The unfortunate minister sponsoring the draft NPPF is the well-liked Greg Clark, whom we have known as an intelligent and sincere friend to countryside, thoroughly aware of all environmental issues.  Prior to his present troubles, he had actually won the support of the green-minded by his initial opposition to, and subsequent abolition of, the existing definition of Previously Developed Land (aka Brown Field Sites) as including back gardens.  It is genuinely sad that he has put his high reputation at risk by promoting, and inevitably continuing to defend, the new and appalling draft NPPF.

Why is it appalling?  For all the reasons that the National Trust, CPRE, Civic Trust, RTPI and other caring and authoritative bodies have said that it is.  Not very much new appears in the analysis below.

1. First and foremost, although the document purports to be a document about Planning, it has not been written from a Planning standpoint, but from a particular narrow (building) standpoint, and it manifestly owes its nature to dominant influence by that type of business-person who says, 'We can't build as and where we want to, because of burdensome Planning restrictions – apparently oblivious to the fact that there are overwhelmingly strong reasons for not letting everybody build as and where they may wish to.

2. 'The purpose of the planning system is to contribute to the achievement of sustainable development', wrongly asserts the NPPF.  And, in a later paragraph, 'Development means growth'.  Alas, it fails to explain what it means by 'growth'.  Most economists will understand the word as referring to National Income (GNP) growth, much of which comes about with little or no building development.  Most environmentalists, and indeed academic economists, conscious of the many types of growth (tobacco industry, carbon-emitting growth, soaring consumption...) are by no means enthusiastic about simple GNP growth as the most desirable of aims.  Planning must of course include planning for appropriate growth, creating employment and income, provided that it is of environmentally acceptable nature and location.  But, no less obviously, growth is only one of the quite numerous and sometimes conflicting aims of Planning, and for the NPPF to assert otherwise is indefensible.

3. More culpably – and this is what has infuriated so many of the critics – supporters of the draft NPPF have tended publicly but mistakenly to equate 'growth' with 'growth in the number of houses', possibly in order to win sympathy with the NPPF's anti-Planning arguments.

4. The next serious misrepresentation is the sustained implication that the recent low housebuilding figures have been due to restrictions on land availability - greenfield land in particular.  This is simply an untruth: there is ample building land available, although most of it generates a developer less profit than a greenfield site in desirable countryside; it includes very many genuine brownfield sites which the previous administration rightly insisted, as the NPPF does not, should accommodate most new housing.  The developers are sitting on most of it, waiting for an economic climate when building will be more profitable.  Meanwhile the number of unoccupied dwellings is very high, and successive administrations have done very little to reduce it.  The high homelessness is a genuine problem: it owes something to successive governments' privatisation of former Local Authority housing, but the recent low housebuilding figures are due more to economic circumstances which prevent very many families from obtaining capital sufficient to stimulate effective demand for more houses.

In sum, it is disgraceful that a purportedly Planning document should, at least by strong implication, be blaming housing shortage on a national Planning policy which for over half a century has done so much – in contrast with some other countries – to protect the much-loved countryside from urban or suburban-type sprawl.

5. Central to the NPPF argument is 'the presumption in favour of sustainable development'.  But what exactly does 'sustainable' mean?  The NPPF takes refuge in the definition that 'sustainable means that better lives for ourselves do not mean worse lives for future generations' – which, so far as it goes, can hardly be disputed, but which is of course far too vague for careful Planning decisions to be based on, and the flimsiest of constraints upon developers.

Even if one accepts the vague concept of 'sustainable development', the NPPF comes close to asserting that, if there is no clear Planning policy document to demonstrate inappropriateness of a planning application, it should be deemed sustainable.  'The default answer to a development proposal is "yes" except where a key sustainable development principle is compromised.'   But, given the vagueness of the last nine words, what is the logic supporting this stance?  If sustainability is made definable, a development application should normally be passed when it is sustainable, and refused when it is not.  If Local Planning Authorities fail to get very thorough Planning policies written, they may well be at fault, but that is no reason to punish the countryside, and those that live in it, by permitting an application which is not sustainable.

6. Developers, including housebuilders, do not like lots of restrictions and conditions which limit their freedoms and compel their careful adherence.  Somewhat disingenuously, Mr Clark is now defending the draft NPPF on the grounds that it is primarily a simplifying document, with no cost to countryside or environment.

There may be a case for some simplification and reduction of planning documentation, although as the WKPS Planning Secretary who has to look at, and draft comments on, hundreds of applications per year, I do not find the quite numerous Planning and Policy Statements either confusing or incomprehensible, and I do not really believe that a competent professional will do so, either.

Abridging the Planning rules and guidance as drastically as is being proposed would undoubtedly cause the loss of very important details and even principles.  I offer two examples of the Supplementary Planning Document (SPD) which the NPPF wishes to discourage in order to present less constraint upon the developers.  The first is the invaluable regular Appraisal of a Conservation Area, detail of which it would be impossible to include in a Core Strategy.  The second is any new initiative, brought about not by the economic changes on which the NPPF lays such emphasis, but by advances in knowledge (sometimes science) or by fresh ideas – such as the Local Heritage Assets list, which Tunbridge Wells BC is proposing to draw up in the form of an SPD.  Developers may not like Inspectors to be told that features of a Conservation Area are not to be damaged, or that a non-listed building with interesting local history should not be demolished, but Planning is all about protecting what is precious, as well as fostering economic growth.

To repeat, the draft NPPF is an appalling document.  WKPS will be joining the Great and the Good in opposing it, and we must use such influence as we possess to induce our local politicians to do likewise.