Planning matters

In seeking to provide the conditions for long term economic growth, draft policy E1 would require local authorities to “allocate sites to implement the economic vision and strategy and meet existing and anticipated needs over the plan period…and the specific locational requirements of different sectors”[4]. This includes, where a need exists or is anticipated, making provision for: “the expansion or modernisation of other businesses of local, regional or national importance to support economic growth and resilience (including industries such as leisure and tourism which may be of particular importance in certain areas).[5]” Few authorities currently allocate sites for tourism uses. The allocation of major sites to support long-term investment would be helpful but on the whole, provided that authorities provide a positive policy framework, there is no absolute need for allocations for tourism uses. For those areas where tourism is an important part of the economy, recognition of this within the local plan’s vision and strategy is vital.

 

The draft NPPF states that development proposals within settlements should be approved unless the benefits of doing so would be substantially outweighed by any adverse effects, when assessed against the national decision-making policies in this Framework[6]. Whilst there are some limitations to the draft policy, overall, this generally reflects the current position and is a good starting point for such operations.

 

Many tourism operations take place outside settlement boundaries. The introduction of more extensive decision-making policies into the NPPF provides reinforced support for the development of tourism development in locations outside settlements. Proposed Policy S5 states that certain forms of development, such as rural businesses and services, “including tourism”, should be approved unless the benefits would be substantially outweighed by any adverse effects, when assessed against decision-making policies elsewhere in the Framework[7]. The location outside settlements would need to be shown to be necessary. The principle of this emerging policy is welcomed. It will provide explicit support across every authority, barring any local deviations tested through the plan-making process. 

Draft Policy S5 would work in parallel with draft policies E2 and E4. E2 would provide substantial weight to the economic benefits of proposals for commercial development which allow businesses to invest, expand and adapt, especially where this would support the economic vision and strategy for the area. In applying policy E2, draft policy E4 states that the sustainable growth of businesses in rural areas should be supported including through facilities to support rural leisure and tourism (paragraph 1c). This provides a welcome reinforcement for the sector. Together these go further than the current NPPF.

Draft policy E4 goes on to say that development proposals to meet business needs in rural areas may need to be located outside settlements and in locations that are not well served by public transport. In these cases, the decision-making policy says that opportunities to use previously developed land and sites that are physically well-related to existing development should be taken where they exist[8] and the siting and design of development should be appropriate having regard to the character of its surroundings[9]. These are not fundamentally different to the current NPPF.

 

The NPPF definition of “main town centre uses” includes certain tourism uses, including hotels and various leisure, arts and culture developments[10]. 

The NPPF maintains the support for town centre locations, with little overall change proposed to the policy approach for main town centre uses.  These will continue to be directed to existing centres with substantial weight to be given to supporting the overall vitality and viability of centres (Emerging Policy TC2). For proposed main town centre uses not located in an existing centre or in accordance with an allocation, these will continue to be subject to a sequential test which focuses on the town centre, then edge of centre if feasible and only if suitable sites are not available within a reasonable period, out of centre sites can be considered (Emerging Policy TC3). Flexibility on factors such as format and scale continue to be expected by policy while consideration of disaggregation has potentially been re-introduced (removed in the first edition of the NPPF in 2012). Notwithstanding the above, the consultation document does question whether the sequential test should be removed in order to allow greater flexibility to respond to changing patterns of demand. It will be interesting to see what the outcome of the consultation is in due course.

  

Whilst noting the term tourism is not defined in the emerging or the existing NPPF, except for a reference as part of main town centre uses, elsewhere we would expect all aspects of tourism to be covered i.e. attractions, accommodation and associated infrastructure. The visitor economy is also supported by a range of leisure and sporting facilities and destinations. There are separate policies in the draft NPPF for some of these types of uses e.g. sports facilities and therefore specific development proposals do need to be considered in this context.

The greater emphasis on rural tourism is very much welcomed. The emerging NPPF does not provide carte blanche for applicants, however, as other policies in the NPPF (e.g. flooding, landscape, ecology, heritage, transport) will still apply.

The principle of the plan-led system is reinforced through the consultation. Even with a stronger national set of decision-making policies, there will still be a need to ensure that the visitor economy, particularly where this has a significant role in a local area, is embedded within the emerging local and neighbourhood plans. Local authorities will also be considering whether assessments of need and allocations to meet needs for tourism will now have to be given greater prominence in the plan-making process from hereon in[11]. It has always been important for operators, and the wider industry, to engage throughout the plan-making process but perhaps there will now be greater reasons to monitor progress before engagement to ensure that assessments of need and allocations are robustly tested, and the generally positive emerging national policies are not diluted at a local level.

The introduction of decision-making policies provides a strong starting point. That said, I am left with a number of questions for the industry in relation to the application of these emerging policies:
 

1. What is considered to be a rural business and service for tourism, in relation to draft Policy S5?
    
2. How would a location outside settlements be shown to be necessary? Is there a risk that this could be artificially limited by decision-makers in the absence of further guidance or will they rightly consider the term broadly and on a case-by-case basis?
    
3. Does ‘commercial development’ include tourism development when it comes to applying substantial weight in support of proposals under draft Policy E2. It should.
    
4. What precisely is rural tourism in draft Policy E4? Is it any tourism located outside the settlement boundary or could it be limited to small-scale tourism associated with traditional rural business?
    

We are currently working with operators and industry representatives as part of reviewing the draft NPPF with a view to making representations before the consultation deadline on 10 March 2026. Please do get in touch if you would like further information.