ATCM Chief Executive's Blog

This section offers news and views about Town Centre related issues. Regular articles by Simon Quin are sure to get you talking about the issues of the day.

If you want to comment on any of these articles, you can email me with specific points at simon.quin@atcm.org or you can post thoughts and questions in the on-line Discussion Forum, though that option is only open to ATCM members.

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New planning policies; new challenge for local authorities
Tuesday 05 January 2010

The Government’s launch of new planning policy for town centres in England on 29th December 2009 contains much that is welcome. However, the real challenge will lie with how able local authorities are to assemble data, monitor their catchment areas and build an evidence base in the manner required under the new policy. If a major commitment is not made to this by every local authority there is a risk that we will once more see a significant rise in out of town development at a time when town centres need strong support.

The new PPS4 replaces PPS6 but retains the clear objective to promote the vitality and viability of town centres as important places for communities. It also seeks to promote competition between retailers and enhance consumer choice in town centres and to enhance the sense of place of individual centres. PPS4 makes clear that regional and local planning authorities should “prepare and maintain a robust evidence base” that understands existing business needs and likely market changes in order to support their development plans and development management. Annex C of the document sets out an extensive list of data sources and Policy EC1 explains how regional and local government should work together on this, and includes details on what should be included in determining quantitative and qualitative need for retail and leisure development. There is an accompanying Practice Guidance document which provides further information on this and which gives examples.

PPS4 retains the focus on regional planning bodies and local planning authorities needing to develop strategies for the “management and growth of centres” but recognises that some centres may be in decline and urges flexibility in such locations, including possibly reclassifying centres within the local and regional hierarchy to permit changes of use within the centre. The focus is also clearly on promoting competitive town centres (Policy EC4) and this includes a diversity of retailing including support for existing markets and the possible reintroduction or creation of new markets. The role of the evening and night time economy is also recognised and Policy EC4 makes it clear that local planning authorities have a key role to play in creating and managing this.

The importance of the evidence base is clear in the policy on site selection and land assembly for main town centre uses (Policy EC5). Local planning authorities are required to base their approach “on the identified need for development”. This is the fundamental underlying the whole approach to the new policy statement. If local authorities do not have a robust evidence base which clearly identifies what the needs for development over the plan period are, then it would appear to undermine all that follows.

PPS4 retains the sequential test (the ‘town centres first’) approach found in PPS6, and PPG6 before that, with the initial focus being existing centres and then edge of centre sites, with a preference for those “that are or will be well-connected to the centre”, and only then can out of centre sites be considered. A key change in PPS4 though is the introduction of a wider impact test which requires local authorities to assess the impact of proposed locations for development on existing centres. Proposed development locations in edge of centre or out of centre locations should not have “an unacceptable impact on centres within the catchment of the potential development”. There is also a requirement for the impact of development on sites within a town centre which substantially increases the attraction of that centre to be assessed to see how it impacts on other centres. What should actually be considered in assessing impact is set out in Policy EC16 which is concerned with planning applications for main town centre uses that are not in a centre and not in accordance with an up to date development plan. Once more it is very clear that consideration of impact will require local authorities to have a robust evidence base in order to consider factors such as town centre vitality and viability, in centre trade/turnover, current and future expenditure capacity, and potentially locally important impacts.

Where planning applications are received by local authorities for development of main town uses not in a centre and not in accordance with an up to date development plan, Policy EC17 states that such applications should be refused where they have not demonstrated compliance with the sequential test or where “there is clear evidence that the development is likely to lead to significant adverse impacts in terms of any one of the impacts set out in either Policy EC10.2 (general impacts relating to all planning applications for economic development) or Policy EC16 (those impacts specifically referring to main town centre uses).

PPS4 is also clear on the need for monitoring. It states in Policy EC9 that regional planning bodies and local planning authorities should use their annual monitoring reports to keep under review the network and hierarchy of centres, the need for further development and the vitality and viability of centres at a local level. It goes on to state that local authorities should “regularly collect market information and economic data, preferably in co-operation with the private sector” on a range of indicators set out in Annex D of the document, which is concerned with Town Centre Heath Check Indicators.

Although there is much to be welcomed in this new PPS and we are encouraged by the strong support for town centres, we are extremely concerned as to whether all local planning authorities will be able to respond consistently. Whether it be in allocating sites for development or considering applications for development outside existing centres that are not in accordance with an up to date development plan, there is a real challenge for local authorities to build a robust evidence base. The risk is that the evidence base will be short of detail and open to challenge by retailers and developers who wish to develop outside of established centres.

At this moment, we are concerned that much of what has been achieved by the town centre first policy in recent years could be under threat unless local planning authorities respond quickly and work with the private sector and other partners to develop the strong local evidence base. ATCM is therefore encouraging its members to work even more closely with planning officers and elected members to source data and information. We believe that initiatives such as Milestone, the new information portal for town centres, that we are launching in partnership with Springboard in March this year, will make an important contribution to this. The online ATCM HealthCheck can also assist in obtaining a qualitative perspective and we are reviewing this in the light of the new PPS so that it is even more relevant. However, we remain concerned that local planning authorities are being asked to undertake extensive work without the resources available to do it. If the work is not done, then the whole system will be undermined.

Full details of the new planning policy can be found here: