Need and impact: planning for town centres - Communities and Local Government Committee Contents


2  The Government's proposed changes

Current policy on planning for town centres

15. In principle, town centre development, as other development, should be on a 'plan-led' basis. Local planning authorities prepare a development plan, or 'Local Development Framework' (LDF), which sets out the approach to managing development, including allocating land to different uses. The existing Planning Policy Statement 6 (PPS6) expresses that plan-based policy as follows:

Local planning authorities should work in conjunction with stakeholders and the community to:

16. As part of the process of producing the local development plan, local planning authorities should assess the need for development.[14] PPS6 states

Need assessments for the development plan document period should be carried out as part of the plan preparation and review process, and updated regularly. […] This will provide the basis for identifying the need for additional development and the appropriate scale of such development in the centres within an authority's area, bearing in mind their role and function. It will also enable the local planning authority to test alternative options and make choices about where growth should be accommodated.[15]

17. Local planning authorities should in principle, therefore, have in place development plan documents prepared on the basis of assessments of need for various types of development; and applications for the approval of new development should be determined in accordance with the plan. There are nevertheless further considerations which have to be applied when an application for new, or further, development of a site is brought forward:

In the context of development control and subject to the policies set out below, local planning authorities should require applicants to demonstrate:

a) the need for development [the 'need test'];

b) that the development is of an appropriate scale;

c) that there are no more central sites for the development [the 'sequential test'];

d) that there are no unacceptable impacts on existing centres; and

e) that locations are accessible.[16]

18. The 'sequential test' requires that "in selecting sites, all options in the centre should be thoroughly assessed before less central sites are considered".[17] The sequential approach to site selection "should be applied to all development proposals for sites that are not in an existing centre nor allocated in an up-to-date development plan document".[18] The 'need test' requires that "need must be demonstrated for any application for a main town centre use which would be in an edge-of-centre or out-of-centre location and which is not in accordance with an up to-date development plan document strategy."[19] Together, the 'need test' and the 'sequential test' have been the mainstay of the 'town centre first' approach, acting to direct development towards town centres and away from out-of-centre locations and to curtail large out-of-town development likely to suck the life out of existing town centres.

The proposed changes

19. The Government's proposed changes to Planning Policy Statement 6 have now been rolled up into the proposed new Planning Policy Statement 4: Planning for prosperous economies. As stated in the quote reproduced above from the Ministerial foreword to the July 2008 consultation on the proposed changes to existing policy as set out in PPS6, the fundamentals of the existing policy remain the same.[20] The 'town centre first' principle remains, as do the requirement to assess need during the preparation of the local development plan, the 'sequential test', and the requirement to assess the impact of edge- and out-of-centre development proposals on the viability and vitality of the town centre.

20. The proposals would remove the requirement for an applicant to demonstrate the need for a proposal for a main town centre use which is in an edge- or out-of-centre location and which is not in accordance with an up to date development plan strategy. Instead, such proposals should be accompanied by an 'impact assessment'. As under existing policy, the impact assessment is to be undertaken following a sequential assessment, which ensures that all in-centre options for development have been thoroughly assessed before less central sites are considered, and must confirm that the proposed development cannot be accommodated on a town centre site.

21. The 'need test' in PPS6 was required only for applications in an edge of centre or out of centre location (and not in accordance with an up to date development plan). The new impact assessment, however, will also be required where a significant development, not in accordance with the development plan, is located in an existing centre and such a development would substantially increase the attraction of the centre and could have an impact on other centres. In such cases the impact on those other centres should also be assessed.

22. The proposed new PPS4 allows for local authorities to set floorspace thresholds for the scale of development which should be subject to an impact assessment, but states that in the absence of such thresholds being defined, a comprehensive impact assessment will be needed for retail and leisure developments over 2,500 square metres gross floorspace. That 'default' threshold of 2,500 square metres reflects the starting size for a retail outlet which would generally be considered a 'superstore', though a new supermarket will these days typically be significantly bigger than that. The draft PPS4 also indicates that local authorities should engage positively with applicants prior to the submission of a planning application to agree the scope of the impact assessment and to ensure that the level of detail and type of analysis required are proportionate to the scale and nature of the proposal and its likely impact.

23. The impact assessment requires both 'key' and 'wider' impacts to be considered. Key impacts are:

  • Carbon dioxide emissions and resilience to climate change;
  • If located in an edge-of-centre location, the impact on the spatial planning strategy, in particular the role of the centre in the hierarchy of centres;
  • Impact on existing, committed and planned public and private investment in a centre or centres in the catchment area of the proposal;
  • If located in an edge-of-centre location, whether it is of an appropriate scale (in terms of gross floorspace), in relation to the size and role of the centre and its catchment area;
  • Accessibility of the proposal by a choice of means of transport, including walking, cycling, public transport and the car;
  • Impact on in-centre trade/turnover and on trade in the wider area, taking account of current and future consumer expenditure capacity in the catchment area;
  • Impact on town centre vitality and viability including local consumer choice and the range and quality of the comparison and convenience retail offer; and
  • Whether the proposal secures a high quality and inclusive design.

24. Wider impacts, which are to be assessed unless the local authority has identified locally important impacts in its development plan, are:

  • Impact on allocated sites outside town centres being developed in accordance with the development plan;
  • Impact on deprived areas and social inclusion objectives;
  • Impact on local employment, particularly whether it will create new jobs and lead to a net increase in employment; and
  • Impact on economic and physical regeneration in the area.

CONSUMER CHOICE

25. PPS4 also sets out a policy entitled 'local planning approach to planning for consumer choice and promoting competition for town centre development', which emphasises the role that both smaller shops and street markets play in ensuring consumer choice. This policy states that local planning authorities should proactively plan for consumer choice and promote competitive town centre environments by:

PRACTICE GUIDANCE

26. The July 2008 consultation on the proposed changes to PPS6 noted the Government's commitment to publishing practice guidance to support the implementation of the policy. Many of the written responses to the consultation on the draft PPS6 expressed the view that the effectiveness of the new impact assessment framework would depend to a considerable degree on the content of that guidance. A 'living draft' of the practice guidance was published for consultation on behalf of CLG by consultants GVA Grimley at the same time as the consultation document on the new PPS4.[21] The consultation period ends on 28 July 2009.

27. The practice guidance sets out further detail on assessing impact, stating that "The objective of an impact assessment is to measure and where possible quantify the impacts of proposals".[22] In relation to assessing the impact of new proposals on planned/committed development, the practice guidance states "many of the factors relevant to need assessments [that is, the need assessments which will still have to be undertaken for the authority's overall development plan] will also have a bearing on the effects of new proposals on committed/planned development".[23]

28. The practice guidance acknowledges that the assessment of impact is inevitably subjective and will involve judgements, and that it will therefore be for the decision-maker to determine what constitutes an 'acceptable' or 'adverse' impact when making a judgement based on an assessment of the positive and negative effects relating to the impacts identified in national policy.

29. In assessing the impact on vitality and viability of town centres, the practice guidance notes that it will be appropriate to consider the implications of a proposal on retail diversity, particularly the range, type and quality of goods. The guidance states that this will be especially relevant in historic market towns or centres which have developed a distinct and unique character. In important historic centres, or centres which rely on a particular diversity and special character, the practice guidance notes that it may be appropriate to take a cautious approach to potential adverse impacts.

30. The practice guidance states that any potential employment benefits of new development should be balanced against any possible reduction in employment opportunities in town centres, so that any consequent loss of jobs in the town centre is considered, as well as any additional jobs generated. In the case of proposals on the edge of, or outside, the town centre, the benefits for the economic and physical regeneration of the area will need to be weighted against potential town centre impacts, including the effect on turnover, vitality and viability and planned new investment in nearby centres.


13   PPS6, para 2.16. Back

14   Ibid, para 2.28(a). Back

15   PPS6, para 2.32. Back

16   Ibid, para 3.4. Back

17   Ibid, para 3.14. Back

18   Ibid, para 3.13. Back

19   Ibid, para 3.9. Back

20   See para 8 above. Back

21   See above. Back

22   Practice guidance, para 7.3. Back

23   Ibid, para 7.27. Back


 
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Prepared 25 July 2009