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One function of the NPPF should be to bring planning policy up to speed on practices that have become widely adopted within the industry where those practices that are clearly consistent with broader policy goals. It is therefore strange that cultural activity, now broadly regarded as a key strand of delivering sustainable places, has been altogether excluded from the draft. Ixia, a think tank that looks at the role of culture within the built environment, has called for an urgent debate into the absence of cultural activity, and its role in delivering sustainable development, from the current draft.
As Ixia point out, a key difficulty is inconsistency with other organs of the state for whom culture continues to be a key means of delivering thriving places, for example Arts Council England (ACE), Design Council CABE and the Homes and Communities Agency. Also, ‘cultural infrastructure’ is already recognised within the list of types available for funding through the Community Infrastructure Levy. Given the prominence awarded to culture within other areas of policy there is a danger its absence from the NPPF will create confusion at a local level, particularly in relation to how CIL money may be used. Critically, the value of cultural activity is also consistent with the mood music of the NPPF, which acknowledges the planning system should ensure development produces ‘vibrant’ places and promotes community ‘well-being.’ The document seems to shy away from its own convictions; in doing so it will undermine those seeking to develop programmes designed to achieve the very objectives it espouses.
In response to Ixia’s call ACE this week has produced a comprehensive response to the NPPF; in it they identify specific areas where culture should be mentioned if the framework is to reflect the pivotal role culture plays in underpinning economic prosperity and fostering community cohesion.

Definitional issues are critical here. Currently drafted, the NFFP presumes ‘leisure’ and ‘heritage’ are synonyms for culture. ACE asserts specific and separate reference needs to be made to ‘culture’ so as to distinguish it from, for example, ‘sports’. At Plan Projects we would welcome a broad definition which encompasses all areas of activity that allow for creative expression and strengthen civic life, be it horticulture, the arts and, indeed, sporting activity. Critical for us is that the LPAs should be permitted, within their Local Plans, to adopt a definition that suits the needs, values and traditions of their communities and, once identified, this definition should lead to the development of a cultural strategy within their Local Plan, the absence of which would result in the plan being found unsound.
The NPPF hints at a definition of culture we would support. Firstly, there exist openings within the document that will allow communities and LPAs to weave into their Local and Neighbourhood Plans cultural provision that reflects their own, local, understanding of culture. This offers an authentic means of introducing culture into the development process. For example, achieving ‘vibrancy’ requires ‘accessible local services.’ LPAs should ensure culture lies at the heart of service provision. The document goes on to state ‘planning policies and decisions should address the connections between people and places’. This again leaves the door open for LPAs to develop their own approaches to how these ‘connections’ may be cultivated, but one obvious route would be cultural programming.

Secondly, Neighbourhood Plans will give local communities the authority to influence development in their area. The closer the planning system comes to the people it effects, the more ‘cultural’ it becomes. This creates a route by which the planning system can be used to deliver cultural activity at a local level. If a neighbourhood forum decides to animate their high street with commissioned public art, or to make changes to the streetscape such that it will foster cultural activity, this will not be inconsistent with the NPPF.

Finally, the NPPF recognises the need for planning to deliver development that will ‘function well and add to the overall quality of the area…over the lifetime of the development.’ This places the onus not just on good design, but also on the requirements for the built environment to be effectively managed and maintained. Allowing for long term stewardship on the part of the LPA is consistent with cultural planning that seeks to involve the community in the running and management of the places where they live and work.

However, despite the areas of tacit support for culture, the absence of any specific reference, bar as a by-product of heritage, is a glaring and serious omission. The glossary should provide a definition and it should appear wherever well-being, community services and economic resilience are discussed.
Ivan Tennant, Principal, Plan Projects

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