The Government today published the consultation on the new draft PPS4 – Planning for Prosperous Economies. This is a PPS with a difference, seeking to perhaps sensibly (although clearly that will depend on the shape of the final PPS), combine all of the various strands of planning policy related to the economy into one document, therefore bringing together PPS4, PPS5, PPS6 parts of PPS7 and part of the Annex of PPS14. The consultation takes into account previous recent consultations on both PPS4 and PPS6 and the stakeholder groups formed to review these policies.
It also will allegedly reflect the recommendations of the Killian Pretty Review in terms of reducing the regulatory burden – it is encouraging to see that the whole of the KP Review isn’t simply going to be lost in the black hole of government translation…
In the new draft PPS4, the objectives for ‘Prosperous Economies’ are set out as to:
- achieve sustainable growth
- raise the productivity growth rate of the UK economy
- improve economic performance and reduce the gap in growth rates between regions
- deliver more sustainable patterns of development and respond to climate change
- promote high quality and inclusive design, improving the quality of the public realm and open spaces
- improve accessibility and provide alternatives to car use
- promote the vitality and viability town and other centres as important places for communities and ensure that they are economically successful recognising that they are important drivers for regional, sub-regional and local economies
- ensure economic growth and development is focused in existing centres
- ensure competition between retailers and enhanced consumer choice through innovative and efficient shopping, leisure, tourism and local services in town centres
- conserve and enhance the heritage of centres where appropriate
- promote social inclusion and accessibility
The draft PPS focuses on the need to prepare an evidence base to understand and respond to existing business, leisure and retail needs and to prepare Local Economic Assessments. This evidence base should underpin development plans and should understand the economic markets, the broad need for land for economic development, areas of deprivation and deficiencies. All of the evidence will need to be subject to regular review to ensure relevance and to take into account additional regeneration and employment needs. This may well have significant implications for local authorities who struggle with the resources required to undertake such assessments – however, on the basis that streamlining the policies will reduce pressures and regulatory burdens this may not transpire to be an issue…
The new PPS also takes on the mantle of moving from plan-led to a spatial planning system emphasising the need for encouraging sustainable economic growth in conjunction with future housing and population needs and taking into account social, economic and other relevant factors. There is an emphasis on the need for Regional Spatial Strategies to disaggregate where appropriate to the district level in identifying locations of strategic sites etc, Obviously, there is a wider question here as to how this will be dealt with in the event of a new Conservative Government who have stated their intention to abandon Regional Spatial Policies – it would seem that much existing planning policy will subsequently need to be reviewed – again.
In terms of Planning for Town Centres the PPS is broadly similar to the draft PPS6 and responds to the individual consultation on this policy regarding defining the hierarchy of centres, defining and managing growth identifying deficiencies and addressing decline etc. In particular, the new policy proposes to enable a change of use to become easier, increasing flexibility in the system in situations where reversing decline may not be possible. As expected, the needs test has been removed and the sequential approach has been retained along with an impact assessment which brings forward for consideration all of the other elements contributing to making a ‘Prosperous Economy’.
The new PPS emphasises the possibility for local authorities to set floor space thresholds for edge-of and out-of town developments as well as the possibility for the reallocation of sites and making provision for land assembly to accommodate growth in the future. A specific clause is also included to encourage residential and office development as appropriate uses above ground of retail and leisure uses within town centres.
Perhaps responding to concerns from local authorities about the manipulation of the planning system with regard to the way in which housing development is leveraged as part of town centre development, the PPS introduces a clause which requires local authorities to ensure that housing in out of centre mixed-use development is not, in itself, used as a reason to justify additional floor space for main town centre uses within these locations.
Tackling the thorny issue of competition, the new draft PPS states that local planning authorities should proactively plan for consumer choice and promote a competitive town centre environment by:
- Supporting the diversification of uses
- Planning for a strong retail mix
- Recognising that smaller shops can significantly enhance a town centre
- Retaining and enhancing existing markets and reintroducing or creating new ones
- Planning for a range of tourism, leisure and cultural activities
- Taking measures to conserve and enhance the established character and diversity of their town centres
In comparison to some of the initial proposals for competition in town centres this is a pale imitation lacking any real substance in terms of competition assessments and leaving it highly open to interpretation. A difficulty with moves to ‘encourage’ and ’support’ is that, in the event of a refusal on the grounds of seeking to retain smaller shops, a local authority may well be vulnerable at appeal from the arguments of an applicant with significantly more resources to invest in the case. Furthermore, there is a risk that local authorities may seek to preserve markets and local shops that the local economic market simply cannot support into the long-term without further development and investment which may only be brought about by introducing some of those stores seen to negatively impact on local retailers – it can be something of a Catch 22 and is a difficult position to seek to resolve.
Other areas covered include introducing a more flexible approach to recognise the difference between urban and rural economies and recognising the need to minimise car-parking whilst also taking into account the genuine need for parking by different aspects of the local economy.
The draft PPS seeks to reinforce the moves towards a positive planning culture which encourages applications regarding development as enabling rather than something to be managed, controlled or prevented; it proposes an obligation for councils to consider commercial applications favourably unless they can show the potential costs of a scheme outweigh its benefits and encourages local authorities to speed up the planning process by using tools including simplified planning zones. However, the case in many local authorities continues to be that development is a battle, and frequently a lesson in compromise which may not necessarily benefit all or even one party ultimately.
There is a significant amount in the detail of the consultation in terms of how the various PPS will be brought together which is likely to be the subject of significant debate over the official 12 week consultation period. At first glance it looks to be a more compressive and cohesive approach to planning for local economies than has previously been the case with the differing and overlapping objectives of the numerous relevant PPSs. With the number of differing views particularly on PPS6, it will be interesting to see the final form of the PPS itself.
We will keep you updated.
Written by Stephen Byfield