Chapter 8
88) Do you agree with the proposed changes to policy for planning for town centres? 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 supports the direction of travel of the proposed changes to planning for town centres. This includes the retention of the core principle that main town centre uses should be located within existing town centres but also on the policy emphasis aimed at diversifying town centre use to bring in more residential accommodation. The RTPI welcomes the emphasis placed on a plan-led approach in TC1, which is especially important in achieving the objective of reflecting locally distinctive roles and opportunities for town centres. In order to ensure this approach is taken forward, it is important that we take positive and significant steps towards full plan coverage across the country, a matter dealt with in response to Q9(a).
To support consistent application of this new national decision-making approach to town centres, the RTPI would strongly recommend an update of the respective PPG. Such an update could set out a clearer role for SDSs in terms of supporting town centre regeneration at a sub-regional level. We would further welcome a clearer consideration of how developing town centres strategies can work alongside and align with a vision led approach to planning for transport as set out in TR1.
To further support the application of this policy the RTPI would welcome further consideration of the detail set out within the glossary definition of ‘town centre uses’. The institute would welcome the addition of civic and community facilities but would also recommend drive-through restaurants be removed, considering the clear tension of such development types with policies set out in Chapters 14-17.
89) Do you agree with the approach to development in town centres in policy TC2? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Strongly agree.
a) If not, please explain how you would achieve this aim differently?
The RTPI supports the substantial weight attributed to strengthening the long-term vitality and viability of town centres, with a particular focus on diversification and residential. To strengthen this policy the RTPI would further recommend reference to supporting the visitor economy and heritage led residential schemes. A clearer understanding of what would be considered as a part of the day-to-day services set out in TC2(1)(b) will support its implementation.
90) What impacts, if any, have you observed on the operation of planning policy for town centres since the introduction of Use class E?
We note the work published by PAS on the matter in 2023, which highlighted some benefits such as an increase in cafés and restaurants and office space in existing vacant retail premises. We do note some concern around the loss of active frontages and potential impacts on residential amenity from new restaurant and café use types. However, some of the unintended consequences have occurred out of town centres. As a result of the change, formerly B1 properties (offices, research, light industrial) can be occupied by retail which can occur out-of-town without needing to be considered in town centre locations first.
Ultimately, the introduction of Use class E, has led to a substantial weakening of the sequential test and without a disaggregation of this Use class, the RTPI does not consider the sequential test fit for purpose any longer. The RTPI notes the suggestion in the consultation document that reliance could instead be placed on policies for sustainable transport to make sure developments are in suitable locations. In the event that the sequential test is removed we would wish to see a comprehensive and detailed proposal for how such policies could be implemented. This will have consequential implications for a significant proportion of the proposed Framework, including proposals for vision-led transport planning.
91) Do you believe the sequential test in policy TC3 should be retained? Strongly agree, partly agree, neither agree nor disagree, partly disagree, strongly disagree.
Partly disagree.
a) Please provide your reasons, particularly if you disagree.
In order to fully understand the proposed approach, the RTPI would welcome greater clarity over how the new approach to disaggregation in TC3(3) would be expected to work. As set out in response to Q88 and Q90, if the sequential test were to be removed and instead decision-making was instead to focus predominantly on sustainable transport considerations, the enhanced connection between the vision led transport planning and town centre approaches would be a critical consideration. The RTPI would also seek better clarity over how proposals would be considered in line with policy provisions in S5 and GB8.
92) Do you agree with the approach to town centre impact assessments in policy TC4? 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 would welcome the provision of guidance noting the potential difficulties in preparing impact assessments in accordance with TC4(2) without an up-to-date local plan in place.
