31 Jul 2019
Amid the flurry of pre-summer recess updates to the Planning Practice Guidance were two new additions on planning for economic needs. The first relates to specific guidance on, “how can authorities assess need and allocate space for logistics?” (new para 31), and second, guidance on the wider question of, “how can the specific locational requirements of specialist or new sectors be addressed?” (new para 32).
The addition of logistics within the PPG is perhaps not surprising given it was one of the notable updates made to the revised NPPF published earlier this year. As we have summarised previously, it is welcome to see this critically-important sector being given specific recognition (particularly as the sector is not always universally welcomed at a local level) and this is now reflected in the guidance. Importantly, the PPG emphasises that policies for logistics should be formulated “separately from those relating to general employment land”.
However, this has typically not been the case in all local plans. Part of the issue is that logistics space markets and networks often cut across local authority boundaries, with wide functional economic market areas and specific needs in terms of access to the strategic transport network, power capacity and labour supply. This emphasises the need for collaboration between local authorities and also engagement with logistics operators and developers – the sector should embrace this invitation to help plan-makers better understand their current and future needs.
Further, research by Lichfields on the ‘last mile’ segment of logistics highlighted that planning is to some extent still catching up with this fast-moving sector, and needs to better understand industry trends. Some 58% of authorities surveyed viewed the lack of an up-to-date local plan as a key barrier to meeting last mile needs. The PPG now points to a broad range of evidence being considered to help determine local logistics needs, including “changes in the local population and the housing stock as well as the local business base and infrastructure availability”.
The second addition to the PPG on understanding the locational requirements of specialist or new sectors appears, at face value, to be a recognition that traditional ‘predict and provide’ approaches to employment land forecasting are not without their limitations. The PPG cites high tech, engineering, digital, creative and logistics as examples of such industries, where clustering can drive innovation, productivity and economic growth. These and other fast-growing sectors don’t always fit neatly into traditional B use class definitions, so it’s arguably a rallying call for a more nuanced understanding of the inter-relationships between sectors and space and the factors that drive competitive advantage. More qualitative evidence and engagement with businesses and occupiers in this regard will contribute to better plan-making.
Echoing the revised NPPF (see para 81a), there’s also now specific reference in the PPG to the need to take account of policy and evidence contained in Local Industrial Strategies. There are currently 6 Local Industrial Strategies in place nationally, and with more on their way, they will have an increasingly important role to play in setting the direction of policy as well as future public funding to support delivery. Lichfields’ work on a number of Local Industrial Strategies nationally has reinforced how getting land use planning policies right is critical to facilitating local economic ambitions. The challenge now is how to translate broad strategies to enhance regional economic productivity into clear and focused policies in future local plans, and having the evidence in place to back these up.
Image credit: DNPBFN SWNS Alamy Stock Photo
16 Mar 2018
The National Planning Policy Framework (NPPF), consulted on in 2011 and published in 2012, came as the UK economy was emerging from the deepest recession in a generation. Today, that period of recession continues to cast a long shadow in terms of impact on the public finances and productivity levels, and is now complicated by the economic uncertainties created by Brexit. In his Spring Statement earlier this week, the Chancellor Philip Hammond summed up that there is “light at the end of the tunnel”, but the latest Office for Budget Responsibility (OBR) forecasts point to a prolonged period of somewhat sluggish growth ahead (see Lichfields’ analysis).
In that context, the Government has chosen to make limited substantive change in terms of directing planning policy for the economy and business through its recently published draft NPPF. An “economic objective” remains the first overarching objective of the planning system (paragraph 8, point a). However, the wording has been broadened to expressly refer to the need to, “support growth, innovation and improved productivity” (emphasis added). Productivity is a concept rarely explored in any great detail in plan-making or decision-taking, but the added emphasis seems appropriate given the national imperative on the issue.
In line with the draft NPPF’s new structure, economic considerations (including the rural economy) now have their own chapter (6). In the current NPPF, “building a strong, competitive economy” is the first element of delivering sustainable development – tellingly, it now follows the chapter on delivering a sufficient supply of homes. In terms of content, however, the wording of the draft chapter looks familiar when compared to paragraphs 18-22 of the current NPPF. In line with the wider amendments to the current NPPF, the text has been reduced and simplified.
The widely-cited line that the planning system should do, “everything it can to support sustainable economic growth” (paragraph 21 of the current NPPF) disappears, but the general direction – and note the further reference to productivity – remains clear:
“Significant weight should be placed on the need to support economic growth and productivity, taking into account local business needs and wider opportunities for development.” (paragraph 82)
Also notable is the specific reference to the Government’s Industrial Strategy White Paper. This is not surprising, and is sensible; as written in an earlier blog, Government very much sees the Strategy as cutting across all areas of policy-making. In the same vein, planning policies should now have regard to Local Industrial Strategies (paragraph 83, point a). The Industrial Strategy, and how it is manifested locally, is therefore set to become more influential in plan-making and a potential material consideration. Local authorities and sub-regions will therefore want to be proactive in bringing forward Local Industrial Strategies not only to help realise growth opportunities in their area but also given the weight they might carry in making future planning decisions.
On employment land more specifically, the NPPF currently states that, “planning policies should avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose” (paragraph 22). This no longer appears in the economy chapter, but now features in expanded form in chapter 11 on “making effective use of land”. The sentiment is largely the same but the test has been sharpened: regular reviews of allocations are required and, even prior to plan reviews, applications for alternative uses should be supported where unmet needs for development could be provided for. Furthermore, in “areas of high housing demand”, the use of existing employment (and retail) land for homes is supported where this does not “undermine key economic sectors or sites”.
Taken overall, the draft NPPF looks very much like ‘business as usual’ when it comes to planning for the economy – there’s little in the way of new detail or prescription. As they start to come forward, Local Industrial Strategies will need to give consideration to how local plans can help deliver wider economic objectives, particularly improving productivity. The Government appears to view employment land as something of a sacrificial lamb in the quest to meet housing needs (in contrast with the much stronger policies to protect employment land proposed in the draft London Plan, as detailed in recent research by Lichfields). It’s also less clear how well the approach proposed nationally sits with the Government’s clearly stated intentions to support economic growth and productivity.
Ultimately, local authorities will need up-to-date and more comprehensive evidence to inform their judgments about the need for, and relative importance of, the employment land in their areas, particularly in the face of added pressure for release to other uses. Economic evidence looks set to remain key to planning decision-taking.
See our other blogs in this series:
National Planning Policy Framework review: what to expect?
Draft revised National Planning Policy Framework: a change in narrative
NPPF consultation proposals – what could they mean for town centres?
NPPF consultations – what could they mean for designers?
Draft NPPF: heritage policy is conserved…
Draft NPPF: implications for aviation?
Draft NPPF: more emphasis on healthy and safe communities
Lichfields will publish further analysis of the consultation on the draft revised NPPF and its implications. Click here to subscribe for updates.