Comment

National planning policy reforms: Are we building a strong, competitive economy?

DLUHC’s consultation on the proposed changes to the NPPF begins by setting out its intentions: ‘how we might develop new and revised current national planning policy to support our wider objectives’[1]. The objectives are particularly with reference to the Government’s commitment to ‘levelling up across the country’. The latest in our series on the proposed reforms sees Director, Amy Gilham explain why the revisions don’t go far enough to deliver these aims.

The central premise of ‘levelling up’ is reducing the productivity gap across the country. Fundamental to this should be the NPPF policy thread of ‘building a strong, competitive economy’ and the sectors which are recognised to support its achievement.

The revisions and consultation document do not currently go far enough, quickly enough to support the delivery and achievement of these objectives.

Building a strong, competitive economy: An imbalance

There are no immediate proposed text changes to the already short, one and a half page, chapter 6 of the NPPF: Building a strong, competitive economy. The wider revisions to the NPPF still appear to place housing as sovereign (see our thoughts on this here).

While it is not in dispute that housing is a fundamental requirement for our population, the absence of changes to the chapter or material change indicated in the consultation document is concerning given this is arguably the chapter of prime importance to achieving a narrowing of the productivity gap. There is a clear opportunity for planning to play a central role in driving innovation and meeting the diversifying market demands of our economy.

Unintended consequences

There have been recent incidences of decisions on housing at Local Plan Examination in Public (EiP) which have had repercussions for employment land. In areas where housing numbers are contentious, this can result in revising down employment land numbers without consideration of the wider than local – strategic – role of employment land for sectors such as logistics and R&D space. Look to the recent Warrington EiP for example where despite the authority’s pro economic growth stance their employment land provision was halved by the Inspector due to the conclusion that housing numbers did not need to be increased above the standard method and as such, there would have been a significant mis-alignment between housing and employment land provision in the borough.

Sectors driving productivity change

The consultation document itself includes some reference to specific economic sectors, namely R&D, technology and ecommerce. The NPPF will need to go further in supporting the allocation of land for such uses and recognising the full extent of their role in delivering levelling up. Paragraph 85 (previously paragraph 83), as it remains, will not stand the test of time. Some clear opportunities present themselves:

R&D, technology and life sciences

While R&D, life sciences, bio tech and so on support high skilled and highly productive jobs, and the sector is spreading its geographical fingers from the golden triangle of Oxford, Cambridge and London to core cities, the NPPF can play an important role in encouraging development elsewhere in the country to truly deliver on the levelling up objective.

The sector has particular skills requirements and naturally seeks agglomeration with key research institutions, industry and businesses (to maximise the potential ‘bump effect’). This could be harnessed through a more strategic approach to considering locations for investment against areas of deprivation for example. Supporting the allocation of land in the right places and for a range of clustered, adaptable uses will underpin the ability to deliver levelling up. 

The green economy

Greater attention could also be given to joining the dots with the green energy approach (see our previous article here) in the NPPF as a clear win for R&D investment and productivity growth.

Whilst positive steps have been taken to recognise these sectors through the new Government Departments for Energy Security and Net Zero and Science, Innovation and Technology, it is critical that joined-up thinking and approaches to policy take place to deliver adaptable, high-quality development.

The NPPF needs to be a critical driver in supporting this and realising actual growth on the ground. As currently drafted, it provides scant direction for this to be an area of focus for local planning policy.

Logistics and e-commerce

The logistics sector is forecast a 43% increase in its productivity to 2039^[2] and has relevance across the country^[3] making it ideal to support achievement of levelling up objectives.

The reference to ecommerce as one element of the good infrastructure required to deliver a competitive economy is welcomed. We await the future consultation on the Infrastructure Levy to fully tell us how far this will go, and whether wider supply chains which form part of e-commerce will be fully recognised.

Looking to the future

While the NPPF in its current form includes reference to being ‘flexible enough…to needs not anticipated in the plan’ this could go further to encourage policy to fully accommodate and support as yet unknown employment land uses which will come forward in the future as our economy and the sectors within it change. Perhaps the starting point is getting it right for the current ‘known’ employment land uses including the range of spaces required by industry such as innovation hubs and the need for clustering. 

The role of employment land

The role of employment land is arguably, in a strategic Government context, to support economic sector growth. Little attention currently seems to be afforded to the importance or the nuances of this.

Brownfield land is prioritised, which makes sense from a densification and ‘re-use’ view point, but will not be applicable to all forms of development.

Logistics operations have specific locational requirements which often necessitate greenfield land adjacent to the strategic transport network. Likewise, the most productive location for some R&D investment might be land adjacent to an existing hospital or university for example, where synergies and cross over in resource and knowledge would best be realised. It may be that the land in the location required is not brownfield.

There should therefore be flexibility and appreciation of the specific locational requirements of different aspects of the employment land sectors.

Timeliness or tardiness?

In the opening section of the consultation document it explicitly states that it is vital for the necessary changes to be made to the NPPF ‘as soon as possible’. However, many of the potential revisions and (hopefully) improvements with regards to economic sectors and employment land are being parked for some other, un-disclosed, timeframe.

To truly achieve levelling up, the planning system needs to support the right approach right now. To be a ‘global leader in driving  innovation’^[4], we cannot hesitate. Waiting presents a missed opportunity to build a strong, competitive economy.

For more information please contact Amy Gilham.

16 February 2023

[1] Levelling-up and Regeneration Bill: reforms to national planning policy

[2] New report shines light on logistics sector role in UK economy

[3] British Property Federation report reveals: 280 football pitches of warehouses required to support Government target of 300,000 new homes

[4] National Planning Policy Framework