Picking through the latest NPPF: a commercial planning consultant’s POV

By simplifying land into urban and rural categories - Policies S4 and S5 relating to the principle of development inside and outside settlements - this latest NPPF does not acknowledge that employment development prefers locations that are accessible for the products created in most manufacturing businesses.

In our experience, the first priority for the location of a commercial operation is not whether the site is urban or rural but whether it is close to a road network in order to take advantage of the supply and delivery efficiencies.

Allocating sites and determining applications based on whether they are simply inside or outside a settlement area, as set out in this latest NPPF, misses this important piece of the locational jigsaw.

Businesses supplying products nationally need to be located adjacent to the national road network not just local A roads.

Businesses in regions such as the East Midlands and East Anglia are not alone in relying on the international supply chain via ports linked with the European mainland.

A research exercise we undertook in one local authority area in the East discovered that hardly any of the allocated sites in a 10-year old Local Plan had been developed because they were inappropriately located for these type of accessibility links.

We are not just referencing the 'big shed' warehouse operators who have these requirements, but the significant contribution made by SME businesses, including the many start-ups, grow-ons and small scale operations.

While, it is positive that the NPPF does acknowledge the need to accommodate big sheds, high tech and data centres in specifically referencing them, it is disappointing that the new Framework does not distinguish between types of business development or acknowledge that businesses located outside settlements are not necessarily related to agriculture.

There is a contradiction in emphasis between Policy E2 which states that 'substantial weight should be given to the economic benefits of proposals for commercial development' to support business growth and Policy S5. The latter policy only permits development if it is on a list which, in this context, includes reusing or replacing an existing building - which hardly constitutes much-needed economic growth or expansion - or where it would address an 'evidenced' unmet need.

However, the paragraph that developments not on the list '…should only be approved in exceptional circumstances, where the benefits of the proposal would substantially outweigh the adverse effects, including to the character of the countryside and in relation to promoting sustainable patterns of movement..' is helpful.

Thus, transport network locations where the countryside is not of a tranquil or valued character should be able to be argued as being exceptional circumstances.

In accommodating the latest National Planning Policy Framework, we will, as ever, continue to work hard to demonstrate that proposals by all our clients - including those who are SMEs - are supported with evidence for locations that are appropriate to their commercial business needs.