Comment

The need for planning parity in ‘building a Britain fit for the future’

Over the last twelve months two words have dominated the political landscape; ‘Brexit’ and ‘equality’.

As we move forward into a post-Brexit economy it is therefore disappointing that the government has failed to recognise the important role the planning system has to play in ‘building a Britain that is fit for the future’ (the Government’s name for the UK’s Industrial Strategy). The revised draft National Planning Policy Framework (NPPF) removes any emphasis on ensuring that local planning authorities recognise the equal importance of planning effectively for both their housing and employment needs.

Revising the NPPF presented the ideal opportunity to address this imbalance following on from the publication of the Industrial Strategy White Paper last November. More than simply a missed opportunity, this signifies a lack of political appetite to provide an effective planning framework for identifying and delivering new employment sites. Unless of course the site is to be used for one of the Industrial Strategy’s ‘high-value’ businesses.

This policy vacuum has particular relevance to key growth sectors such as logistics, which form the ‘backbone of British industry’[1]. Logistics development facilitates the local deliveries and international trade underpinning all other sectors within our economy – it really matters. In Turley’s 2015 research paper ‘Delivering the Goods’, we reported that the logistics sector generated around £100bn in GVA across the UK. Just two years later, the Freight Transport Association reports that this has increased to over £124bn, equating to 11% of the UK’s non-financial business economy[2].

The canary in the coal mine

It is therefore essential that the revised NPPF is geared up to positively influence local plan policies and land allocations to support key growth sectors such as logistics. However, the ‘canary in the coal mine’ is evident early on in the draft revised NPPF with a proposed watering down of the economic objectives of the planning system in paragraph 7. Whilst it recognises that the planning system should ‘help build a strong, responsive and competitive economy by ensuring that sufficient land of the right types is available in the right places at the right time’, the revisions remove the need for the planning system to identify and co-ordinate development requirements as part of this.

So what clarity and direction does the draft revised NPPF provide on how to build a strong and competitive economy? The answer simply is very little. Planning policies must still identify strategic sites to meet anticipated needs over the plan period, but no clarity is provided on how this should be identified, maintained and delivered through the local plan process. This provides no clear policy impetus for local plans to facilitate timely changes in market demand within dynamic sectors such as logistics, whose development requirements are often influenced by local, national and international priorities.

Other than a brief mention within the draft National Planning Practice Guidance (NPPG), there is still no requirement within the draft revised NPPF for a joint Strategic Housing and Employment Land Availability Assessment to be undertaken during the plan making process, or for local authorities to identify a mixture of small and large sites to meet the needs of end users. In stark contrast to the proposed housing policies outlined in paragraphs 74-76 of the draft, local authorities are also not required to maintain and review annually a five year supply of employment land or plan for a ‘margin of choice’ to their land demand forecast calculations.Planning for this additional amount of land would ensure a reasonable choice of sites for businesses and developers and allow for delays in sites coming forward.

The impact of not planning effectively for employment needs is that it stifles the opportunity for the UK to prosper. Not only through denying developers the opportunity to regularly promote land through the local plan process for their pipeline of end users, but also by limiting the options available for existing companies to expand onto readily available sites. Stifled opportunity also comes in the form of the UK missing out on overseas investment as inward investors struggle to find the land they need for their new business requirements and settle for locations abroad. The simple equation is that without the sites, our businesses will struggle to grow and the UK will not only run the risk of missing out on overseas investment but also on all the associated jobs that this could bring.

Levelling the playing field

Whether we look at its current or draft revised form, the NPPF is not sophisticated enough to respond quickly to the market forces that govern the dynamics of high growth sectors such as logistics and does not provide the tools for plan making to be ‘sufficiently flexible to adapt to rapid change’ (paragraph 11) and ‘changes in economic circumstances’ (paragraph 83d).

The draft revised NPPF recognises in paragraph 20 that ‘each local authority should include those policies and strategic site allocations necessary to provide the homes and workplaces needed for the area’. To do this effectively, the revised NPPF should be clear in requiring local planning authorities to undertake a joint assessment of their housing and employment needs, recognising their interdependence. As with planning for housing growth, local authorities should also be required to plan for a five years’ supply of employment land, which should be reviewed annually or with ‘trigger mechanisms’ for review in place to ensure adequate supply is identified to meet market demand.

Where the draft revised NPPF requires planning policies and decisions to make ‘effective use’ of land it should also provide a mechanism to ensure that this does not prejudice the growth of businesses within sectors such as logistics whose requirements are changing as the sector continues to innovate and grow. An employment site which has little market interest now may see this change in the future and planning policy should not provide an easy opportunity for such sites to be lost to residential uses.

Paragraph 72 outlines the circumstances in which it would be acceptable for housing sites to come forward on sites which are not allocated and outside settlement boundaries. To level the playing field, it is crucial that an equivalent policy is put in place outlining the circumstances for employment sites to come forward on ‘exception sites’ and the level of investment, GVA and job creation should be key considerations within this policy.

Whilst it is positive that the draft NPPG recognises the importance of joint working across borders when planning for business needs more can be done to level the playing field between housing and employment policies in the draft NPPF. The changes aforementioned would ensure that both housing and employment needs are given equal importance within the plan-making process and would be a step in the right direction to ensuring that national policy provides the mechanisms that British industry deserves to enable it to build a Britain that is fit for the future.

Further Turley commentary on the draft revised NPPF is available here. 

[1] David Wells, Chief Executive, Freight Transport Association

[2] Freight Transport Association Logistics Report, 2017

22 March 2018