Responding to the UK Government’s Consultation on the proposed changes to the National Planning Policy Framework
24th September 2024
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The National Planning Policy Framework (NPPF) sets out the Government's economic, environmental and social planning policies for England. The policies set out in this framework apply to the preparation of local and neighbourhood plans and to decisions on planning applications.
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The NPPF holds significant weight in how our urban, and natural, environments are formed. The policy guidelines in the NPPF are interpreted by Local Planning Authority policy writers. Those policies influence how our neighbourhoods are protected, grow, and the nature of them. it is critical that guidance reflects the best possible information and available research of the day to offset the risks of unintended consequences that create health inequities.
The government published a consultation on proposed changes to the National Planning Policy Framework on 30 July 2024. It included questions and proposed changes on a number of topics, which have implications for people’s health and wellbeing. This paper sets out Centric Lab’s responses to questions and policy changes and how they influence health.
Health is more than the sum of our personal behaviours. It is a dynamic biological interaction with the microbial, environmental, social, and built environments around us. Through biological regulatory systems such as the HPA-Axis our bodies are constantly responding to changes in stimuli. For example, changes in external temperature can cause our body to release stored energy to ensure we reach an equilibrium and maintain a healthy body temperature. Equally, when faced with a physical threat such as a speeding vehicle our body responds to produce chemicals such as adrenaline to provide short term strengths to move out of the way. This natural system has evolved with us over the years we’ve been on this planet.
However, research has repeatedly shown that when people are repeatedly exposed to novel stressors that cause these aforementioned biological responses a wear-and-tear can occur on internal regulatory systems. As a result, over sustained periods of time a dysregulation begins to occur, which can then result in a permanent change to how our body functions.
There is mounting evidence that these dysregulations of immune, endocrine, and metabolic systems are pathways to the development of non-communicable diseases, such as the relationship between psychological and physiological trauma and the development of obesity. This means that we need to take a more scientifically accurate approach when looking to make positive impacts to people’s health in context to the role of the built environment.
The UK Government recognises the importance of tackling NCDs and that “effective public health strategies can deliver an extensive range of benefits, not just to individuals but to communities, the health service and the economy as a whole.” The UK Health Forum warned that: “The current and escalating future burden of non-communicable disease on the NHS is unsustainable”. It therefore should be an imperative for central and local governments to set guidance that is more accurate and to develop policy with the best resources available.
This paper aims to build on the existing knowledge base that spatial planning has a role in influencing health outcomes, and articulates it towards being more biologically, culturally, and socially accurate. The result is a reduction in the exposure to environmental and psychosocial stressors through a range of direct and systems-based solutions.
N.b.
For the avoidance of doubt we have focused our comments specifically in reference to proposed changes. There are numerous areas of the NPPF that Centric Lab and its ecosystem of health justice partners would wish to comment on, however that would make this piece of work onerous and not in context of the Government’s consultation. That may be saved for another time…
OBSERVATION 1
The NPPF’s vague and undefined use of terminology around strategy means that attempts to address the injustices around housing needs, the unjust spatialised nature of service provision, the inaccessibility of our built environments as well as broader issues relating to environmental degradation and climate change can all be loosely interpreted and misused to ensure self-serving behaviours entrench inequities.
OBSERVATION 2
Without accuracy, ambiguity, complacency, and ignorance run amok. When matters of health, communities, inclusion, and safety are left to be decided at the whim of a policy writer people can easily be harmed. We’ve proposed definitions to: Community/Communities, Community-led Health Impact Assessment, Inclusive, Health, Modern Economy, Resilience, Safe/Safety, Sustainable Development.
OBSERVATION 3
The amendment to explicitly address the disease of Obesity as a spatial planning issue without also addressing any issues of pollution, contamination, and social inequity shows a weak understanding of disease pathology. These subtle policy inferences carry huge weight as when trickle-down narratives are formed. It allows for inaccurate policies to be justified despite the harm they cause, and the evidence suggesting otherwise. Research from our Obesity Justice programme, Obesity is increasingly understood as a condition marked by the dysregulation of multiple bodily systems, with mental health, stress, and environmental factors playing a crucial but often under-recognised role.
OBSERVATION 4
Currently, at its core, the NPPF holds a presumption in favour of sustainable development (again, undefined), which means that the driver behind planning in the UK is the new development of land, maximising and extracting value. When the dominant driving force of change in the built environment comes from profit-motivated companies, this embodies extractive practices that have routinely shown to harm people and entrench inequities. The NPPF should not hold a presumption in favour development but rather maintaining other governmental objectives such as the Equality Act 2010 and the Climate Change Act 2008 including the 2050 net zero carbon target and the interim carbon budgets
OBSERVATION 5
Within a framework of Ecological Justice is an understanding that all systems are spatialised, materialised and embodied within us and our environments. An NPPF that takes that into account would explicitly name and address how, as a piece of policy, it is a key determinant of health and spatial inequality, as well as seek to use the built environment as a pathway to ensuring greater health and justice.
We reviewed the Tracked Changes to the Document and made comments of these on a downloadable pdf here, as well as answered the live consultation questions which can be read below.
Responses to online consultation
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Response:
Accelerating the approval for housing applications under this amendment and ensuring steady pipeline of housing under the 5 year housing land supply bypasses the real context and conditions of housing shortages in the UK and seeks to address only the symptom and not the cause. Since it is now effectively mandatory for LPAs to maintain steady supply, funding will be geared towards new builds which are land, material and carbon intensive rather than use funding to address the complex empty homes issue. Whilst we agree that housing is a key area of concern, the methods to achieve this are incredibly short-sighted and place pressure in the wrong places. Using the word sustainable to describe development is also contradictory when the sustainable option to retrofit and redistribute is available and not taken.
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Response:
No. This is a dangerous precedent to set in place when there are existing issues arising from the development of brownfield land. In Southall, west London, a former gasworks site is being redeveloped into a large-scale residential mixed-use development site, and the issue of contaminated land has led to health injustices in the local area. Without more adequate policy, compliance, and environmental regulation this addition has the potential to put further communities in harm's way. As many brownfield sites are likely closer to multi-ethnic working class communities this policy guidance can in fact be racist where it will disproportionately put harm in the way of lower income non-whites over wealthier white majority communities.
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Response:
In principle, yes. In practice, the examples given in the golden rules such as biodiversity net gain are not always secured onsite, they are sometimes delivered off-site or even through offsets. Developing these golden rules around securing benefits for nature and public access arbitrarily do not hold up on the ground and it is misleading to develop this approach without robust criteria and guidance for on-site delivery. It would be more convincing to work on actioning the securement of benefits for nature and public access to green space before the need to release Green Belt land.
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Response:
Yes, ensuring mixed tenure means going beyond affordability to include social rent units.
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Response:
Yes. By not considering the existing demographics of an area, plans can cause cultural displacement and alienation when housing typologies and tenures are introduced when they don’t reflect existing cultural needs - such as young families with newborns needing accommodation close to existing family and social networks. A mix of tenures and types, that also include diverse versions of coliving (that would support single parent families) would support lower-income families and people accessing newer (often healthier) homes.
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Response:
No. Using a term such as ‘modern economy’ has the potential to gentrify through policy. The term “modern economy” is opaque and is represented through the zeitgeist of its time. In the government’s eyes this looks like “laboratories, gigafactories, data centres, digital infrastructure, freight and logistics”. These are overwhelmingly large infrastructural requirements for an economy however the only “modern” element of them is their proximity to technology. One can argue that a modern economy through an ecological, or Doughnut Economics, lens might be circular, or hyper-local where we’d see the introduction of shared spaces such as makerspaces or spaces such as Library of Things.
If the NPPF proposed to uphold community life and not just a vehicle for increasing GDP through housing development then it would make direct reference to the types of business/infrastructures suitable to a carbon-friendly, regenerative economy. A modern economy that reflects the health and ecological challenges of our times would encourage a more nuanced articulation of “modern economy” than what is proposed. -
Response:
Social enterprises and the non-profit community organisations that support local communities to develop resiliency and build community wealth. These are organisations focused within areas such as retrofit and the circular economy.
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Response:
National planning policy is to be understood as a determinant of health. The allocation of facilities, buildings, services and goods indisputably influences people's health. We see this through the lens of people’s exposure to novel stressors in the environment (air, noise, light, and heat pollution) and from society (financial insecurity, marginalisation, etc - often known as psychosocial factors). As such, national planning policy can better support local authorities in promoting health communities by actively targeting the representation of these factors within geographic regions. The targeting involves data-led baselining and determining whether any new proposed planning applications lead to an increase or decrease in these stressors. A key methodology that can be deployed would be the requirement for local planning authorities to arrange for a community-led, and designed, Health Impact Assessment which if following the WHO’s four interlinked values of democracy (promoting stakeholder participation), equity (considering the impact on the whole population), sustainable development and the ethical use of evidence. This would ensure that plans reflect the lived experiences of communities and follow stringent guidelines to ensure plans have meaningful impact.
With regards to the topic of childhood obesity, there is a requirement to acknowledge wider scientific research that obesity is a complex dysregulation of the endocrine and metabolic system that has multiple pathways and not just a matter of a relationship between diet and exercise. For example, Krajmalnik-Brown et al (2012) have talked about how acute stress impacts nutrient absorption and energy regulation in the gut, meaning that the consumption of food on a highly stressed body does not automatically mean the body acts in the way as intended, resulting in food-related interventions not having desired weight related goals. In addition, it is increasingly known that childhood obesity is an epigenetic (heritable traits) issue, whereby the parents' life experiences can be passed down to children through their coded gene function. This means that the parent’s life experience is a determinant of whether a child is more susceptible to developing obesity as a disease. Therefore, if there is a genuine aim to reduce childhood obesity there needs to be an addressing of the environmental and socio-economic conditions in which people live, work, and play, and how these experiences can be traumas on metabolic and endocrine regulatory systems. The treatment of obesity is a wider sociological framing of society. This can start with the built environment by: regulating the industries and entities that look to emit pollutants into the environment; protecting and encouraging the restoration of microbially diverse environments that support health gut biomes; ensuring the conditions under which social benefits (jobs, services, etc.) that arise from agendas are designed with health science. -
Response:
The term community can mean many different things to different people. There are communities of people defined colloquially by geographic boundaries. However, there are also communities of people defined by their characteristics, such as gender identity, political perspectives, and collective organising over specific geographic matters (e.g. protection of local green space). Our research has shown that in order to reduce health inequalities and inequities there should be more accuracy to the use of this term as to create exclusions of people who have legitimate concerns relating to planning decisions, and upon whom decisions are made in relation with other central and local government strategic policy.
We propose a defining by adding a prefix of:
Local: meaning a group of people within a specific geographical area;
Organised: meaning a group of people within a relative geographical area representing collective interests for the betterment of the geographical area;
Identity Oriented: meaning a group, or groups, of people who have defined, and protected, characteristics such as gender identities, racial(ised) identities, and class identities.
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Response:
Yes, but the new wording is also problematic. The proposed deletion of this phrase, in particular, “support community-led initiatives” and replaced with (164.b.) “Local planning authorities should support planning applications for all forms of renewable and low carbon development. When determining planning applications for renewable and low carbon these developments, local planning authorities should: recognise that even small-scale and community-led projects provide a valuable contribution to significant cutting greenhouse gas emissions” is problematic in its use of language. Originally it can be read that the emphasis was on the local planning authority to support initiatives, which can come in the form of preference or even incentives (e.g. financial, time, resource). However, by replacing and adding the term “when determining planning applications” it puts the emphasis on the support being a subjective appraisal of what’s being presented rather than the emphasis on support coming from structural means within a local government or planning authority. By removing the policy guidance for structural support it can weaken the capacity for community-led activity. Equally, by removing a support system and not making reference to where it is being replaced is damaging to an ecosystem of community-led methods of meeting the challenge of climate change.
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Response:
National planning policy can do more to address climate change mitigation and adaptation by taking into account the needs of vulnerable people at the centre of decision making in the built environment. The legal challenge against the government on the National Adaptation Plan by Friends of the Earth was made because of the insufficient vision and action to protect against climate change, this does translate into specific, deliverable actions - e.g. the role of national planning policy in supporting planning applications for retrofit for overheating, and creating mandatory targets for retrofitting existing properties within and beyond council stock. This includes social and public infrastructure as well as housing.
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Response:
Climate change plans (especially adaptation plans and resilience measures) and local plans must include frameworks on how the built environment and changing environment impact health, ideally through community led impact assessments. This will make action on climate change urgent and immediate and will necessarily bring in understandings of health as ecological.
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Response:
With reference to the planned edit of footnote 63, there is a risk that not actively protecting the use of agricultural land for food production can harm the United Kingdom’s capacity for food resilience in times where climate change is impact crop yields and issues such as global supply chain breakdown (COVID-19 pandemic / Russia-Ukraine war) can cause inflationary activity in pricing, resulting in higher costs for businesses and people and some going without vital nutrients - an obvious impact to people's health and wellbeing.
If you would like to engage with us on any of the matters raised here please contact Josh via email on josh @ thecentriclab.com
What would an NPPF look like from an Ecological Justice framing?
Taking on an Ecological Justice approach to the NPPF requires a foundational shift to the role and motivations around planning and the relationship with land in the UK.
Currently, at its core, the NPPF holds a presumption in favour of sustainable development, which means that the driver behind planning in the UK is the new development of land, maximising and extracting value.
What is understood to be a ‘need’, how needs are met, and how policy is to be spatialised is contextualised within this motivation. The supply of homes, an overwhelming focus of the NPPF, are referred to in the context of choice and competitiveness in the market for land, not on the distribution of pre-existing infrastructure that is sufficient to meet demand (there are up to 1 million empty homes in the UK). Here, land serves a narrow purpose and is related to through its quality and potential of ‘performance’ in the market, regardless of real need.
The ambitions of national policy are restricted by ‘subjects to viability’, which means the delivery of affordable homes, social rent homes, net zero, biodiversity, climate change adaptation etc can be foregone if profitability is impacted as a result.
The NPPF’s vague and undefined use of terminology around strategy means that attempts to address the injustices around housing need; the unjust spatialised nature of service provision; the inaccessibility of our built environments, as well as broader issues relating to environmental degradation and climate change can all be loosely interpreted and misused to ensure continued profit driven extraction of land.
An Ecological Justice framing challenges these two basic premises - that a presumption in favour of development should even exist, as well as an invitation to relate to land as kin rather than as an asset and market to be exploited and developed.
Ecological Justice is the recognition that health and justice are tightly intertwined with the environments we live in and land we live on.
The spatialisation of injustice demands that we take policy and decision making tools such as the NPPF seriously in their roles in enabling and building harmful and extractive systems.
At its core, our definition of Ecological Justice is rooted in Kinship, relationality and mutuality, starting with land as kin not as a lifeless resource to be exploited.
The epistemology behind this approach requires a change in the role of land in planning, land cannot be referred to simply by its competitiveness on the market, or its performance and use, rather its being and the conditions that enable meaningful relationships with it. From this, the NPPF would necessarily shift away from new development and continued economic systems of extraction, in which decision making is determined by profit, and instead seek to address existing imbalances and inadequate distribution within the existing built environment without the need to build new. In doing so, the understanding of net-zero, biodiversity, climate change mitigation and adaptation as well as housing shortages would shift to reflect reality rather than a market based worldview of need, demand and delivery within land use planning in the UK.
Within Ecological Justice-as-a-framework is an understanding that all systems are spatialised, materialised and embodied within us and our environments. An NPPF that takes that into account would explicitly name how as a piece of policy it is a key determinant of health and spatial inequality, as well as seek to use the built environment as a pathway to ensuring greater health and justice.
This looks like policy that is explicit about the context that it is working in, upholding or challenging, that names the true drivers, challenges and needs within the context, and that works more coherently to reflect the relationships that are manifest within our built environment.
These relationships are broad and expansive, however some examples are our relationship to food production and access, movement, home, education and health etc.
This approach is a process rather than an outcome and can be practised through engaging critically with the language and definitions that we use and the political and economic contexts that decisions are made in.
For example, contextualising housing needs and using this piece of policy to focus on retrofitting and renovating vacant housing stock rather than building new homes, and budgeting for the processes of redistribution of services, infrastructure and homes. It can also be practised in decision making processes that centre lived experience expertise that is deeply rooted and connected to place over time.
Shifting the approach and relationship to land, knowledge and the expertise base of these planning decisions ensures a greater coherence of people and place, seeding ecological justice.