Manchester Friends of the Earth response to the National Planning Policy Framework consultation.
Back in December 2022, the Department for Levelling Up, Housing & Communities announced a consultation on the Government’s “proposed approach to updating to the National Planning Policy Framework.”
The consultation also asked for views on the proposed approach to preparing National Development Management Policies. (Chapter 10).

The National Planning Policy Framework (NPPF) and other planning policies often seem a million miles away from people’s everyday lives – but the NPPF has a major impact on a wide range of everyday local issues including: housing, economic development, local building standards transport, greenbelt & natural environment and whether fracking for shale gas or new coal mines can be permitted locally.
The NPPF also sets the framework for how our local plans – such as the Greater Manchester Places for Everyone plan – are assessed during the Examination in Public to assess whether the Plan is “justified” and “sound”. (Examining Plans)
Nationally, Friends of the Earth have raised serious concerns about changes to the NPPF. Back in September 2011, FoE submitted evidence to the House of Commons Communities and Local Government Select Committee highlighting a range of concerns including:
- It is recognised however that the current planning system is difficult for communities to engage with, and policy could be made more accessible, and
- Friends of the Earth is concerned that the NPPF fails to recognise environmental limits, and therefore encapsulates a fundamental misinterpretation of what it means for development to be sustainable.
In December 2018, Friends of the Earth challenged the government over its failure to conduct a European strategic environmental assessment (SEA) while preparing the revised NPPF, which was published in July 2018.
The 2012, the NPPF had introduced the presumption in favour of sustainable development which means that such development should be approved by local councils without delay. However, one big problem with this is how the Government and developers have choosen to define ‘sustainable’.
The 2018 NPPF revisions saw the removal of the United Nations definition of sustainable development from the Framework – with the Campaign to Protect Rural England labeling the revised NPPF as a ‘speculative developers’ charter’.

See Planning for the future – Friends of the Earth response to the White Paper for background information.
In April 2021, Friends of the Earth was part of a coalition of environmental and social charities and NGOs that sent an unprecedented joint-response to the government’s consultation on changes to the National Planning Policy Framework (NPPF) demanding much greater action from government on planning for climate change. The joint-response highlighted that the proposed changes to the NPPF failed to address the seriousness of the climate emergency which the government claims is a priority.
The most recent NPPF consultation saw media reports signalling that the Government was going to remove the current ban blocking the development of onshore wind energy.
However, in February this year, Friends of the Earth joined a coalition of organisations, business leaders and individuals who raised concerns with Michael Gove (Secretary of State for Levelling Up, Housing and Communities) and Grant Shapps (Secretary of State for Energy Security and Net Zero) that the “proposed changes to the National Planning Policy Framework are entirely inadequate to bring about the required change in policy“.
The decision to replace the Footnote that refer to onshore wind energy with some marginally revised wording, in the form of new Footnotes 62 and 63, looks to be almost identical in effect, and inevitably means the effective ban will remain in place. (Letter)
Why respond to (yet) another Consultation?
We are not planners or lawyers and despite the at times baffling and arcane planning language – Manchester Friends of the Earth felt it was important to respond to the consultation as planning legislation and regulation sets the ground rules for decisions about what does (or does not) happen in Greater Manchester and in communities across the country. Our response is available below. (With big thanks to Magnus).

See the Planning and environmental law web pages to find out more about Friends of the Earth work on planning issues.