5 Conclusion
80. We are strong supporters of the Government's
'town centre first' policy. There are many reasons—economic,
social and environmental—why it is crucial that the vibrancy
and vitality of town centres should be maintained. We are pleased
not only by the Government's continued commitment to that policy,
but also by the wide degree of support which it commands—at
least in principle—across the whole range of those who responded
to the Government's consultation on its proposed changes, and
those who gave evidence to our inquiry.
81. One key justification for the removal of the
need test is that it forms a "barrier to entry" to the
market for retailers, particularly those attempting to compete
with the 'big four' supermarkets. Our view is that it is right
that the planning system should represent a barrier to development:
a hurdle put in front of developers to oblige them to demonstrate
the merits of their plans, and to enable local communities to
judge whether their benefits outweigh their disadvantages. That,
indeed, is the purpose of the planning system. In the context
of these changes, an effective 'town centre first' policy requires
a barrier to damaging out-of-centre development.
82. We have not seen compelling evidence that the
'need test' has had adverse effects, though we accept that it
may, in some circumstances, have been used inappropriately, distracting
from the proper assessment of the impact of a proposed development
on the local area. Particularly in the current economic circumstances,
we consider that the removal of the need test would present an
unacceptable risk to town centres. The proposed new impact assessment
framework has the potential to enable better decision-making,
but only in the context of the retention of the need test.
83. Having examined existing policy, the proposed
changes and the recently published practice guidance, we welcome
in principle the broader range of key and wider impacts included
in the new impact assessment framework, which have the potential
to provide local authorities with a more refined tool for decision
making. We also take some comfort from the explicit reference
within the draft PPS4 to the role which smaller shops play in
significantly enhancing the character and vibrancy of town centres;
and from the positive reception which the practice guidance has
received from the planning profession—whilst acknowledging
that it has not yet been tested.
84. Whether the advantages of that more refined tool
for decision-making can be realised, however, will depend on the
capacity of local planning authorities to implement it effectively.
We expressed serious concerns about both labour shortages and
skills gaps in local authority planning departments in a report
of last year: our concerns have not been allayed since. Some tools
and resources are in place to assist local authorities in this
regard; but further action may be required if the objectives of
this change in planning policy are to be achieved.
85. Monitoring
the effect of the changes will be crucial. The Government's intentions
in introducing these changes are good, and the majority of our
witnesses expected them to have a broadly positive effect. Witnesses
were also in agreement, however, that the effects could not be
fully known until they had been extensively tested by actual applications.
The Government must keep a close eye on the results of the introduction
of the new framework, and of the practice guidance which goes
with it, and be ready to change either or both of them if they
are not adequately protecting town centres. We
recommend that our successors in the next Parliament revisit this
subject 18 months to two years after the introduction of the changes,
to ensure that effective monitoring has been undertaken and that
the new policy is effectively protecting and enhancing the vibrancy
and vitality of our town centres.
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