF will have little effect when it comes to the SA of local plans.  Only time will tell what will replace the requirements of the SEA Regulations following Brexit and whether this will be seen as an opportunity to pick up on LPEG recommendations and scale back SA requirements for local plans.  LUC will continue to follow developments closely.

For more information on our Strategic Planning & Assessment services, including SA, speak to Jonathan Pearson.