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Changing planning policy for England

Thursday 17 July 2008

NABMA members will be aware that within PPS6 markets figure prominently and the APPMG are united in urging government to highlight the profile of markets in any revision of PPS6, not as add ons, but as an integral part of town and city centre regeneration programmes.

 

To see the document you can click here http://www.communities.gov.uk/publications/planningandbuilding/pp6consultation

 

NABMA would like to thank Simon Quin, Chief Executive of ATCM for the below helpful summary produced following the APPMG yesterday

 

“The consultation paper on proposed changes to PPS6, Planning for Town Centres, which was announced in last year's White Paper on Planning and Sustainable Development was published late last week by the Government. The consultation is clear that the changes proposed are not about revisiting the fundamentals of the town centres first policy and that the emphasis remains on ‘promoting vibrant, viable town centres more successfully'. There is also clear emphasis on the need for partnerships between the public and private sectors to bring the right development forward in town centres. However, there is radical change in the consultation paper in a number of respects.

 

The consultation paper places significantly greater emphasis on competition than previous versions of PPS6 or its predecessor have done. Planning must be seen to promote competition and consumer choice and not unduly or disproportionately constrain the market. This is evident throughout the paper with a number of specific insertions to this effect proposed, including references to productivity, competition between retailers, and job opportunities. There is a change in emphasis linked to this so that local authorities are required now to use ‘market information and economic data' in developing planning policy and considering applications.

 

Secondly, as foreshadowed in the White Paper in 2007, the consultation proposes the abolition of the ‘needs test' for planning applications. However, rather than then leaving other tests untouched, the consultation paper proposes the replacement of the existing impact assessment with a new impact assessment framework covering both strategic planning and wider economic, social and environmental factors. The previous five aspects that applicants had to demonstrate (need for the development; that the development is of appropriate scale; that there are no more central sites for the development; that there are no unacceptable impacts on existing centres; that locations are accessible) have been reduced to two for proposals that are not in accordance with an up to date development plan: that there is no more central site that exists (the ‘sequential test') and that ‘there are no unacceptable impacts arising from the proposed development, including on existing centres'. Although the requirement to demonstrate need has been abolished, the requirement for appropriate scale is retained as one of five ‘key town centre impact considerations' whilst accessibility is now one of seven ‘wider impact considerations'.

 

There are some other interesting nuances in the consultation document. There are several references introduced to helping tackle climate change, which could in many cases be seen to support the town centres first argument, and a more specific reference to creating safe environments in town centres that reduce risks and mitigate the impact of crime, including terrorism. The requirement for local authorities to plan for growth and manage change remains but specific references to avoiding over-concentration of growth in higher level centres seem to have been weakened, although there is still a clear wish to see an appropriate distribution of town centre uses.

 

The paper changes previous references to dynamic networks and hierarchies of centres to clarify that it is economies that are dynamic instead and that as a result planning policies need to be ‘flexible' and able to respond to changes. It is clear that any significant change proposed in the hierarchy of centres needs to be done through the development plan process.

 

The consultation paper changes the emphasis on what should be considered by those engaged in drawing up development plans when assessing the need and capacity for additional retail and leisure development, stressing now that both quantitative and qualitative considerations are to be considered together, with the latter having additional weight in deprived areas.

 

Whilst not making a specific reference to town centre management (though BIDs now join town centre and retail strategies as a tool for those planning and implementing town centre policies), a new paragraph does state that planning authorities should ‘positively and pro-actively manage the role and function of their town centres...[and]...support sustainable economic growth and development and the needs of business and engage with town centre investors and service providers' (Para 2.11a). Interestingly, new paragraph 2.18a sets out an agenda for town centres that most TCM initiatives could, I think, adopt wholesale. It places great emphasis on the need for a good mix of shops and services, refers to character, vibrancy, tourism, leisure, culture, daytime and evening uses and a diversified offer, aspects of which should appeal to all.

 

In total this is an 88 page document with much to be welcomed but with some things that I think will pay detailed consideration if we are to be confident that the aspirations set out by the Secretary of State in the Foreward are to be met. It is perhaps worth noting that one of the reasons for the proposed changes is that it is believed the needs test had unintended consequences. It would be useful to have a debate over the Summer (responses are due on 3 October) to minimise future risk of such things. There will be further thoughts on this in the next few weeks.

 

To see the document you can click here http://www.communities.gov.uk/publications/planningandbuilding/pp6consultation