Making sense of the NPPF Prospectus for public health in England Summary Briefing, January 2023
Introduction
The 2020 Planning White Paper proposed significant reform to the planning system in
England (the Health and Wellbeing in Planning Network delivered a webinar on this in
September 2020). Long story cut short and through various political and policy evolutions,
the White Paper turned into the Levelling Up and Regeneration Bill bringing forward
legislative changes to reform the planning system. As a result, the Department for Levelling
Up, Housing and Communities (DLUHC) published a consultation Prospectus – Levelling-up
and Regeneration Bill: reforms to national planning policy – in December to set out its
proposed approach to changes to national planning policy, other local planning processes
and on specific policy topics. The deadline for responses is 2nd March 2023.
This briefing is not strictly a summary of the Prospectus. As there are many important
signposted documents in the Prospectus, you should read them in conjunction with this
briefing as there may be elements that may be particularly relevant to you individually but not
covered in this briefing or where you can get further details. This briefing aims to:
• make sense of relevant proposals in the Prospectus as they relate to public health
involvement in planning
• highlight how these proposals may impact on local ability to address identified public
health needs or priorities through planning
• help you inform your own understanding and response to the Prospectus.
Please note there may also be issues which may be missing or require further consideration
by DLUHC and others, and are not identified in this briefing, but can be included in your
respective responses to the consultation. There is also need to be aware how recent
changes (new NHS bodies and duties) brought about by the Health and Care Act 2022 are
relevant to the planning, and this was subject to a 2022 blog published by the Health and
Wellbeing in Planning Network.
This briefing is by no means an attempt to suggest ‘adding’ new things for the planning
system and planners to deal with, which may be perceived as burdens. But because many
land use activities will impact on people’s health and wellbeing, it is important that the
planning system, its operators and users acknowledge, understand and takes proactive and
preventative step to support, not undermine, people’s ability and desire to look after their
health and wellbeing. Local public health teams may wish to engage with their planning
department to set out issues that align with identified local health and wellbeing needs and
priorities set out in local health strategy. National health organisations may also wish to
respond to set out strategic issues that impact on the ability of the public health, healthcare
and social care systems to improve population health and help reduce inequalities.
Finally, to ensure responses from public health are clearly articulated based on identified
public health needs assessment and agreed priorities in any health and wellbeing strategies,
it may be useful to frame them through the following health lens – will the proposals, in any
way, collectively, individually or cumulatively:
– enhance or reduce the ability of public health professionals to have their say
through the different windows of opportunity offered by the planning system?
– support or undermine their ability to bring forward local approaches to address
identified health and wellbeing needs and priorities?
– result in better or worse consideration of any population physical and mental
health and wellbeing outcomes?
– result in disadvantaging certain population groups/ geographical areas over
others, thereby exacerbating existing disparities?
– is the Prospectus silent on any key issue of direct interest to public health?
Summary
The Prospectus signposts to a wider scope of related planning reform which means a need
to be aware of them, know what they mean for public health and how/ when to respond to
them. It is a challenge for those working in planning full time to keep on top of all the system
changes and implications so it will be more challenging for public health professionals who
will have other responsibilities and portfolios.
• The Bill: The Levelling Up and Regeneration Bill is essentially a Planning Bill and
most of the forthcoming reforms will relate to provisions in the Bill as indicated in this
Briefing. If you can find summary briefings of the Bill or attend discussion events, I
would encourage you to do so. Most organisations involved in housing, planning and
development will already be providing useful information so look beyond public health
bodies. Otherwise there is no substitute for actually reading the Bill or at least the
Bill’s background Explanatory Notes or DLUHC Policy Paper.
• All roads lead to a new NPPF: As the Prospectus indicates, there will be further
information and consultation on a revised NPPF as well as the new National
Development Management Policies. But your engagement with national policy
consultation should be proportionate to involvement in local plan making processes.
• Your place, your local plan: The local plan and local planning will undergo
significant reform not just in terms of process but its drivers. Much of these drivers
and processes are highly technical. The overarching message for public health is to
continue to support the timely preparation of local plans, given the pressures to adopt
local plans, as well as promoting specific policies important to public health.
• Adapting new lens: Wellbeing and addressing health inequalities can be viewed and
implemented through various different lens in the planning system. The Prospectus
suggests a number of these windows of opportunity including but not limited to urban
design, housing need, nature recovery and climate change. This also means there is
a need to broaden your knowledge of other information outside the public health
systems such as the Environment Act and Net Zero Strategy.
• Getting the Public Health house in order: Key insurance policy for getting a public
health foot in the door will be to ensure local public health and other health strategies
reflect priorities and implementation through the planning system. This is particularly
timely as local systems update their needs assessments and strategies in light of the
new ICB/ ICS. Doing this helps to clarify and signify to other users of the planning
system where planning can be a useful and essential delivery tool for local public
health priorities. And will be a particularly useful exercise in knowing your priorities
and how/ where best to respond to these consultations in the future.
• Taking a health impact assessment approach: The Prospectus introduces a
complex range and depth of issues but not all may have direct health implications or
may not be immediately obvious an area of interest for health. There may be a case
for a HIA approach to support your understanding locally to systematically understand
the issues, identify where there are significant gaps, make the necessary
recommendations and actions not only in making a response to the consultation but
also in informing improvements to your current involvement in planning.
Signposting to other expert briefings
Because the Prospectus addresses many of the fundamental questions posed about the
purpose, functionality and mechanics of the planning system, including those proposed in the
Levelling Up and Regeneration Bill, it can be quite overwhelming and complex to cover
everything. Other planning experts have provided useful commentary and deep dives, and I
would signpost you to their contributions if you are interested in the wider planning debate
(e.g. Royal Town Planning Institute, Lichfields, Barton Wilmore now Stantec, Irwin Mitchell
and Iceni Projects). There are also other organisations e.g. the Town and Country Planning
Association, Local Government Association and The Quality of Life Foundation who may be
publishing relevant commentaries/ briefings to the health and wellbeing agenda.
Overview of specific proposals relevant to health
I have identified fifteen proposals/ issues in the Prospectus which are worth highlighting in
relation to general observations on what they mean for health. It should be noted that the
Prospectus contains a mixture of:
• proposals relating to those in the Levelling Up and Regeneration Bill so you should
read the Bill’s policy paper alongside the Prospectus and this briefing.
• proposals to make immediate changes to the NPPF to reflect new priorities of the
Government, and a tracked changes NPPF version was published and should be
read alongside the Prospectus.
• other proposals and ideas for potential future changes.
1. Speeding up local plan preparation (chapter 9)
Local plans set out policies and requirements for determining planning applications but take
a few years from start to adoption. Most local plans are not up to date, and many are in the
process of review. In reforming local plan making process (see the Bill policy paper for
details), the Government wants to place stronger weight on local plans, provide more
certainty to the decision-making process on developments, and make it quicker and simpler
to create up to date local plans by removing some of the current hurdles and put in place
stricter timescales. It is expected these reforms to be implemented from late 2024. So, from
late 2024, plan makers will be required to begin preparing new style local plans.
What this means for health: While many of the complexities to local plan preparation are
outside the scope of public health concern, they nevertheless frame public health
involvement in the plan-making process. Having strong and explicit policies supporting
actions on health improvement and reducing health inequalities will continue to be an
important foundation for planning for health. So public health involvement in engaging plan
makers in bringing forward health-related policies needs to be aware of these changes and
timescales, and ensure this involvement continues to be informed by relevant and sufficient
public health evidence approach based on local health needs and priorities.
2. Changes to supplementary planning documents (chapter 9)
Supplementary planning documents (SPD) build upon and provide more detailed advice or
guidance on policies in an adopted local plan. Councils will no longer be able to prepare
SPDs but new Supplementary Plans from late 2024. Existing SPDs will cease to have effect
when councils adopt the new-style plan.
What this means for health: The majority of local planning for health guidance are currently
set out in SPDs for example on the use health impact assessments and hot food takeaways.
They will cease to have effect if councils do not update them as new supplementary plans.
Supplementary plans require more resourcing because under the Bill they undergo a more
stringent requirement in the preparation process than SPDs. But when created as a
supplementary plan, it means they will have greater weight in decision-making.
3. New national development management policies (chapter 10)
The Bill introduces a new set of national planning policy called National Development
Management Policies, an idea introduced in the 2020 Planning White Paper. Development
management refers to the process of making decisions on individual planning applications.
The Prospectus sets out the case for National Development Management Policies and initial
thinking on their scope and content, including:
• Statutory weight as a set of policies, and separate document to the rest of the NPPF.
The latter would be re-focused on principles for plan-making
• support slimmer plans by removing need for generic issues of national importance
• full public consultation would take place on the draft policies
• provide indicative examples of ‘gaps’ where national policy is silent on common
decision-making issues.
What this means for health: The new National Development Management Policies can help
to provide certainty for identifying national public health priorities that local planning can help
address. Currently for some priorities each council are having to make the case individually
for certain policy approaches but often with mixed results through the examination and
decision-making processes although the evidence base/ case for action may be similar.
Having national development management policies relevant to health can also allow councils
to better focus on creating more bespoke local policy and guidance approaches.
4. Wider changes to national planning policy in the future (chapter 12)
There may be changes to national planning policy are likely to be needed to reflect the Bill
and other aspects of government policy. The Prospectus suggests a list of possible changes
but DLUHC are not consulting on them at this stage. The government will undertake a full
consultation on a revised National Planning Policy Framework and proposals for National
Development Management Policies.
What this means for health: The Prospectus suggests that there will be a consultation on a
full revision of the NPPF and the new National Development Management Policies. The
timescales are dependent on the Bill process but public health teams should begin to think
about how and what part of the current NPPF can be maintained, improved upon/
strengthened to ensure all aspects of the wider determinants of health, and health
inequalities can be integrated into national planning policies. The Prospectus isn’t clear about
the status for updating the Planning Practice Guidance in which there is currently a whole set
of guidance on planning and healthy places, namely food environments and the use of health
impact assessments.
5. Planning for housing (chapter 4)
Making small additions to NPPF paragraphs to ensure new housing and developments are
done in a sustainable way, and maintain the uplift to in calculating housing need in urban
areas to make the best use of brownfield land.
What this means for health: The location of new housing and developments will become
more of a consideration when setting housing targets/ locations and having them in
‘sustainable’ locations can benefit health in terms of proximity to social networks, active
travel opportunities etc. There is a need to assess whether prioritising all development in
urban areas can be the most sustainable and best way for promoting health outcomes.
6. Small sites and brownfield-first policy (chapter 5 and chapter 11)
In support of levelling up, to target the majority of delivery on brownfield sites outside London
and the south east, and make sure that national planning policies are supportive of gentle
densification of urban centres, and how to boost development on small sites.
What this means for health: There is a need to consider whether small sites, if not supported
by other policies on minimum space standards, access to amenity spaces or protection from
environmental risk factors, can have other adverse effect on other health outcomes in terms
of mental wellbeing and quality of life.
7. More social rent homes (chapter 5)
Making changes to the NPPF to make clear that local planning authorities should give
greater importance in planning for Social Rent homes, when addressing their overall housing
requirements in their development plan and making planning decisions.
What this means for health: Prioritising delivery of affordable housing, including those for the
Social Rent tenure can be positive as affordability and security of housing is a determinant of
people’s mental and physical health. There is a need to ensure that the delivery of this,
tenure, other affordable housing tenures and all housing is high quality, healthy, sustainable
and meet people’s quality of life needs.
8. More housing for older people (chapter 5)
Adding specific expectation to the NPPF that particular regard is given to retirement housing,
housing-with-care and care homes, which are important typologies of housing that can help
support our ageing population. DLUHC is also launching a taskforce on older people’s
housing, which was announced in the Levelling Up White Paper.
What this means for health: The ageing population is a significant public health issue which
will have implications in the way places are planned, services are commissioned and type of
housing provided. Research has shown the planning system has consistently failed to plan
for and build sufficient and appropriate housing for older people.
9. Asking for beauty and refuse ugliness (chapter 6)
Make changes to the NPPF to emphasise the role of beauty and placemaking in strategic
policies to encourage beautiful development and make a stronger link between good design
and beauty. The NPPF was updated in 2021 to introduce requirements on design codes.
Other proposed changes, i.e. in secondary legislation to require permitted development
schemes to take into account design codes.
What this means for health: The issue of health in ‘beauty’ was raised previously by Public
Health England in its response to the Building Better Building Beautiful Commission’s report
which goes beyond visual aesthetics. There is a need to consider whether determinants of
health can be included in the definition of beauty and placemaking in the NPPF. Taking into
account of health outcomes in developing local design codes (See forthcoming OHID
publication) can be a good foundation for creating healthier places and communities.
10.Biodiversity net gain and local nature recovery (chapter 7)
The government is seeking views on how they can strengthen policy and associated national
design guidance to promote small-scale changes that can enhance biodiversity and support
wildlife recovery. They are related to concurrent changes introduced on biodiversity net gain,
local nature recovery strategies, local design codes and the National Model Design Code.
What this means for health: a recent review by the government’s environmental regulator –
Office for Environmental Protection found Government’s progress on delivery of its 25 year
plan to improve the environment has ‘fallen far short’, and this may have implications for
population and human health, as well as for the natural environment.
11. Recognise importance of food production (chapter 7)
The government’s food strategy highlights that the UK maintains a high degree of food
security and is seeking views on increasing the consideration given to the highest value
farmland used for food production in the Framework for both plans and decision making.
What this means for health: Access to food has wider implications for public health including
healthy food availability and affordability so securing the land is an important planning issue.
Food growing at neighbourhood to wider local authority wide scales, together with initiatives
to manage healthier food consumption, can be an important part of a whole system approach
to supporting and building a healthier local food environment.
12. Further support climate change mitigation & adaptation (chapter 7)
Stakeholders have suggested that planning policy should address other climate risks
identified in the third Climate Change Risk Assessment, such as overheating and water
scarcity, and that it should help put more focus on nature-based solutions and multifunctional benefits.
What this means for health: Policy and guidance have been continuously strengthened for
adaptation and flood risk management but further improvements/ additions may be needed
on considering other health risk factors as a result of a wider scope of climate change
impacts and vulnerabilities of certain population groups or geographies to these impacts.
13. Other policies to deliver Levelling Up missions (chapter 11)
The government is seeking additional views on what changes to national planning policy
might be made to reflect the Levelling Up White Paper published in February this year and
the levelling up missions.
What this means for health: The levelling up missions suggest taking a health in all policies
approach to improving on the social, economic, environmental and health-related conditions
across communities in England. Various health organisations have published reports with
recommendations for levelling up health which may be useful references including the NHS
Confederation and the Health Foundation. National and local planning should be seen in this
HiAP approach which also means a need for the public health sector to be clear about the
role of planning in delivering identified health priorities.
14. Safety and security for women and girls (chapter 11)
In delivering levelling up missions on health, wellbeing, and pride in place, DLUHC wants to
understand if national planning policy should do more to enable local authorities to consider
the safety of women and girls, and other vulnerable groups, when setting planning policies or
making decisions.
What this means for health: Ensuring the planning and design of public spaces make women
and girls, and everyone feel safe is an important determinant of health, in particular mental
health and wider social cohesion considerations. Research has found increasing awareness
that spaces are dominated by men and built for the ‘default male’ citizen. There are
opportunities to take a healthy streets approach to such issues and review whether Secured
by Design guidelines can better support wider wellbeing, safety and security considerations.
15. Impact on Public sector equality duty (chapter 13)
The consultation ends with a question on what asking for view on whether there would be
any potential impacts that might arise under the Public Sector Equality Duty. The
consultation did not come with a published impact assessment.
What this means for health: The Prospectus sets out a wide range of proposals which
individually, collectively or cumulatively can have implications for public health involvement in
planning and what this means for impact on actions to reduce health inequalities. There may
be a wider discussion whether an assessment under Public Sector Equality Duty can
adequately cover wider public health and health inequalities considerations, and whether
taking a concurrent health impact assessment approach.
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Author: Michael Chang FRTPI, HonMFPH