The revised National Planning Policy Framework [NPPF] was published on 24 July 2018. The changes to the way that viability is considered and the introduction of the Housing Delivery Test have been hot topics over the past two weeks (and for months before that); but what about the logistics sector? This blog looks at some of the potential implications that the revised NPPF could have on logistics.
Strategic Thinking
The introduction of “employment” and “other commercial development” (paragraph 20) into the list of land uses for which strategic policies should set the pattern, scale, quality and make sufficient provision for, is welcome. This should be seen as a step in the right direction, particularly for employment development and should encourage some joined-up thinking by local planning authorities [LPAs], including for logistics.
Paragraph 82 goes on to explain that policies and decisions should recognise and address the specific locational requirements of particular sectors, including “clusters or networks of knowledge and data-driven, creative or high technology industries; and for storage and distribution operations” (highlighting is Lichfields’ own). The specific mention of storage and distribution operations (that incidentally, were not included in the March draft) is long overdue and provides recognition of the recent growth in this sector. Indeed, to be one of only three sectors explicitly mentioned in the ‘Building a strong, competitive economy’ chapter is testament to the role that logistics could play in the future economy.
This focus on strategic policies for logistics should encourage policy and decision makers to think more about the location of warehousing space. The location of distribution hubs has historically been led by the quality of the local highway network, and the distance to motorway hubs, rail freight terminals and ports. Whilst these are still key factors, the recent flurry of development of logistics buildings that has arisen because of a seismic shift in the way we shop (i.e. increased internet shopping) has resulted in the saturation of the workforce in some locations. This has caused prospective occupiers to undertake more detailed demographic analysis in areas where they are considering locating, to enable them to try and understand the quality of the existing and future workforce that would be available to them. Furthermore, the way that the last-mile of parcel delivery could evolve over the next few years i.e. through electrically powered e-vans, micro vehicles and e-cargo bikes which can provide a better delivery service to customers (in comparison to light commercial vehicles) could also have an impact on the way that logistics services operate, their scale and where they locate.
These are all factors that will impact on the location of future logistics and distribution hubs and will need to be properly interrogated throughout the development plan process.
But where will they live?
The creation of jobs through the growth of businesses is an attractive proposition for many councils. There are examples across the country of LPAs that actively support economic development, particularly in logistics and distribution, where they are promoting hundreds of hectares of employment land through the development plan process. These employment hubs can create hundreds of jobs for local people and can attract job seekers from further afield. However, this workforce needs somewhere to live. Indeed, the revised NPPF recommends that planning policies should support a mix of uses on larger sites, with the aim of minimising the number and lengths of journeys to work (paragraph 104a). However, in some cases, there won’t be enough homes for the expanded workforce to live in, as LPA housing requirements might not align with higher, aspirational employment land targets.
The revised NPPF does not help in this regard. Firstly, and as opposed to the standard methodology for the assessment of housing need, the revised NPPF does not include anything similar for the assessment of jobs and employment land. This means that each LPA can use its own methodology to derive a figure. This could be a ‘going for growth’ type of scenario; or a more modest ‘do nothing’ type scenario.
Secondly, the standard methodology does not appear to properly consider employment growth. Indeed, the revised NPPF does not include the 2012 NPPF policy that LPAs should ensure that a plan’s housing and employment strategies are integrated (2012 NPPF paragraph 158). Whilst there is nothing stopping plan-makers from increasing their housing need by utilising different methods of assessing need; some LPAs aren’t keen on increasing their housing numbers on a voluntary basis. And we have not yet seen any examples yet of how inspectors have considered an LPA’s use of a different approach.
If LPAs want to aim for higher employment growth, national policy should refer to providing enough housing to sustainably support the number of jobs that developments will create. Employment and housing growth need to align, and that coordination seems to be missing from the latest iteration of the NPPF.
Parking, parking, parking
The revised NPPF includes a requirement for new and expanded distribution centres to make provision for sufficient lorry parking. Whilst this is nothing new in practice, the revised NPPF now expects policies and decisions to take into account any local shortages, to reduce the risk of parking in locations that lack proper facilities or could cause a nuisance. It is somewhat surprising that the NPPF finds space to highlight anti-social behaviour of lorry drivers, but in doing so, it does reflect a common local concern by those promoting new B8 schemes. Whilst it doesn’t seem reasonable for new proposals to ‘over-provide’ on lorry parking to solve existing parking problems as a matter of course; there may be merit in B8 developers ‘over-providing’ on lorry parking to supplement a policy compliant provision (where schemes allow), as a benefit to the local community or to mitigate against other impacts.
So, has it gone far enough?
In a nutshell, probably not.
Whilst we are moving in the right direction, and the introduction of strategic policies is welcome, the disconnect between the way that housing need is derived (the standard housing methodology) and employment land need is calculated, does not help create sustainable communities. There could be a situation (particularly in the northern regions) where housing numbers are pushed down due to the standard methodology, but the LPA concerned is ‘going for growth’ and planning for hundreds of thousands of square metres of logistics space. Where is the workforce going to live? There has to be a symbiotic relationship between objectively assessed housing and employment need.
The government has almost adopted a ‘business as usual’ approach to logistics. Whilst producing a housing-focussed framework, a balanced approach is essential in creating truly sustainable development. Logistics developments play a huge role in our economy, enabling businesses to grow and creating jobs in local communities. The government needs to make sure that employment development is properly planned for and that we allow growth in the logistics sector to create opportunities for generations to come.
