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Draft PPS4

Date: 10/7/2009

This response is made on behalf of the Planning Officers Society (POS).

The Planning Officers Society represents the most senior professionals and managers of planning functions in the English Local Authorities.  We set out to:

  • Act as an advocate and promoter of Local Government planning.
  • Assist and advise the Government and the Local Government Association on planning matters and related issues.
  • Act as a centre of excellence, undertake research and promote best practice in planning matters.
  • Promote all aspects of the built and green environment by working closely with other organisations and professions.


The Society's aim is to ensure that planning makes a major contribution to achieving sustainable developments, from national to local level, in ways, which are fair and equitable and achieve the social economic and environmental aspirations of all sectors of the community.

Introductory Note

Draft PPS4 will :

  • Update draft PPS4 - Planning for Sustainable Economic Development
  • Update draft PPS6 - Planning for Town Centres
  • Consolidate national planning policy on economic development into single streamlined PPS

Eventually it will replace :

  • PPG4 - Industrial & commercial Development & Small Firms
  • PPS5 - Simplified Planning Zones
  • PPS6 - Planning for Town Centres
  • Economic Development parts of PPS7 - Sustainable Development & Rural Areas
  • Parts of PPG13 Transport

Purpose of Draft :

  • Bringing together key national planning policies relating to the economy to create a coherent & modern set of flexible, proactive development Plan policies to meet the economic challenges of today & the future & help the economy prepare for the recovery
  • Greater certainty for business in terms of speedier planning decisions
  • Underline the need for regional planning bodies and LPAs to plan positively & proactively for economic development in their areas,
  • Emphasise the contribution planning can make to help deliver jobs investment & improved productivity.
  • Implement recommendations from Matthew Taylor review of rural housing & economic development.

 Some Key Policies/messages in the PPS

  •  Considering planning applications for economic growth favourably unless there are good reasons to believe that the costs outweigh the benefits
  • Encouraging local authorities to use tools such as simplified planning zones to speed up the planning process
  • Removing the requirement for developers to submit a needs test, retaining the need for developers to seek the most central sites first in a sequential test & a tougher impact test that covers a wide range of indicators and that assesses proposals against economic, social & environmental impacts on a town centre.
  • Providing for sustainable economic growth in keeping with the need to protect the countryside
  • Maintaining a strong focus on accessible centres and Town Centre first in pursuit of sustainable development principles through emphasising the importance of cities & towns by safeguarding town centres that are key drivers of the economy and the centres of community life.

Key issues to be welcomed:

  • The early review of policy statements & integration of national policy on economic development into a streamlined policy framework for planning economic growth in urban & rural areas is a more comprehensive and cohesive approach to planning for local economies than has previously been the case.
  • The recognition of the linkage between urban & rural economy and that there is no such thing as a separate rural economy and the acknowledgement of the importance of small scale economic development serving rural settlements
  • The structure of the draft which separates policy at plan making and policy directed at decision making with both being supported by appropriate evidence and which has become a familiar part of the preparation of Core Strategies and significant planning applications
  • The encouragement for a flexible evidence based approach to economic development requiring provision for a diverse range and type of businesses that focuses on regeneration and areas of need
  • The shift in focus on outcomes through planning positively & proactively for economic development  & the recognition of the role planning can have in delivering jobs, investment and improved productivity
  • Maintaining a commitment to strong town centres which should not be lost through the merging of the documents; looking at the impact test in an holistic way and on encouraging competitiveness and diversity.
  • Clarification of the role of housing is welcome and that whilst house building can be regarded as a form of economiuc activity the governments policies are contained separately in PPS3 and clarification that whilst a broad range of business activities is implied for business sites, it is not the intention to encourage town centre uses on them
  • The retention of the 'needs'test at the development plan stage is welcome as it provides an element of certainty and enables planning to be undertaken in an integrated manner, taking into account socio-economic change over the plan period and ensures a plan led process.

Areas of concern or need for clarification

  • The format of the document differs from existing PPSs in that specific policies are set out for local authorities to adhere to. Clarity is required as to how prescriptive these policies are. There appears little scope or discretion for local authorities in employment policies other than for example size and disposition of employment land allocations.
  • In general the document advocates a positive and constructive approach towards economic development proposals together with what appears to be an amended balance in favour of this element over social and environmental considerations. However both social and environmental as enshrined in PPS1  must be given due consideration within PPS4
  • Removal of the needs test may encourage more out of centre retail proposals. Such large-scale proposals tend to cater mainly for car borne access. Having regard to the government's aim of reducing reliance on the private car, clarification would be helpful on how such proposals would be justified in the absence of demonstrated need. Developers may feel encouraged to bypass the plan making process and pursue development through planning applications, undermining the plan led process
  • Broadening thedefinition of economic development together with a general presumption in favour of economic development proposals could lead to a broader range of uses on employment sites strengthening the hands of developers claiming an inability to find suitable alternative sites for development, employment sites being a cheaper alternative and taking important business land out of the business supply. The presumption in favour could also encourage developers to bypass the plan making process and pursue development through planning applications undermining the plan making process
  • PPS4 clarifies that offices are a town centre use which is to be supported. Ancillary office facilities elsewhere are supported and this too is welcome. However, it needs to be acknowledged that in some instances non-speculative office development, which may be lost to a district or region can be considered in other accessible locations. Failure to acknowledge the need for out of centre offices in appropriate circumstances could result in lost investment and jobs.
  • Need to recognise the contribution of recycled land in the land supply projections resulting from the natural turnover of sites. There should be reference to retaining good quality buildings in employment uses. Both are key components of a regions economy and the planned provision for its sustainable development
  • The PPS is not specific on the issue of protecting employment land for economic development purposes or on ensuring that strategic employment sites remain used for the strategic purpose intended. However the requirement to review existing and future supply and to assess detailed need for employment land over the LDF period could imply policies of protection are appropriate. Clarification is required.;
  • Clarification of town centre uses is given and although broad those identified are mainly commercial. Consideration should be given to include public service buildings community and cultural uses as town centres have more than an economic remit
  • The well understood tensions between rural economic development and green belt policies are not addressed with the PPS remaining silent on the subject.
  • There is a lack of reference to the SNR process now being developed in the light of the Local Democracy, Economic Development and Construction Bill. No account is therefore taken of a single integrated regional strategy SIRS or link to Regional Funding Allocations
  • The draft focuses on the need to prepare an evidence base to understand and respond to existing business, leisure and retail needs and to prepare Local Economic Assessments. Whilst there is support for the development of a robust and comprehensive evidence base, there will be significant implications for LPAs who continue to struggle with the resources required to undertake such assessments.
  • The important link between housing and employment appears fairly quiet apart from the reference to housing being addressed in PPS3.



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