Chapter 7
84) Do you agree that more emphasis should be placed on relevant national strategies and the need for flexibility in planning for economic growth, as drafted in policy E1? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI supports the emphasis placed on national strategies but would welcome more emphasis on how this should inform approaches at a sub-regional scale, with fuller regard to the considerations set out in PM1(2)(c). As set out in response to Q15(a), the RTPI firmly believes that a National Spatial Framework is the most effective way of achieving this and we believe that economic development will be one of the greatest beneficiaries of such an approach. We note in E1 the approach to flexibility regarding development plans centres around them not being overly prescriptive about the types of uses that would be acceptable on particular sites. However, this does not consider what a flexible approach would meaningfully look like for SDSs and nor does it consider how such flexibility can be built into the review process for local or strategic plans.
A comprehensive and coherent approach to evidence bases needed to inform plan preparation will be necessary in order to achieve the aspirations of E1. In order to support its implementation, the RTPI would wish to see a review and update of the economic needs assessments, employment density guidance and whether the current use class order accurately reflects the character and composition of modern industry. Careful consideration will be needed as to how a development plan will meaningfully support the some of the proposed policy objectives. For example, how will inadequate infrastructure, services or housing, or a poor environment be identified as potential barriers to investment in a robust and consistent manner across the country? Furthermore, without a strong and clear policy connection it may be difficult to encapsulate the interplay between housing need and economic development aspirations.
Whilst the RTPI recognises the reference made to AI growth zones but we would welcome inclusion of decision-making and plan-making policy related to data centres specifically may be beneficial, especially when considering the benefits of co-locating such developments to providing waste heat and enabling digital sectors.
85) Do you agree with the approach to meeting the need for business land and premises in policy E2? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
Notwithstanding comments made in regard to Q84, the RTPI strongly supports the substantial weight afforded to meeting the need for business land and premises in E2. This includes recognition of the necessary differentiation across a range of different economic development uses, including modern arrangements for logistics encompassing last mile delivery infrastructure. We also note the flexible approach to economic growth is provided predominantly through development management in policy E2, E3 and E4. Read alongside E1 this highlights the difficult balancing act of identifying need strategically but providing adequate flexibility locally. We note some concern that establishing need in catchment areas could be complex. This includes reference to market signals, which may be interpreted in a very broad sense and may benefit from the provision of further clarifications or associated guidance to encourage a consistent approach. The process of identifying existing available land or buildings may also benefit from further guidance as it could prove a contentious element of this policy.
86) Do you agree with the proposed new decision-making policy supporting freight and logistics development in policy E3? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) Please provide your reasons, particularly if you disagree.
The RTPI understands why a standalone policy is considered appropriate for freight and logistics considering the specific locational and physical characteristics of such development. The RTPI believes this policy may benefit from a definition of freight and logistics and further details around locational matters for the purposes of applying this policy. Clarity would also be welcomed as to how such uses would engage S5. We note the policy approach to limiting environmental impacts in E3(1)(b) but would consider this relevant to all forms of economic development land use types. Therefore, in order to encourage a consistent approach to applying quality design and placemaking principles to developments, the RTPI believes this should be more effectively covered in regard to the design and placemaking chapter.
In regard to E3(1)(a), whilst the RTPI welcomes recommendations to ensure that development is sustainably located, this may be difficult regarding some development types, giving their locational and physical characteristics needing to be located close to trunk roads, thereby not constituting as sustainably located.
Clarification over E3(1)(c) regarding provision for sufficient and secure parking for lorries and other vehicles. It is not clear from the drafting whether this relates to short stay, waiting and loading, or is in relation to safety and welfare road use, noting that this is managed in TR5.
87) Do you agree with the approach to rural business development in policy E4? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly disagree.
a) Please provide your reasons, particularly if you disagree.
Currently as drafted, the RTPI does not feel this policy provides enough detail to enable development of rural businesses. We note, for example, very similar wording and approach regarding E2(1)(b) and E4(1)(d), which may therefore benefit from some consolidation and amalgamation. This is especially relevant given E2(1)(b) has substantial weight afforded to its consideration, whilst E4(1)(d) doesn’t. We also note that S5(1)(b) covers off a lot of the considerations as currently set out within this policy.
