Comment
NPPF2 and employment land: Playing second fiddle to housing
In the face of economic uncertainty the revised NPPF presented an opportunity to firm up the somewhat lax approach to planning for the needs of business. In seizing this opportunity the revised framework emphasises the continued need to ‘support economic growth and productivity’ with planning policies helping to enable this via a ‘clear economic vision and strategy’ that ensures closer ties with Local Industrial Strategies and other local policies for economic development and regeneration (Paragraph 81).
The framework also reinforces some of the basic principles of good strategic planning, including the calls for planning policies to make ‘sufficient provision’ for employment (Paragraph 20), ‘identify strategic sites’ for local and inward investment (Paragraph 81) and ‘address the specific location requirements of different sectors’ (Paragraph 82).
The requirements for planning policies and decisions to ‘reflect changes in demand for land’ and be informed by ‘regular reviews’, previously set out in paragraph 22, also remain and are amplified within Paragraph 120 to promote the most effective use of land; therefore, enabling the release of employment land to meet housing and other needs where there is no reasonable prospect of the site coming forward for its intended use.
So what does the revised NPPF mean for employment land, integrated approaches to planning for housing and jobs, and our collective pursuit of shaping better places? How can developers, businesses, Local Planning Authorities (LPAs) and Local Enterprise Partnerships (LEPs) ensure effective planning for much needed employment land?
An own goal for effective strategic planning?
Housing need is not disputed. However, the apparent withdrawal of the Planning Practice Guidance (PPG) for Housing and Economic Development Needs Assessments , following the publication of the revised NPPF whilst the government reviews its approach, creates an open goal for the loss of employment land with potential economic development consequences. Although less prescriptive than that published for housing need, it nevertheless provided an important (and much needed) framework for robustly assessing economic/employment land needs, changes in demand and prospects for employment development across functional economic market areas.
The removal of the link between the standard method for assessing housing need and employment figures will also result in LPAs having the option of not considering future job growth and the potential role of housing supply in increasing the supply of local labour to fill these jobs. Based on recent precedents, this is likely to result in employment forecasts, policies and targets being subject to far less scrutiny, potentially leading to a lessening of economic ambition in some areas. We recently witnessed this at a Local Plan examination in public in the East of England.
There is also a danger that redundant employment land will be seen as an opportunity to meet housing needs, potentially at the expense of providing a positive approach to protecting and enhancing employment land supply to support economic growth.
Getting it right and making employment land matter
Ensuring there is a sufficient supply of employment land - of the right type and in the right locations – remains of paramount importance. Getting it right clearly matters; for local and inward investment, for business growth and critically for building a strong, competitive economy. However, in the context of an increasingly vague planning guidance there remains huge scope for LPAs to get it wrong, with Local Plans potentially accommodating far less employment land than might be needed.
The risks of underplaying need are profound and could hinder achievement of the Government’s Modern Industrial Strategy, as well as Local Industrial Strategies and targets for increasing economic growth and productivity set by LEPs or Combined Authorities (CAs).
Perhaps this is where the solution lies; LEPs acting as custodians of sites and premises supply, with more considered and commercially informed approaches to identifying economic development needs adopted as part of setting Local Industrial Strategies. This could include, for example, assessments of commercial property market conditions and the key location and property requirements of the LEP’s priority growth sectors, amongst other evidence, similar to that prepared by the Enterprise M3 LEP.
The expected role of LEPs as influencers of Local Plans could become more important in this regard, with their role in advancing robust sub-regional evidence helping in Local Plan preparation and in ensuring employment land supply and demand both within and across local authority boundaries are in balance. This should tie in closely with their preparation of Local Industrial Strategies.
If this is the case it will be important for UK Plc to engage in the process of devising these strategies in those areas where it has a vested interest. Businesses and commercial developers also need to be more forthcoming in articulating the need for employment land and working with policy makers to give them the evidence that will protect and enhance supply.
And if that doesn’t work, then is it time for national planning policy to learn from policy approaches being implemented at smaller spatial scales? The draft London Plan (March 2018) responds positively to halt historic loss of employment land to housing through policies which seek to accommodate both uses and reduce competition for sites. This includes no overall net loss of industrial floorspace capacity, as opposed to land, within designated Strategic Industrial Land and Locally Significant Industrial Sites (Policy E4); actively supporting intensification of industrial sites (Policy E7); and, encouraging mixed use (Policy E7).
The impacts of these policies on safeguarding employment land and its activities has yet to unfold but in the absence of more rigorous policy at the national level, authorities elsewhere should be encouraged to likewise consider creative solutions in developing holistic planning policy to support their economic growth
For more information on the impact of the NPPF on employment land please contact Gavin Amos or Amy Gilham.
09 August 2018