Policies intended to support the long-term vitality and viability of town centres remain a central part of the draft NPPF, set out in Section 8. At first reading the proposed approach appears largely unchanged, with both the sequential and impact tests retained. However, subtle shifts in emphasis could have important consequences.

The revised wording suggests that the sequential test may apply only to ‘new’ development. In addition, the accompanying Consultation Document raises the possibility of removing the test altogether. The reasoning provided is that the introduction of Class E already limits the circumstances in which the test is used, and that sustainable transport policies, particularly Policy TR3, could instead take on this role.

Although accessibility is an important consideration, the sequential test has always served a wider purpose. Whilst sustainable travel benefits are inherently associated with town centre locations, the sequential test also gives these areas a degree of positive preference. Development in town centres is often more complex, more costly and takes longer to deliver. Without clear policy support, the investment many centres urgently require may not materialise.

If the test were removed, developers would only need to demonstrate that their proposals are, or could be, located in places that reduce the need to travel and offer a choice of transport modes. When combined with the draft policy’s general encouragement of development within settlements under Policy S4, this would make out of centre retail and leisure schemes significantly easier to bring forward. Although the current sequential test is not perfect, it remains the only mechanism that prioritises in centre and then edge of centre opportunities. Without it, there is a real risk of increased out of centre development, which could negatively impact both town centre vitality and viability, and future investment.

Another notable proposed change is the removal of the requirement to define Primary Shopping Areas for larger town centres. This is a sensible step, given that the introduction of Class E means that planning policy can no longer restrict town centre uses to retail alone, nor should they. Successful centres depend on a wider and more adaptable mix of uses, and rigid Primary Shopping Area boundaries are unlikely to support their long-term vitality.

Planning policy needs to continue to champion town centres in a way that secures their resilience and ensures they remain at the heart of thriving communities, but also recognises that some restrictions on out of centre development continue to be required.

If you would like to discuss what these changes could mean for your town centre projects, contact a member of our Town Centres & Economic Regeneration team below.