This will compare PPS4 on retail and town centres with the NPPF practitioners draft section on this (pages 19-21). This will not be easy as this is arguably the most complex area of current national policy.
The objective of policy on town centres is, much same as before, just precised.
|recognise town centres as the heart of their communities and pursue policies to support the viability and vitality of town centres
||promote the vitality and viability of town and other centres as important places for communities. To do this, the Government wants:– new economic growth and development of main town centre uses to be focused in existing centres, with the aim of offering a wide range of services to communities in an attractive and safe environment and remedyingdeficiencies in provision in areas with poor access to facilities– competition between retailers and enhanced consumer choice through the provision of innovative and efficient shopping, leisure, tourism and local services in town centres, which allow genuine choice to meet the needs of the entire community (particularly socially excluded groups)– the historic, archaeological and architectural heritage of centres to be conserved and, where appropriate, enhanced to provide a sense of place and a focus for the community and for civic activity
With a bit of tweaking I think the NPPF could express a more positive tone. The High Street is in trouble, it needs a more intensive focus of efforts to secure their competitiveness. I would suggest:
‘Promote town centres as the heart of their communities, needing policy and action to innovate, secure investment and compete to ensure their long term viability and vitality. Policy needs to be realistic to the long term prospects of an area’.
The overall focus of the policy is much as before,
|Local planning authorities should plan positively to promote competitive town centre environments and set out policies for the management and growth of centres over the plan period.
||local planning authorities should, as part of their economic vision for their area, set out a strategy for the management and growth of centres over the plan period.
In terms of planning the retail hierarchy again the policy is very similar, but much shorter. Nothing is really lost as the rest of this section of PPS4 is grandmother sucking eggs stuff.
|Define a network (the pattern of provision of centres) and hierarchy (the role and relationship of centres in the network) of centres that is resilient to anticipated future economic changes.
||Define a network (the pattern of provision of centres) and hierarchy (the role and relationship of centres in the network) of centres that is resilient to anticipated future economic changes, to meet the needs of their catchments having:i) made choices about which centres will accommodate any identified need for growth in town centre uses, considering their expansion where necessary, taking into account the need to avoid an over concentration of growth in centres. Identified deficiencies in the network of centres should be addressed by promoting centres to function at a higher level in the hierarchy or designating new centres where necessary, giving priority to deprived areas which are experiencing significant levels of ‘multiple deprivation’ whereii) ensured any extensions to centres are carefully integrated with the existing centre in terms of design including the need to allow easy pedestrian accessiii. where existing centres are in decline, considered the scope for consolidating and strengthening these centres by seeking to focus a wider range of services there, promoting the diversification of uses and improving the environmentiv. where reversing decline in existing centres is not possible, considered reclassifying the centre at a lower level within the hierarchy of centres, reflecting this revised status in the policies applied to the area. This may include allowing retail units to change to other uses, whilst aiming, wherever possible, to retain opportunities for vital local servicesv. ensured that the need for any new, expanded or redeveloped out-of-centre regional or sub-regional shopping centre or any significant change in the role and function of centres is considered through the regional spatial strategy
It is important the NPPF clarifies the role of the ‘duty to cooperate’ on sub-regional centres and boundary issues.
‘Where an existing centre serves a wider catchment than the local planning authority or a new or expanded sub-regional centre is proposed it is important that, as far as possible, the duty to cooperate leads to a common strategy leading to an agreed approach on the centres role’.
Otherwise we will be back to the age of lengthy public inquiries on the Lakesides and Bluewater Parks of this world.
On planning for sites.
|Allocate a range of suitable sites to meet the scale and type of retail, commercial, community services and residential development required in town centres. This should include an assessment of the need to expand defined town centres to ensure a sufficient supply of suitable sites. It is important that retail and leisure needs are met in full and are not compromised by limited site availability. Local planning authorities, therefore, should undertake an assessment of the need to expand town centres to ensure a sufficient supply of suitable sites;allocate appropriate edge of centre sites where suitable and viable town centre sites are not available, and if sufficient edge of centre sites cannot be identified, set policies for meeting the identified requirements in other accessible locations;set policies for the consideration of retail and leisure proposals which cannot be accommodated in or adjacent to town centres;Local planning authorities should apply a sequential approach to planning applications for retail and leisure uses that are not in an existing centre and are not in accordance with an up to date Local Plan.
||Local planning authorities should identify an appropriate range of sites to accommodate the identified need, ensuring that sites are capable of accommodating a range of business models in terms of scale, format, car parking provision and scope for disaggregation. An apparent lack of sites of the right size and in the right location should not be a reason for local planning authorities to avoid planning to meet the identified need for development. Local planning authorities should:a. base their approach on the identified need for developmentb. identify the appropriate scale of development, ensuring that the scale of the sites identified and the level of travel they generate, are in keeping with the role and function of the centre within the hierarchy of centres and the catchment servedc. apply the sequential approach to site selection (see policy EC5.2)d. assess the impact of sites on existing centres (see policy EC5.4).e. consider the degree to which other considerations such as any physical regeneration benefits of developing on previously-developed sites, employment opportunities, increased investment in an area or social inclusion, may be material to the choice of appropriate locations for development
The section starts off fairly well, (although it repeats almost the same sentence twice), but:
- Unlike existing policy no real definition of town centre uses, despite being used twice in footnotes in defining other concepts.
- ‘Required in town centres’ could be used by the likes of Walmart to argue that they are required elsewhere. It is less strong than the previous concept of assessing need then allocating it sequentially. We are now talking about requirements
- It looks at the need to expand town centres to accommodate the totality of uses, not just retail and leisure. It might usefully refer to the need to intensify and expand town centres.
- The business models qualification has been dropped, as worded it could never be met and perversely disincentivised positive site identification in town centres. A salutary lesson in what happens when BIS official write planning policy.
- ‘Assessment of the need to’ is too limp.
- The ‘role and function in the hierarchy- level of travel’ test is important. The town centres first approach is undermined, as has sometimes happened, if local centred are allocated excessive development (in which case the needs and impact tests dont apply – see the Sainsburys Clapham Common court cases) -‘Out of town in town’.
- It confusingly sets out the sequential approach and impact as applying only to applications on unallocated sites outside town centres, whilst a version of the sequential approach without the impact assessment, applies to plan making. This again is a perverse disincentive to positive plan making when issues of the impact of the expansion of one centre on another apply. Plans for expansion of one town centre could be undermined by inappropriate out of town in town at another.
I would suggest this part is rewriten
‘The key policy is that town centres are the first choice for retail, leisure and other uses attracting a lot of people (main town centre uses). Town centres are also important as places for higher density housing and the full range of other facilities contributing to vital communities. Large office and community facilities uses are also appropriate in areas with good public transport accessibility
Plans should allocate in town centres a range of suitable sites to meet the scale and type of assessed requirement for main town centre uses, as well as for housing and mixed uses; appropriate to the role and function in the network and hierarchy of centres, and their accessibility to a choice of means of transport. It is important that retail and leisure needs are met in full and are not compromised by limited site availability. Therefore plans to expand and intensify town centres should be drawn up and delivered in partnership with business and local communities to ensure a sufficient supply of suitable sites.
If this requirement cannot be met in full in existing and expanded centres other locations should be assessed:
a) in line with the sequential appproach; &
b) by an assessment of impact on existing centres and on their plans for expansion’
LPAs are required to
define the extent of the town centre and the primary shopping area, based on a clear definition of primary and secondary frontages in designated centres, and set policies that make clear which uses will be permitted in such locations.
The definitions of edge of centre and primary shopping area are much the same as before however the edge of centre defintion drops off all of the clarifications on ease of walkability that have been established in landmark appeals. A slightly expanded defintion is needed.
In the next post ill look at the sequential approach and the impact test.