Name: Jane Wilson, Chair, Arts Development UK
Email: jane.wilson@adec.org.uk
, artsdevUK@aol.com
I am responding on behalf of a national charity: Arts Development UK
(AD:uk). This response is in two parts: the first part is a short narrative response to the document, and the second addresses the specific questions set out in the consultation document.
Narrative Response
Arts Development UK is the national professional body for local authority arts officers and increasingly other professionals working in the field of arts and communities.
We welcome the overall aim of the NPPF and especially the stated purpose to achieve sustainable development and the desire to ‘create good quality built environment with accessible local services that reflect the community’s needs and supports its health and wellbeing’.
The recognition of sport, leisure, recreation, and open space and the role they play for sustainable communities is also welcomed, however it throws into sharp relief the silence on arts and culture.
We are very concerned that the NPPF, as it stands, will not be able to deliver on its overall aims due to that silence on arts and culture, given the critical role of arts and culture in economic development, local distinctiveness, regeneration and sustainable development.
Arts Development UK, Oak Villa, Lower Brynamman, Ammanford, Wales SA18 1SN
Tel/Fax: 01269 824728, email artsdevUK@aol.com
www.artsdevelopmentuk.org
Charity Registration: 1121290
Page 1 of 11

The lack of acknowledgement of arts and culture in the NPPF contrasts with statements and policies coming from other government departments. These include ‘Measuring National wellbeing – Measuring
What Matters’ which quotes the evidence of the DCMS Taking Part
Survey of the links between taking part in sport and cultural activities and wellbeing; the CLG Select Committee report on arts and heritage funding, which stated that, ‘It is a mark of a civilized society that its citizens all have access to arts, culture and heritage’; and DCMS statements that the Government is wholly committed to arts and culture. This commitment needs to be secured within national planning policy and in particular we would like to see change in three areas:
 The inclusion of culture as an integral element in Sustainable
Development
 Better definitions of leisure, culture, and community facilities
 The inclusion of arts and culture’s contribution to economic prosperity and health and well being
Yours sincerely,
Jane Wilson
Chair, Arts Development UK
CC Rt Hon Ed Vaizey MP, Secretary of State for Communications,
Culture & the Creative Industries
Arts Development UK, Oak Villa, Lower Brynamman, Ammanford, Wales SA18 1SN
Tel/Fax: 01269 824728, email artsdevUK@aol.com
www.artsdevelopmentuk.org
Charity Registration: 1121290
Page 2 of 11

Name:
Position:
Name of organisation (if applicable):
Address:
Jane Wilson
Chair, Arts Development UK
Arts Development UK
Email Address:
Oak Villa, off Amman Rd, Lower
Brynamman, Ammanford, SA18 1SN jane.wilson@adec.org.uk
, artsdevUK@aol.com
01269 824728 Telephone number:
1a. The Framework has the right approach in establishing and defining the presumption in favour of sustainable development.
We strongly disagree.
1b. Comments.
Para 9:
In our opinion, the general definition of ‘sustainable development’ in the NPPF is right, however the failure to recognize culture as the fourth pillar of sustainable development, alongside the economic, social, and environmental dimensions, leaves the definition as used for the framework severely lacking.
Culture plays a fundamental role in the capacity of both individuals and communities to develop and share a high quality of life, and is critical to both economic and social development, including health and wellbeing. This is visible in the work carried out by the DCMS with the
Department of Communities and Local Government, and with the
Department of Health. We recognize that the NPPF makes reference to
‘quality of life’; however the absence of any explicit mention of culture leaves that reference severely undermined, and weakens links to both
Arts Development UK, Oak Villa, Lower Brynamman, Ammanford, Wales SA18 1SN
Tel/Fax: 01269 824728, email artsdevUK@aol.com
www.artsdevelopmentuk.org
Charity Registration: 1121290
Page 3 of 11

the Localism Bill and the Community Infrastructure Levy.
The addition of clear and unambiguous references to arts and culture in the relevant sections of the NPPF would provide both clarity and a better fit with the general definition of sustainable development put forward in paragraph 9.
Para 15:
The absence of culture from the overall definition as set out in the
NPPF will, following para 15, lead to the absence of arts and culture from local and neighbourhood plans, and/or the risk of challenge to those local and neighbourhood plans that do choose to make explicit reference to culture. This will significantly undermine the efforts of areas working to regenerate through culture, and of areas recognizing that a vibrant cultural offer is essential to maintaining global competitiveness in the knowledge economy. The DCMS has significant evidence of the role of culture in both these endeavours.
Para 19:
This is a clear example of the difficulties that could ensue if the arts and culture are not included within the NPPF.
Para 19, point 2:
If there is no clear recognition of the arts and culture within the NPPF provision is then directly threatened by the presumption that
‘Decision-takers at every level should assume that the default answer to development proposals is ‘yes’, except where this would compromise the key sustainable development principles set out in this
Framework‘. It is not sufficient to argue that arts and culture are covered by the general principles and aspirations to quality of life, as other areas such as built heritage and sport are directly referenced, and the silence on arts and culture can therefore be read as a deliberate omission. Again this will have a significant negative impact on local areas seeking to use culture both for regeneration and as a source of distinctiveness.
Para 19, point 6:
Arts Development UK, Oak Villa, Lower Brynamman, Ammanford, Wales SA18 1SN
Tel/Fax: 01269 824728, email artsdevUK@aol.com
www.artsdevelopmentuk.org
Charity Registration: 1121290
Page 4 of 11

Again, the silence in relation to arts and culture will lead to a lack of clarity on the role they play in achieving ‘vibrant places’.
2a. The Framework has clarified the tests of soundness and introduced a useful additional test to ensure local plans are positively prepared to meet objectively assessed need and infrastructure requirements.
We strongly disagree.
2b. Comments.
Para 23:
Following on from the comment under para 9, the lack of any explicit reference to arts and culture in a paragraph in which leisure, health, and the natural and historic landscape are mentioned, will severely undermine work to sustain and develop cultural infrastructure. Mention of leisure and community infrastructure is not sufficient, as both these terms are subject to a range of interpretations, many of which exclude arts and culture. The absence of any requirement for strategic priorities given the critical importance of cultural infrastructure to vibrant and distinctive localities, is very concerning.
Para 24, point 1
Again, the absence of any reference to arts and culture from the NPPF means their absence from local plans, or in areas which choose to include them, the potential of challenge.
Para 24, point 5
The lack of reference to arts and culture within the NPPF will make it very difficult to protect cultural facilities, other than those designated as historic buildings. Most cultural facilities do not fit that definition and will be left vulnerable to change of use, even though they are often highly prized by their local communities.
Para 25:
We fully support the aim of this paragraph, but are concerned that the
Arts Development UK, Oak Villa, Lower Brynamman, Ammanford, Wales SA18 1SN
Tel/Fax: 01269 824728, email artsdevUK@aol.com
www.artsdevelopmentuk.org
Charity Registration: 1121290
Page 5 of 11

lack of reference to arts and culture within the NPPF will lead to local communities not being able to fully reflect their visions and aspirations within their own local plans.
Para 26:
Again, the absence of arts and culture from the NPPF will leave areas without up to date Local Plans without any basis on which to challenge development activity that would have a detrimental effect on cultural provision, other than that taking place within historic buildings and environments.
Paras 27, 29, and 30
As with the overall definition of sustainable development, we suggest that Local Plans should be based on adequate, up-to-date and relevant information about the economic, social, cultural, and environmental characteristics and prospects of the area. This information is readily available from a range of sources, including the DCMS. Without this evidence base we suggest that local planning authorities will not be able to make fully rounded assessments of requirements for development, specifically in relation to the role and function of town centres and the capacity of existing centres to accommodate development, but also in relation to the needs of business for cultural infrastructure to support the development and retention of employees.
Para 30, point 1
As previously discussed, the word leisure is not sufficiently well defined. It is often taken as synonymous with sport and/or commercial entertainment, and its presence in combination with the absence of reference to arts and culture provides a strong implied message that arts and culture are explicitly excluded.
Para 38:
Again, the absence of arts and culture from the NPPF as a whole will have a detrimental effect on the capacity of local planning authorities to take into consideration the role of arts and culture in health and well-being. As mentioned earlier, the DCMS has significant evidence of
Arts Development UK, Oak Villa, Lower Brynamman, Ammanford, Wales SA18 1SN
Tel/Fax: 01269 824728, email artsdevUK@aol.com
www.artsdevelopmentuk.org
Charity Registration: 1121290
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the impact of culture on health and well-being.
Para 40:
Cultural infrastructure is mentioned within the Community
Infrastructure Levy Overview (May 2011 from DCLG). Its absence from the NPPF introduces a lack of clarity and potential challenge to local communities wishing to use the community infrastructure levy mechanism for arts and cultural development
2c. The policies for planning strategically across local boundaries provide a clear framework and enough flexibility for councils and other bodies to work together effectively.
We strongly disagree.
2d. Comments.
Paras 45, 46, and 47:
The absence of arts and culture from the NPPF will significantly undermine the capacity of local planning authorities to ‘work collaboratively with others to ensure that strategic priorities across local boundaries are properly co-ordinated and clearly reflected in individual local plans.’ This is of concern both for the planning of regionally and nationally significant cultural infrastructure and for the developing role of Local Enterprise Partnerships in relation to culture, and its critical role for economic development, both through cultural regeneration and local distinctiveness, and the role of culture in relation to the knowledge economy, where strategic and long term planning is essential to maintain global competitiveness.
3a. In the policies on development management, the level of detail is appropriate.
We strongly disagree.
3b. Comments.
Para 48:
Arts Development UK, Oak Villa, Lower Brynamman, Ammanford, Wales SA18 1SN
Tel/Fax: 01269 824728, email artsdevUK@aol.com
www.artsdevelopmentuk.org
Charity Registration: 1121290
Page 7 of 11

As it stands, the NPPF does not allow independent inspectors to scrutinize plans for culture, or to consider the need for those plans to be included. It is possible that local planning authorities that have chosen to include arts and culture could be challenged on the basis that their plans for sustainable development have not been developed
‘in accordance with the policies in the framework’.
Paras 49, 50, 51, and 52:
Similarly, although neighbourhood plans are to enable communities to
‘develop a shared vision for their neighbourhood’; this is undermined by the absence of arts and culture from the NPPF and the presumption that neighbourhood plans should be in general conformity with local plans. Local communities are passionate about their culture and cultural provision, and the NPPF as it stands will not enable them to include that commitment within their neighbourhood plans.
Para 55:
Without clear statements within the NPPF that define culture’s contribution to sustainable development we foresee both a loss of existing provision and a failure to plan for future need. Facilities providing arts and cultural activity are already at risk where they are not protected under the existing planning regime (i.e. live music venues operating within public houses), and the significant reduction in protection under the NPPF for cultural infrastructure will put a far greater range of facilities at risk. Although in the short term, the space used by cultural facilities might generate greater revenue through other routes, we suggest that longer term gains from protecting and enhancing cultural infrastructure are far more significant and should again be recognized as an integral part of sustainable development.
Paras 58, 61
Again, given the absence of arts and culture from the NPPF, and the lack of a requirement for local planning authorities to assess need, it is difficult to see how good decision-making in relation to impact on arts and cultural provision is going to be carried out.
Paras 62 and 63
Arts Development UK, Oak Villa, Lower Brynamman, Ammanford, Wales SA18 1SN
Tel/Fax: 01269 824728, email artsdevUK@aol.com
www.artsdevelopmentuk.org
Charity Registration: 1121290
Page 8 of 11

Again, the silence on arts and culture throughout the NPPF, and their likely subsequent absence from local plans, will mean that the impact on arts and cultural provision will not be able to play a role in the determining applications.
4a. Any guidance needed to support the new Framework should be light-touch and could be provided by organisations outside
Government.
We strongly disagree.
5a. The ‘planning for business’ policies will encourage economic activity and give business the certainty and confidence to invest.
We strongly disagree.
5b. Comments.
Paras 71,72, and 73.
The silence on arts and culture throughout the NPPF again undermines the capacity of the NPPF to deliver: the role of culture in developing viable and vibrant town centres is well documented, as is its role in local distinctiveness. It is also a critical component in ensuring the global competitiveness of our cities. Arts, culture and creativity and also critical to the development and sustainability of the knowledge economy, where businesses are competing on a global field to attract and retain employees. Including arts and culture within the initial definition of sustainable development would resolve this issue.
6a. The town centre policies will enable communities to encourage retail, business and leisure development in the right locations and protect the vitality and viability of town centres.
We strongly disagree.
6b. Comments.
Para 76:
Again, the absence of any reference to arts and culture undermines
Arts Development UK, Oak Villa, Lower Brynamman, Ammanford, Wales SA18 1SN
Tel/Fax: 01269 824728, email artsdevUK@aol.com
www.artsdevelopmentuk.org
Charity Registration: 1121290
Page 9 of 11

the capacity of the NPPF to protect the vitality and viability of town centres. As stated earlier the use of the terms leisure and community is not sufficient, as these are not well defined and in many cases where local definitions have arisen, they do not include arts and culture, so that their use in this context moves towards promoting a position which is not just silent on arts and culture, but one in which they are excluded. Attempts to create balanced evening economies through the promotion of a diverse cultural and leisure offer, or to ensure local distinctiveness through the cultural offer, would be undermined through the NPPF as it stands.
7a. Transport. The policy on planning for transport takes the right approach.
We disagree.
7b. Comments.
Again, our comments here are specifically in relation to the absence of arts and culture, and use of the word leisure without proper definition.
Sustainable communities. The policies create strong, vibrant and healthy communities, by creating a good quality built environment with local services that reflect community needs and support wellbeing.
We strongly disagree.
Comments.
Para 124:
Again, the silence on arts and culture throughout the NPPF will seriously undermine its capacity to create ‘a good quality built environment, with accessible local services that reflect community needs and support well-being’. The explicit reference to recreational facilities is not helpful in this context, as again, it is a term which is not well defined, and is often used interchangeably with sports.
Para 126:
Arts Development UK, Oak Villa, Lower Brynamman, Ammanford, Wales SA18 1SN
Tel/Fax: 01269 824728, email artsdevUK@aol.com
www.artsdevelopmentuk.org
Charity Registration: 1121290
Page 10 of 11

The definition of community facilities ‘such as local shops, meeting places, public houses and places of worship’, again appears to exclude arts and cultural facilities by omission, and adds to the concern with the use of the term community facilities elsewhere in the NPPF. This should not be misunderstood as a desire to see the emphasis on community facilities weakened; we welcome this inclusion, but believe that this definition, without reference to specifically cultural facilities, further weakens the position for arts and culture within the NPPF.
Paras 128, 129
Again, the absence of any mention of arts and cultural facilities is a serious omission. Arts and culture also make ‘an important contribution to the health and well-being of communities’, and whereas we welcome the explicit mention of good quality open spaces and opportunities for sport and recreation, we fear that in this context the silence on arts and culture will further undermine any local or neighbourhood plans that choose to include arts and culture.
Arts Development UK, Oak Villa, Lower Brynamman, Ammanford, Wales SA18 1SN
Tel/Fax: 01269 824728, email artsdevUK@aol.com
www.artsdevelopmentuk.org
Charity Registration: 1121290
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